The paragraph needs to refer to water quality, environmental legislation such as water quality and revert this back to the potential impacts of developments flows directed to Water Recycling Centres. The policy should refer to the Water Cycle Study that has been submitted in support of this Local Plan.

Paragraph 257 has been added following our previous response which states “to ensure that development does not have a detrimental impact on the water environment, particularly in relation to water quality and the potential for impacts on the water-based sites protected under the Habitats Regulations Directive, major development will be dependent on the waste water infrastructure being capable of accommodating and treating the additional flows from development or being able to be made so”. We assume this is in relation to water/foul water but needs to be clearer and say that.

Whilst the addition of paragraph 257 is positive, this could still be improved by incorporating the text previously suggested as highlighted below:
“Taking account of the above evidence, the policy therefore commits the Greater Norwich authorities to ensuring 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".

There is no mention of wastewater infrastructure directly in the policy. This should be highlighted as it is the key bit of infrastructure that poses the most risk to the water environment. A sound local plan will also need to highlight the need to phase development with infrastructure upgrades, which this policy does not do.

It is important to note that the plan has not addressed water quality sufficiently anywhere. The plan has not referred to key legislation such as the Water Framework Directive (WFD). Without necessary safeguards in the Local Plan, the sewerage undertaker could be placed in a position where they will be breaching permit as they are obliged to accept flows. This could create an exceedance in environmental legislation such as the Water Framework Directive.

Please note that our response to this policy should be read in conjunction with our representation to paragraph 145. We have raised our unsound representation in this policy itself as this would be the most appropriate location for these comments to be addressed.