Regulation 18 draft Local Plan

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Object

Regulation 18 draft Local Plan

Chapter 2 – Spatial Portrait

Representation ID: 7001

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

With reference to the Waste Management text (page 11) we note that wastewater/ water recycling is not referenced. Rutland is served by twenty water recycling centres (WRC) within the county. Eleven of the WRC have permits with dry weather flows that equate to the number of people served by the WRC and so are at capacity. Applying flows from 2022 indicates that ten WRC could accommodate growth within their catchments. Some 7,800 new homes could be served using existing permitted flow capacity at the ten WRC. The biosolids from the WRC are managed outside of the county with all Oakham’s sludge being transported and treated at the Flag Fen (Peterborough) Sludge Treatment Centre, for example.

Support

Regulation 18 draft Local Plan

Vision

Representation ID: 7724

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water support the 2041 Vision and specifically the local delivery of carbon net zero through the Local Plan. With regard to the list of infrastructure (bullet 7) we note that water and water recycling are not referenced. Given the importance of Rutland Water and the potential for WRCs to support a spatial distribution of growth that complies with the sustainability hierarchy, Anglian Water would welcome the inclusion of water supply and water recycling plus flood prevention in the Vision text.

Support

Regulation 18 draft Local Plan

Chapter 3 – Vision and Objectives

Representation ID: 7725

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water broadly support the Strategic Objectives.
On objective 2 we would welcome the inclusion of water efficiency as a bullet point for high standards of design. Anglian Water welcomes the identification of the multifunctional role of green and blue infrastructure in objective 8.
We support the inclusion of water resources, water quality and flood management in Objective 9 (natural resources) and water supply and wastewater management in Objective 10 (essential infrastructure). Given climate change and the opportunity for natural flood management to be promoted through Local Nature Recovery Strategies we suggest flood prevention and adaptation could be added to blue and green infrastructure.

Support

Regulation 18 draft Local Plan

Chapter 4 - Climate Change

Representation ID: 7726

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Our Thriving East report indicates that Rutland ranks well on rainfall, temperature, and flood risk in the region. However, GHG emissions are high per resident and renewable energy capacity is also low.
Looking at other assessments of Rutland’s position on climate change, the Climate Scorecard assesses the Council at being at 14% versus the average for single tier councils of 36%. The Planning and Land Use score of 6% against an average of 35%. The absence of an up-to-date Plan means that the Council has not, for example, a net zero strategic objective or which requires whole life carbon assessment of new development.

Support

Regulation 18 draft Local Plan

Policy CC1 - Supporting a Circular Economy

Representation ID: 7727

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

We support policies on the circular economy including CC1 and Anglian Water continues to seek to maximise the resource value in operations including the generation of energy from biowastes. The waste hierarchy supports our aim to assist Councils in utilising existing infrastructure capacity rather than build new capacity which generates waste in construction.

Support

Regulation 18 draft Local Plan

Policy CC2 - Design Principles for Energy Efficient Buildings

Representation ID: 7728

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water supports policies CC2, CC3 and CC4 including the cost benefits and carbon efficiencies from designing and building energy (water?) efficient buildings as opposed to retrofitting. Given the construction of new homes and building stock is approximately 1% per year and we have just over 25 years until net zero being legally required in 2050, the benefits of making a step change in construction and building performance is clear. Our sector leading approach on climate change means that we are able to provide information to show how we comply with these policies in our developments.
On CC2 d) we support the potential for heat recovery from wastewater.
We would comment that utilities infrastructure is not standard development therefore the policy and associated validation requirements which will be needed should be applied proportionally. All waste development is deemed to be major development and so we would ask that small kiosks, for example are excluded from the CC2 f)

Support

Regulation 18 draft Local Plan

Policy CC4 - Net zero carbon (operational)

Representation ID: 7730

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

We would comment that utilities infrastructure is not standard development therefore the policy and associated validation requirements which will be needed should be applied proportionally. All waste development is deemed to be major development and so we would ask that small kiosks, for example are excluded from CC4 requirement on renewable energy generation and instead that we submit a summary of the renewable energy projects delivered across the Anglian Water estate in Rutland and the wider Anglian Water estate.

Support

Regulation 18 draft Local Plan

Policy CC5 - Embodied Carbon

Representation ID: 7731

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water welcomes the policy CC5 on Embodied Carbon. We suggest that the first part of the policy should be in utilising embodied (capital) carbon in existing infrastructure to select the most sustainable locations for and quantum of growth. This may be best placed in the Spatial Strategy policies and should be referenced in the supporting text for CC5. As operational carbon is reduced through decarbonisation of the grid and transport electrification the embodied carbon in new construction and that saved by using existing infrastructure will be increasingly important on the path to net zero. Anglian Water is able to provide tCO2e figures for each of the spatial options which the Council wants to consider.

Object

Regulation 18 draft Local Plan

Policy CC6 - Water Efficiency and Sustainable Water Management

Representation ID: 7732

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

20 Anglian Water with the Environment Agency, Natural England and Cambridge Water are now moving from 110 litres to 100 litres as the water efficiency standard for new homes. We therefore ask that policy CC6 is updated to reflect this and the government position in the 2023 Environmental Improvement Plan. Anglian Water supports the Water Management bullet points in CC6. One question is whether the carbon, water and climate benefits of green roofs is always positive. Work with other Councils suggests that the engineering and design of roof structures means that some buildings and especially those with small roofs provide minimal benefits which could be more sustainably provided through ground level solutions including BNG. Anglian Water would want to work with the Council to support the Evidence Base which shows the thresholds when green roofs do and do not deliver the most environmental gains and so avoid costs in our and others capital schemes which could have been utilised to deliver more effective carbon outcomes and biodiversity gains.

Object

Regulation 18 draft Local Plan

Policy CC8 - Renewable Energy

Representation ID: 7733

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

On policy CC8 Renewable Energy infrastructure we note that the majority of our operational sites are not included on the policy map for ground based solar or wind turbine locations. Anglian Water would welcome the inclusion of all our operational sites and land parcels in close proximity on the map to ensure we can deliver our net zero ambitions either involving the installation of our own arrays or where we are working with a third party and will seek a private wire connection such as at the proposed solar farm near Wing Water Treatment Works. This can also provide resilience to water and wastewater network ensuring that with more extreme weather events being more prevalent they continue to function providing essential services. If the map is not amended or policy support for renewables at vital infrastructure sites included in the new plan, then this will limit where Anglian Water can realistically look to invest and locate new arrays and turbines. We would suggest that to be an effective policy it needs to set out the actual targets for renewables to deliver the Councils overall climate targets and incentivise investment in Rutland’s green energy transition.

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