Regulation 18 draft Local Plan

Support

Representation ID: 7746

Received: 08/01/2024

Respondent: Anglian Water

We agree (Policy E10) that Oakham and Rutland Water support each other’s functions as a town centre for retail and service provision and a destination and visitor hub, respectively.

Support noted.

Support

Representation ID: 7747

Received: 08/01/2024

Respondent: Anglian Water

We support the policies in the sustainable communities’ chapter and specifically SC4 – Pollution control. With reference to our comments above on P-TAL we are working with the Environment Agency to identify solutions which support growth in these four locations over the Plan period. The policy also underpins the wider steps – such as WINEP - and specifically planning applications for works on water and wastewater treatment facilities and networks required to continue to improve their environmental performance.

Support noted

Support

Representation ID: 7748

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water welcomes Policy EN2 on Local Nature Recovery Strategies and is supporting our responsible bodies across the region to produce baseline mapping, identify priorities and so deliver landscape scale connectivity along linear features such as river catchments as well projects like natural flood management which can deliver multiple benefits for nature and nearby communities

Support noted.

Object

Representation ID: 7749

Received: 08/01/2024

Respondent: Anglian Water

On EN4 and replacement trees (3 for 1), whilst we support the aim, on an operational site this may not be possible due to the site constraints, buried assets and operational processes.

Policies EN4 and EN5 (and EN7) recognises the link between fluvial and terrestrial habitats and the role for example of tree cover in also reducing flood risks.

Comments noted. Text to be amended.

Object

Representation ID: 7750

Received: 08/01/2024

Respondent: Anglian Water

On Policy EN6 – protecting agricultural land and where impact is unavoidable, we would observe that the operational necessity and existing locations of assets means that impacts on farmland are unavoidable. For example, relocating works to less valued land may entail significant carbon costs in extending networks from existing assets. It would not represent sustainable development not to mention to the costs to our customers of increased project requirements in the cost-of-living crisis. Anglian Water is not allowed by Ofwat to build things we do not have to support growth or to improve environmental performance. We purchase land by negotiation and have to work with the landowners in terms of locations within existing fields to minimise our impacts. We recognise a balance needs to be struck between water, food, and wastewater pressures all of which are vital to basic human health needs.

Comments noted. Operational and locational necessity would be taken into account in determining applications by Water Companies which affect BMV agricultural land.

Support

Representation ID: 7751

Received: 08/01/2024

Respondent: Anglian Water

We welcome policy EN7’s identification of reservoirs and other blue infrastructure as providing multi-faceted benefits including public access to nature. Wirth reference to Policy EN9 we note that Rutland in our Thriving East report is assessed as having relatively poor public access overall to nature.

Support noted.

Object

Representation ID: 7752

Received: 08/01/2024

Respondent: Anglian Water

On Policy EN10 - Rutland Water Area – we cannot support the limitation to ‘small scale’ criteria the Policy seems to be applying. For operational infrastructure, development is necessarily required by regulators to meet environmental objectives and in the NPPF is classified as ‘essential infrastructure’ precisely because without in the event of a storm or flood event taking out its function there could be significant public health risks. The requirement for HRA provides the necessary protection without the policy unnecessarily limiting or preventing essential works Necessarily the scale and importance of Rutland Water to regional water supplies means that works and new assets may themselves need to be large in scale.

Paragraph 3 of Policy EN10 does not limit Anglian Water's operational requirements to being 'small scale'.

Object

Representation ID: 7753

Received: 08/01/2024

Respondent: Anglian Water

We welcome Policy EN10’s support for recreation, sport and tourist uses and development at and near Rutland Water in principle.
The Policy though is slightly confusing and as worded an appears contradictory.
With regard to our last comment above we do not agree that the whole of Rutland Water should be a valued landscape in policy terms. It will make consenting far more challenging including for our solar and renewable energy ambitions which as we point out is an Achilles heel for the county.
Anglian Water would welcome the opportunity to work with the Council on a sound approach to developing Policy EN10 including alternatives as the consultation document acknowledges that no alternatives to this policy have been considered. We understand that alternatives to this policy will be considered in the context of an up-to-date evidence base.
We recognise that the policy seeks to provide control over development at Rutland Water. However, this policy in isolation does not explicitly recognise the importance of the tourism function of Rutland Water. The policy could be read to be overly restrictive in the context of tourism development. previous comments made on policy E6 of the previous plan are attached for reference

Paragraph 3 of Policy EN10 does not limit Anglian Water's operational requirements to being 'small scale'.

Renewable Energy proposals are subject to Planning Applications, in which Policy EN10 will be a consideration alongside Landscape Policies.

The Rutland Water Area (RWA) designation provides special protection for the reservoir and its surroundings that have been identified within supporting evidence as a valued landscape, in accordance with the requirements of NPPF. Policy EN10 contributes to the protection and enhancement of the natural and local environment of the RWA whilst accommodating appropriate recreation and tourism, and Anglian Water’s operational requirements.

The policy provides criteria for the control of development both within the five defined Recreation Areas (RA) and outside the RAs within the designated RWA.

The RWA boundary follows woodland edges, field boundaries and the A6003 to the east of Oakham. Although the Oakham WRC lies within the Rutland Water Area, Policy EN10 allows for Anglian Water’s appropriate operational requirements to continue within the RWA.

Object

Representation ID: 7754

Received: 08/01/2024

Respondent: Anglian Water

On the Policies map we would welcome confirmation that the Plan is not seeking to expand the Rutland Water Area to include Oakham WRC? With reference to the P-TAL issue explained above and work to support growth in the Oakham catchment further investment will be required in AMP8 (in addition to works being undertaken this AMP – 2020-2025). This is likely to entail a need to further expand the WRC. It would be a significant concern if the Rutland Water Area policy washed over the WRC area and then presented a policy bar on expansion to support growth and improved environmental performance.

Comments noted. Oakham WRC is within the Rutland Water Area, however the wording of Policy EN10 would still permit new development that relates to Anglian Water’s operational requirements.

Object

Representation ID: 7755

Received: 08/01/2024

Respondent: Anglian Water

At page 258, reference is made to wastewater. However there does not appear to be a policy or consideration of wastewater recycling at WRCs, for example. We would recommend that wastewater development is included with waste policy and map on page 244 as well in the waste needs assessment. Alternatively, it could be specifically excluded in waste policy and then covered in more general policy or more probably addressed in Chapter 11 – Infrastructure. We would comment that our development is different from other waste development and as indicated above further investment will be required at Oakham WRC from 2025 onwards in part to address P-TAL. We would comment that the function and operation of WRCs means that works cannot always avoid flood zones given their requirements.

Agreed in-part. Update the Waste Needs Assessment and Local Plan to include consideration of agricultural wastes and waste water. It is not necessary to add waste water development to the Spatial Strategy map.