As the Plan intends to bring forward relatively small sites across rural communities in South Norfolk, we do not perceive a policy requirement for phasing delivery or headroom/capacity at our WRCs to be necessary. However, we actively endorse early engagement with us so we can assess the connection requirements of each development and its impact and implement any mitigation necessary.

See attached document.

Thank you for the opportunity to comment on the Regulation 19 VCHAP. We have engaged with the Planning Policy Team at the Council due to difficulties in managing this consultation and conducting a full review. We are therefore making representation, at a high level which gives an indication for possible comments which we would wish to engage on in more detail and see clarified or addressed ahead of the Council's submission for Examination.

In order to capture these comments given the circumstances and that we have been unable to review the Plan along with its evidence base and supporting documents in detail at this stage, we consider that we are able to recommend that the VCHAP can be considered Sound. We are making this representation, with our position stated, along with the caveat that we may need to amend our comments and provide further comment in more detail at a further date. We would also note that these comments are unlikely to be a complete version of our comments and we may need to pick up on additional sections, particularly with reference to the Evidence Base WCS, during further engagement. We have engaged with the Council's Planning Policy Team, and an initial acknowledgment that a future Statement of Common Ground may be sought between parties to address additional comments was noted and agreed as a sensible way forward.

Evidence base guidance for Local Planning Authorities

Water Cycle Studies – This 2021 guidance is for local planning authorities (and their consultants) and developers who are preparing water cycle studies. It sets out what the Environment Agency expects to see in a water cycle study - Water cycle studies - GOV.UK (www.gov.uk)

Integrated Water Management Strategies – CIRIA hosts the 2019 publication ‘Delivering better water management through the planning system’ (C787F). This sets out the benefits of integrated water management for town planning with case studies and examples of good policy. This is available at https://www.ciria.org/ItemDetail?iProductCode=C787F&Category=FREEPUBS with an account on CIRIA website.

Policy Recommendations – New Residential Developments

We strongly recommend that South Norfolk Council require new residential developments are constructed to meet the optional higher water efficiency standard of 110 litres/person/day, as per Requirement G2 in Part G of the Building Regulations 2010. We would suggest developers submit a water efficiency calculator (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/504207/BR_PDF_AD_G_2015_with_2016_amendments.pdf) report, or equivalent information, at the planning stage to demonstrate compliance with such a policy.

Achieving 110 litres/person/day can be done with existing technology by installing efficient showerheads, spray taps and low flush toilets. Complex greywater recycling and rainwater harvesting schemes are not typically required to adhere to this water efficiency standard.