Comment

Representation ID: 22188

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

We would expect to see within the "water" section of the policy 4, a specific policy or reference to ensuring that foul drainage infrastructure is provided in a timely manner ahead of occupation of new properties. This is hinted at in paragraph 227 "...Taking account of the above evidence, the policy therefore commits the Greater Norwich authorities to lobbying for the timely delivery of improvements to the waste water network by Anglian Water." This could be improved to say " taking account of the above evidence, the policy therefore commits the Greater Norwich authorities to lobbying for the timely delivery of improvements to wastewater infrastructure by AW in line with development time scales, ensuring there is sufficient capacity ahead of occupation of properties." Wastewater infrastructure is the most important pressure on environmental water quality, and growth and development has the potential to reduce the efficiency of that infrastructure leading to major problems. Wastewater treatment and the quality of the water environment should be addressed in the Local Plan to ensure there is infrastructure to support sustainable growth and there is no deterioration of water quality. This point addressing in this section.
From looking at the site allocations, there seems to be significant amounts of development surrounding Aylsham. Aylsham WRC currently only has room to accommodate around 160 dwellings before it reaches capacity. This is a fraction of the development proposed in this area. We would therefore expect to see Aylsham WRC listed here with plans for sewerage infrastructure and WRC upgrades (there are no capacity upgrades planned for AMP7 here). Paragraph 314 states that Anglian Water Services has plans to increase capacity at Aylsham WRC - this is new to us and it would be useful to see some evidence of this.
Given the number of dwellings proposed, the Plan should outline the importance of early consultation with Anglian Water about potential options for foul waste in this area. Paragraph 228 makes reference to the Norwich Water Cycle Study (WCS) which is reassuring to see. This paragraph would benefit from expanding on this to explain how outputs and recommendations from the WCS will be used to inform development within the districts.