Policy 2 refers to residential developments being required to mininise water consumption by meeting the optional requirement of 110 litres/per person/per day and that the highest possible standard with be applied over the plan period.

Anglian Water and the Environment Agency has issued advice to local planning authorities (copy attached) stating that there is evidence to demonstrate a need for optional water efficiency standard to be applied in the Anglian Water supply area. As such we fully support the inclusion of this standard in the policy.

We fully support the intention that development proposals will be expected to meet the current standard water efficiency rather than be limited to the existing standard. This is particularly important given Defra’s recent consultation on personal consumption of water which included reference to potential changes to existing building regulations on water efficiency.

Anglian Water is keen to promote the development of ‘Water smart communities’ including as part of the Local Plan. They use a more holistic and integrated approach to water management with the aim to:

• Enhance liveability by contributing to green streetspaces and high quality open space
• Promote the sustainable use of water resources and infrastructure to enable growth
• Build resilience against the impacts of climate change and extreme weather events
• Contribute to natural capital and biodiversity through multi functional water features
• Deliver water efficient homes to reduce household bills and support affordability

Opportunities for a more holistic and integrated approach to water management should form part of the plan, to encourage multi-functional water management assets which support other community objectives. This approach combines different elements of water management (e.g. combining SuDS with a water re-use system to both manage runoff and provide an alternative non-potable water supply) together with town planning and design (e.g. integrating the planted SuDS features throughout a development to contribute to ‘greener’ streetscapes).

In our previous comments on the Local Plan we had made detailed comments relating to text to be included in Policy FR1 in relation to surface water management, foul drainage and sewage treatment. This wording doesn’t appear in the Draft Local Plan and there is also no specific policy relating to flood risk which would apply to development proposals.

It is therefore proposed that Policy 2 is amended as follows:

‘Minimise flood risk, including reducing the causes and impacts of flooding, supporting a through [catchment] [text to be deleted] [an integrated] [new text] approach to water management [and] [text to be deleted] including the us[e][new text][ing] [text to be deleted] of sustainable drainage [systems and water efficiency and re-use measures.] [new text]

[Applicants are to demonstrate they have followed the surface water hierarchy for all proposals as follows:
a) Water re-use at point of run-off;
b) Discharge by infiltration to the ground;
c) Discharge to an open surface water body;
d) Discharge to a surface water sewer;
e) Discharge to a combined sewer;
No surface water connections are made to the foul sewer system and connections to the combined or surface water system is only made in exceptional circumstances where it can be demonstrated that there are no feasible alternatives (this applies to new developments and redevelopments); ] [new text]

Development must also protect water quality and be water efficient. To achieve the [latter] [deleted text] [this] [new text]:

That adequate sewage treatment capacity and foul drainage already exists or can be provided in time to serve the development; ] [new text]

Housing development will meet the Building Regulations part G (amended 2016) water efficiency higher optional standard;

Non-housing development will meet the BREEAM "Very Good" water efficiency standard, or any equivalent successor;
If the potential to set more demanding standards locally is established by the Government up to 2038, the highest potential standard will be applied in Greater Norwich.
[Development proposals should include water re-use measures, including grey water recycling, surface water or rainwater harvesting, where practicable;

Suitable access is to be safeguarded for the maintenance of existing water supply and drainage infrastructure following development.] [new text]

Reference is made a high standard of amenity in connection with transport impacts but not in terms of existing uses.It is suggested that applicants should also demonstrate that proposed developments would not be adversely affected by the normal operation of Anglian Water’s existing assets e.g. water recycling centres (formerly sewage treatment works).

Nuisance may be caused by noise, lighting and traffic movements but its most prevalent source will be odours, unavoidably generated by the treatment of sewerage.


It is therefore recommended that Policy 2 or another policy should include the following wording:
‘Proposals for development adjacent to, or in the vicinity of, existing uses will need to demonstrate that both the ongoing use of the neighbouring site is not compromised, and that the amenity of occupiers of the new development will be satisfactory with the ongoing normal use of the neighbouring site’