Regulation 18 draft Local Plan

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Support

Regulation 18 draft Local Plan

Policy CC10 - Wider Energy Infrastructure

Representation ID: 7734

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

We welcome policy CC10 as this supports Anglian Water’s wider energy infrastructure needs, our net zero ambitions and resilience in the face of climate change.


Our response:

Support noted.

Support

Regulation 18 draft Local Plan

Policy CC11 - Carbon Sinks

Representation ID: 7735

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water supports policies CC11 Carbon Sinks including no dig construction methods, CC12 Carbon Sequestration including nature-based solutions for water quality.


Our response:

Support noted.

Support

Regulation 18 draft Local Plan

Policy CC13 - Sustainable Travel

Representation ID: 7736

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Support CC13 Sustainable Travel given Anglian Waters transition to an EV and non- fossil fuel-based fleet.


Our response:

Support noted.

Support

Regulation 18 draft Local Plan

Policy CC14 - Flood Risk

Representation ID: 7737

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water supports the intention of Policy CC14 – Flood Risk. One addition should recognise the increased risk of flooding for existing communities due to Climate Change and the cumulative risks that land use change in an area can have on that risk in light of more extreme weather events including drought and storms. The policy should require developers to consider betterment to address the wider flood risks that the proposed development may affect. Text from another Councils emerging plan, perhaps anticipating changes in EA flood risk models in 2024 and NPPF policy, says, ‘Providing betterment over the existing situation in areas at risk of flooding and seeking to achieve integrated water management’. We recommend the current WCS and SFRA are updated in 2024/ 25 to be an Integrated Water Management Study including updated EA flood modelling including surface water flows and new climate change allowances.


Our response:

Support noted. Agree to include reference to increased risk of flooding from climate change: Add in extra sentence at end of first para: ‘One of the most notable indications of climate change has been the increase in the frequency and severity of flooding. This policy is part of an integrated water management approach to water management in Rutland.'
Add in extra sentence to end of criteria e) ‘The design of the SuDS/Integrated Water Management should demonstrate how the effects of climate change has been considered.’

Support

Regulation 18 draft Local Plan

Policy SS1 - Spatial strategy for new development

Representation ID: 7738

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water agrees that a hierarchy of settlements Policy (SS1) enables the Plan to focus development on the more sustainable locations. Increasingly development will towards the end of the Plan period need to deliver net zero (embodied and operational) carbon from day 1 to build in net carbon negative solutions from 2050 onwards. Looking at wastewater recycling centre (WRC) permitted dry weather flow (DWF) capacity Anglian Water suggests the most locations and quantum of development could be deliverable based on WRC permitted dry weather flow alone. (table provided).
Anglian Water suggest that in the second stage Water Cycle Study, the Council’s consultants consider the option of reprioritising the timing and/ or quantum of growth within the four WRC catchments where P-TAL may constrain growth. The revised option could include additional growth at north Stamford as the Stamford WRC is in Peterborough and serves Stamford in South Kesteven as well as small areas in Peterborough and Rutland. Stamford’s WRC is not a TAL site, and its dry weather flow indicates it could serve circa 9,200 additional homes.

Anglian Water’s Pre-Development team advise that growth at Stamford presents network capacity issues, in part due to the location of the WRC and pumping station. A technical solution though is feasible to address the water recycling network issues.
A further option would be additional growth in the Empingham WRC catchment including Edith Weston which has circa 1,550 homes capacity.


Our response:

We will continue to work with Anglian Water through the IDP and future development of the evidence base to ensure development can be supported by infrastructure.

Support

Regulation 18 draft Local Plan

Policy H1 – Sites proposed for residential development

Representation ID: 7741

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water notes (Table 4, page 84) an additional 2,056 dwellings are identified over and above the 650 Rutland Local Plan allocation for Stamford North. In addition, if P-TAL proved to a bar on growth in the catchments affected then circa 2,830 new homes could be served by catchments and WRC which are not so constrained. With reference to page 83 and ‘infrastructure needs’ Anglian Water recognises that in assessing the climate change and carbon implications for growth that water supply and water recycling is approximately two (2) percent of capital and operational UK emissions. Anglian Water proposes to support the Council in quantitatively assessing the whole life GHG emissions for the preferred spatial distribution and quantum of growth during the next stage of the plan’s progression.


Our response:

Support noted.

Object

Regulation 18 draft Local Plan

Policy CC6 - Water Efficiency and Sustainable Water Management

Representation ID: 7742

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

With reference to water use standards, as the Local Plan will inform future development to 2041, we would support a more ambitious approach similar to that proposed by the emerging Greater Cambridge Local Plan which has proposed 80 l/p/d in recognition of future water supply issues as a result of abstraction reductions to protect the environment. The policy tests would need to be robust to require monitoring of the proposed efficiency standard and remediation where the level of usage is exceeded. Policies should also require integrated water management solutions including rainwater/storm water harvesting and greywater recycling for non-potable uses – such schemes should be mandatory in larger developments that can provide economies of scale to achieve robust water efficiency standards. Anglian Water is working to prepare a Joint Protocol and supporting evidence with Natural England and the Environment Agency to underpin more ambitious water efficiency standards. See attachment


Our response:

Comments noted.
There is not sufficient evidence to support this approach at this time, although it is recognised that AWS and NE are preparing evidence and a protocol at the moment.
Higher standards will impinge on viability and deliverability of the plans policies and proposals.

Object

Regulation 18 draft Local Plan

Chapter 7 - Economy

Representation ID: 7743

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

32 In June 2023 we advised Council’s in the Anglian Water region on the introduction of restrictions to non- domestic water supply which may limit employment development. That position statement is also attached to this response. Noting that the majority of Rutland is outside of our service area, we recognise that new or expanding business on the east of the county and in around Stamford may generate new demands for water. When this demand is over 0.15MLD then that request for a new demand may be declined. Where allocations in Policy E1 are for office, warehousing, and logistics these would be unlikely to require that quantum of water. Light industrial uses and in particular food and drink manufacture may generate such demands.
We recommend that Policy E1, E2 and E4 have an informative advising that applicants should contact Anglian Water at an early stage in site selection to consider water demands and process efficiencies.


Our response:

It is recognised that new employment development is likely to generate an increased demand for water, particularly those for food and drink manufacture. Where these relate to site allocations, development principles for these sites can include specific requirements which relate to the requirements of planning applications which will come forward on the allocated sites.

Support

Regulation 18 draft Local Plan

Policy E8 - Local Visitor Economy

Representation ID: 7744

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water supports Policy E8- Local Visitor Economy. The supporting text recognises the role that Rutland Water plays as an attraction and centre for visitors as well as being a leisure hub for both visitors and local residents. The over 66% support for new tourist attractions indicates a broad level of support for further development.


Our response:

Support noted.

Support

Regulation 18 draft Local Plan

Policy E9 – Caravans, camping, lodges, log cabins, chalets and similar forms of self-serviced holiday accommodation

Representation ID: 7745

Received: 08/01/2024

Respondent: Anglian Water

Representation Summary:

Anglian Water supports Policy E9 on holiday accommodation and its provision in proximity to Rutland Water. We welcome the positive clarity that the identification of three areas in Policy EN10 provides on the preferred future location of holiday accommodation.


Our response:

Support noted.

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