Comment

Representation ID: 22190

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Paragraph 330 states that “Anglian Water plans to increase capacity at the local water recycling centre at Wymondham to serve growth”. There needs to be a clear policy added to this document, specifically regarding ‘Foul Infrastructure’. This policy should include a clause to ensure that foul drainage infrastructure and treatment is provided in a timely manner ahead of occupation of new properties. In order to protect the local water environment and existing households/residents from issues with foul flooding, planning permission should be granted once delivery of infrastructure within appropriate timescales has been secured.
For several of the "Main Towns" listed there is a statement similar to: "Anglian Water plans to increase capacity at the local water recycling centres at ..."
It is good to see that Anglian Water are being consulted at this early stage on development. However, there are several WRCs where this statement has been added despite there being no scheduled upgrades to WRC treatment capacity in AMP7. Beyond AMP7, it is difficult for Anglian Water Services to commit to upgrades due to uncertainty surrounding funding availability for upgrades to treatment which is assessed through their Asset Management Plan process. We would suggest a caveat surrounding funding availability is added to this sentence.
Several of these WRCs are also close to their existing permit - so to accommodate the growth Anglian Water will need to apply for a new discharge permit. Given the sensitivity of a number of watercourses within the Greater Norwich area, there could be constraints on the permit due to very tight permit standards/permit standards not being achievable with conventional treatment. Therefore, it is essential that contingency options are assessed and the outputs and recommendations from the Water Cycle Study are used to direct growth within the districts. At this stage it should not be taken as a given that those WRCs will be able to accommodate all the growth until full capacity and impact assessments results are available and funding secured.
These points reaffirm exactly why a separate foul infrastructure policy needs to be included in the local plan.
It would be useful to include a requirement: to demonstrate that there is, or will be, sufficient wastewater infrastructure capacity to accommodate each individual development. This would likely take the form of a Pre-Development Enquiry response from Anglian Water submitted in support of each new planning application.