Regulation 18 draft Local Plan

Object

Representation ID: 7001

Received: 08/01/2024

Respondent: Anglian Water

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.

Agree the sentence regarding Stamford being tightly constrained is ambiguous. Comments regarding waste water recycling noted. The section on Waste Management relates only to the solid waste that the council is responsible for as the Waste Planning Authority and ties to the policies on waste set out in Chapter 10. A detailed Infrastructure Delivery Plan will be published alongside the Regulation 19 consultation plan which will set out the detailed infrastructure needed to support development.

Support

Representation ID: 7724

Received: 08/01/2024

Respondent: Anglian Water

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 noted. Agree to add in ‘water supply and flood prevention’ to last bullet point after community facilities’.

Support

Representation ID: 7725

Received: 08/01/2024

Respondent: Anglian Water

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 noted, regarding Objective 2, this is not considered necessary particularly as policy CC6 covers this matter in detail

Support

Representation ID: 7726

Received: 08/01/2024

Respondent: Anglian Water

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.

Comments noted. Strategic Objective 1: Climate Change states that the council will take positive action to achieve net-zero through (in part) reducing a development’s embodied carbon as set out in Policy CC5.

Support

Representation ID: 7727

Received: 08/01/2024

Respondent: Anglian Water

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 from Anglian Water and their approach to minimizing waste generation welcomed.

Support

Representation ID: 7728

Received: 08/01/2024

Respondent: Anglian Water

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 for CC2 welcomed. Comment regarding part f) noted. The policy is worded (‘should demonstrate’) flexibly so would take into account the scale and function of such small developments when the policy is applied.

Support

Representation ID: 7730

Received: 08/01/2024

Respondent: Anglian Water

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.

Comment noted. The policy is worded (‘should provide for’) flexibly so would take into account the scale and function of such small developments when the policy is applied.

Support

Representation ID: 7731

Received: 08/01/2024

Respondent: Anglian Water

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.

Support noted. Agree inherent in contributing towards reducing a development’s embodied carbon is its location in terms of utilising existing infrastructure and thereby the delivery of sustainable development, one of the key Strategic Objectives in the Local Plan. The Spatial Strategy policies in the Local Plan seek to meet this Strategic Objective.

Object

Representation ID: 7732

Received: 08/01/2024

Respondent: Anglian Water

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.

Comments noted. The request to move from 110 litres per day to 100 litres is noted. The Optional Technical Standard for housing allows councils to set a more stringent standard of 110 litres per day, as compared to the Building Regulations requirement of 125 litres per day, where there is a clear local need (as is the case in Rutland which is classified as being in a serious water stressed area). The 110 litres per day set out in CC6 is considered justified on this basis, recommended in the Rutland Water Cycle Study (2023) (part of the evidence base for the Local Plan). The policy also seeks to go further in terms of water usage by supporting ambitious proposals for down to 85 litres per day.
Comments regarding the efficiency of green roofs is noted. It is acknowledged that green roofs and/or walls are often not feasible in developments and this is reflected in the wording of the policy. Further evidence work on the carbon and biodiversity benefits of such structures, and viability testing may be appropriate in the future to inform the next stages of the Local Plan.

Object

Representation ID: 7733

Received: 08/01/2024

Respondent: Anglian Water

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.

Comments noted. Unclear whether such operational sites have been excluded from the solar panel/wind turbine opportunity areas as part of the initial high-level assessment. Such sites could form part of the next stage of the assessment (a review of the Renewable Energy Study) to be used to inform the next stage of the local plan. The wording of CC8 would not preclude support for ground mounted solar projects that lie outside the opportunity area designation on the Proposals Map as would small to medium turbines not be precluded outside the areas potentially suitable for wind turbines.