Draft Greater Norwich Local Plan – Part 1 The Strategy

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’

Anglian Water is generally supportive of the principle of development proposals providing biodiversity net gain. The policy as drafted says this would apply to development wherever feasible. However the Environment Bill which is currently before parliament refers to biodiversity net gain being mandatory for all development requiring planning permission.

Policy 3 should be amended for consistency with the provisions of Environment Bill.

Policy 4 – Strategic Infrastructure – supporting text

Para 222 – Reference is made to no additional spending being required for water supply infrastructure. However the WRMP includes new potable water transfers to be funded by Anglian Water through customer bills. We would also expect developers to pay appropriate charges for the required connections to the water supply network.

Both of the documents produced by Anglian Water as referenced in para 222 have been published. Anglian Water’s Water Resource Management Plan (WRMP) was approved by Defra in December 2019 and the Water Recycling Long Term Plan was published in September 2018.

We review our Water Resource Management Plan on a continuous basis and will be preparing a new plan for 2024 which will align with the regional plan being led Water Resources East.

Anglian Water is also to prepare a Drainage and Wastewater Management Plan in partnership with stakeholders including the Greater Norwich authorities, the Broads Authority and the EA. This will be used to inform our next business plan for 2024.

The text should be updated to this effect.

Para 225 – Anglian Water promotes the use of Sustainable Drainage Systems as these have benefits both in terms of surface water and sewer flooding as well as wider environmental and community benefits including water quality enhancement.

The text should be updated to this effect.

Para 226 – reference is made to improved monitoring as outlined in Anglian Water’s Water Recycling Long Term Plan. This relates to the monitoring of foul flows within the network rather than existing Water Recycling Centres as stated.

The text should be updated to this effect.

Para 227 – reference is made to standard charges for ensuring water is supplied to development sites and are drained effectively.

Anglian Water applies developer charges directly for connections to water supply network and foul sewerage networks. The charges for 2020-21 do not include standard charges which were included previously. There is also investment made by Anglian Water as part of our business planning process.

The text should be updated to this effect.

Para 228 – reference is made to the preparation of the Greater Norwich Water Cycle Study. Anglian Water has made detailed comments on the content on the draft study which is to be finalised including addressing comments made by relevant organisations.

We are supportive of a number of policy recommendations as set out in the Draft Study including applicants demonstrating that capacity both within the foul sewerage network and at the receiving Water Recycling Centre (in consultation with Anglian Water) is available to serve development proposals and separation of surface and foul flows wherever possible.

These policy recommendations have not been carried forward into the wording of Policy 2 unlike the reference to increased water efficiency in residential development. Please see suggested changes to Policy 2 of the Local Plan.

Policy 4 – Strategic Infrastructure

Policy 4 as drafted appears to refer to Greater Norwich Authorities and partners lobbying Anglian Water as an infrastructure provider for the timely delivery of improvements including wastewater network, Whtilingham Water Recycling Centre and at Yare Valley Sewer.
Water and sewerage companies including Anglian Water prepare business plans on a 5 year investment cycle. Customer charges will be set following submissions from Anglian Water about what it will cost to deliver the business plan. Anglian Water’s business plan for the next Asset Management Plan period (2020 to 2025) was submitted to our economic regulator Ofwat in 2019.
It is therefore suggested that policy 4 is amended as follows:

‘The Greater Norwich Local Authorities and partners [including utility companies will work together in relation to] [new text] [lobby for] [text to be deleted] the timely delivery of improvements to infrastructure…and to’

In addition the policy as drafted refers to Whitlingham Water Recycling Centres and Yare Valley sewer but not to water supply and sewerage network improvements more generally.

Reference is made to groundwater sources utilised for potable (clean) water to supply Anglian Water's customers.

There are a number of sources and SPZs close to proposed developments:
• Aylsham - Aylsham and Coldham Hall sources
• Cawston – Salle Bridge
• Norwich – Costessey Pits,Marlingford, Bowthorpe, Colney, Thorpe St Andrew, Trowse Newton, Caistor St Edmund, Postwick
• Wicklewood – High Oak
• Kirby Cane – Kirby Cane

However there is no policy to ensure that development proposals explicitly give full consideration to the risk of pollution to groundwater sources as set above. Including the documentation to be provided at application stage including mitigation where required.

Appendix 1 Infrastructure requirements.
Water – the text references a number of water recycling centres in the Greater Norwich Local plan area as set out in Anglian Water’s Water Recycling Long Term Plan.
However there is no reference made to there being a requirement for improvements to the water supply and/or foul sewerage networks to accommodate further development. This will include those sites which are allocated in the Local Plan sites together with any sites which come forward for development which are not currently identified.