Regulation 19 Rutland Local Plan
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Regulation 19 Rutland Local Plan
Policy CC8 - Renewable Energy
Representation ID: 8609
Received: 02/12/2024
Respondent: Anglian Water
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The majority of Anglian Water Services operational sites are not included on the policy map for ground based solar or wind turbine locations.
AWS would welcome confirmation that as our sites are set out in statutory plans for water and water recycling, they are included as operational sites for the purposes of bullet 4 relating to solar energy proposals?
Subject to clarification on bullet 4 and AWS’s statutory Plan, AWS may consider seeking Modifications to the Policies Map and CC8 to ensure that there is positive policy support for renewables at and adjacent to vital infrastructure sites. Please regard this a holding objection to the Plan on the grounds that the policy constrains renewable energy opportunities too tightly.
Support
Regulation 19 Rutland Local Plan
Policy CC9 - Protecting Renewable Energy Infrastructure
Representation ID: 8610
Received: 02/12/2024
Respondent: Anglian Water
Support Policy CC9 and the need to protect renewable energy infrastructure and specifically the opportunity to generate and optimise renewable energy production at AWS sites and consequently the need to prevent other development reducing or removing that generation
opportunity.
Support
Regulation 19 Rutland Local Plan
Policy CC10 - Wider Energy Infrastructure
Representation ID: 8611
Received: 02/12/2024
Respondent: Anglian Water
We welcome policy CC10 as this supports AWS’s wider energy infrastructure needs, our net zero ambitions and resilience in the face of climate change.
Support
Regulation 19 Rutland Local Plan
Policy CC11 - Carbon Sinks
Representation ID: 8612
Received: 02/12/2024
Respondent: Anglian Water
AWS supports policies CC11 Carbon Sinks including no dig construction methods,
Support
Regulation 19 Rutland Local Plan
Policy CC12 - Carbon Sequestration
Representation ID: 8613
Received: 02/12/2024
Respondent: Anglian Water
Support this policy including nature-based solutions for water quality,
Support
Regulation 19 Rutland Local Plan
Policy CC13 - Provision for Electric Vehicle charging and Electric Bike parking
Representation ID: 8614
Received: 02/12/2024
Respondent: Anglian Water
CC13 Sustainable Travel given AWSs transition to an EV
and non- fossil fuel-based fleet.
Object
Regulation 19 Rutland Local Plan
Policy CC14 - Flood Risk
Representation ID: 8615
Received: 02/12/2024
Respondent: Anglian Water
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
On part (f) of CC14, it is not clear whether parts f.ii. to vi. are setting out the surface water hierarchy?
AWS continues to advise that the current WCS and SFRA (published in October 2023) should be updated to be a full Integrated Water Management Study. AWS considers that the SFRA should include the methodology and inputs from the soon to be updated national EA flood modelling, for example on including surface water flows and new climate change allowances.
Support
Regulation 19 Rutland Local Plan
Chapter 5 – Spatial Strategy
Representation ID: 8616
Received: 02/12/2024
Respondent: Anglian Water
Agrees that a hierarchy of settlements Policy (SS1) enables the Plan to focus development on the more sustainable locations.
AWS considers that quantum of growth (at least
123 dwellings per annum) in Policy SS1 is deliverable provided that growth is located in settlements whose catchments have headroom capacity or where investment is planned by AWS to 2030.
AWS supports the allocation of employment land, although until those sites come forward for planning and their water demands and wastewater volumes are known it is not
possible to assess the deliverability of employment allocations.
Object
Regulation 19 Rutland Local Plan
Policy SS1 - Spatial strategy for new development
Representation ID: 8617
Received: 02/12/2024
Respondent: Anglian Water
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
AWS advises that the potential in Small Villages for even ‘small scale infill or redevelopment’ (supporting text for Policy SS1) is severely limited by the descriptive permits for 11 WRC serving some of the Small Villages and smaller unnamed settlements.
We note that RCC has not sought to update its 2023 WCS as recommended in AWS’s Regulation 18 submissions. This would have enabled the reapportionment of some of the Small Villages numerical residual allocation of 37
homes to the Small Villages such as Egleton, Bisbrooke and Stretton within numerical permit WRC catchments which have capacity or to the seven Larger Villages which have WRC capacity or to developments at Stamford North or Oakham or Uppingham. On the basis of the reasoning for Policy SS1 in the Background Paper reapportionment to Stamford North, Oakham, Uppingham or the Larger Villages with capacity would have been a produced a more sustainable spatial distribution.
A paper setting out the AWS approach to WRC capacity and caveats for the RAG table above is attached to this response.
Object
Regulation 19 Rutland Local Plan
Policy SS2 – Development within Planned Limits of Development
Representation ID: 8618
Received: 02/12/2024
Respondent: Anglian Water
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
No longer based on sound evidence as development proposals at Braunston (Larger Village) would, for example, now be highly likely to be objected to by AWS given its recent history of dry weather flows and
consequent risk of pollution if addition homes were connected to the sewerage network.
Similarly, applications for new homes at settlements such as Ridlington (Smaller Village) would result in an objection by AWS as these are served by WRC with descriptive permits which AWS will not be investing in in the next five years and where such investment would not be efficient
or deliver carbon economies of scale.
A positively prepared plan should instead direct growth to
locations with known infrastructure capacity and/ or settlements where planned investment will look to remove constraints.