Comment

Representation ID: 22181

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Environment (page 34)
In regards to paragraph 130, there is an enormous challenge in finding water for new developments. We don’t currently have the technology with no consumptive use of water. Some technologies being considered could produce high amounts of carbon e.g. desalinisation, pumping water from other areas. This should be recognised here and the fact that we need to be thinking more holistically about water use for example increasing infiltration and groundwater recharge in headwaters. Using slow the flow techniques and retrofitting water saving measures to existing properties could be considered. We would suggest the following addition: "New water efficient buildings will have also contributed to the protection of our water resources and water quality, helping to ensure the protection and encourage enhancement of our rivers, the Broads and our other wetland habitats". This section should discuss the importance of ensuring that new development does not result in a breach of environmental legislation. A breach of legislation due to the increased polluting load from wastewater treatment works serving those developments.
It is not clear how greater efficiency in water and energy usage will minimise the need for new infrastructure – any new development will still require connection to facilities such as sewerage, mains water and electricity supply; as well as transport links.
Water efficient building can contribute to the protection of water resources, however more people, more buildings and more infrastructure will inevitably lead to greater pressure on the broads and wetland habitats. The plan should insist that all new development is required to aim for 100% retention of surface water through a variety of means. This is the opportunity to raise the bar for development in the GNLP area.
The plan should be clear in stating that there is the need for new developments to incorporate water saving and grey water recycling technologies, sustainable heating solutions and good insulation for example.
Paragraph 133 should mention the importance of trees in providing climate resilience through increased percolation rates (reducing flood risk), shading and cooling rivers in as well as urban and rural areas (also contribute to net zero carbon emissions).