Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC BAR2: Land at Chapel Street

Representation ID: 4171

Received: 07/10/2024

Respondent: Anglian Water Services

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed additional site for 40 dwellings is within the catchment for Barford-Chapel Street Water Recycling Centre (WRC). Based on current data, whilst there is limited headroom based on dry weather flow at the WRC for future growth, there is currently capacity for the proposed growth (VC BAR1/BAR2). To take account of cumulative growth in the catchment, including additional dwellings that might arise through windfall developments, we would welcome the supporting text to encourage the developer to undertake early pre-planning engagement with Anglian Water to discuss network connections and network/WRC capacity.

Anglian Water supports the requirement to alleviate flood risk given the site is identified at the head of a significant surface water flow path. The opportunities for providing overall betterment for the existing community should not be underestimated given the more frequent storms and intense rainfall experienced over the autumn and winter months (2023-24). Reducing surface water run-off can also help prevent ingress to our sewer networks and reduce the probability of surcharge events. Our experience over the winter of 2023-24 leading to the period between October 2022 and March 2024 was the wettest 18 months since records began - causing us to revise our expectations of the pace and scale at which climate change will impact our networks.

Change suggested by respondent:

The policy should be amended to require a flood and drainage strategy to be submitted for the site, which should be supported by a recent pre-planning engagement assessment from Anglian Water.

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Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC BAW1REV: Land east of Stocks Hill

Representation ID: 4172

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Anglian Water notes the statement regarding potential phasing of this site beyond the early years of the Plan given that it is located within the catchment of Whitlingham WRC. Anglian Water has a proposed growth scheme to increase dry weather flow capacity at Whitlingham WRC within our PR24 Business Plan for delivery in AMP8 (2025-2030). However, this is investment is subject to final determination our Business Plan by our regulator, Ofwat, which is due in December 2024.Whitlingham WRC has been identified as a nutrient significant plant and will require phosphate and nitrogen removal upgrades to technically achievable levels (TAL) by 1st April 2030. An accelerated infrastructure delivery scheme will deliver the phosphate element of the upgrade to TAL by 31st March 2027. This will reduce the amount of nutrient mitigation required for developments occupied after these dates.

It is noted that the policy requirement for early engagement with Anglian Water has been removed from the policy and is only referred to in the text. However, we support the requirement for a drainage strategy in the policy – it should be clarified that this assessment should include details of both surface water and foul drainage and with details to be agreed with Anglian Water in addition to the Lead Local Flood Authority.

There are no sewers within the proposed site allocation.

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Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC DIT1REV: Land at Thwaite's and Tunneys Lane

Representation ID: 4173

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Anglian Water supports the policy requirement for early engagement for development at this site. There is limited dry weather flow permit headroom at the WRC to accommodate future growth in the catchment. As a result, the increase in the number of dwellings on the site, together with VC BRM1 and any additional windfall development coming forward, may cumulatively result in insufficient headroom being available at the WRC. Ditchingham WRC does not have an identified growth scheme for AMP8 (2025-2030) in our PR24 Business Plan. Therefore, should a growth scheme be required it would not be delivered until beyond 2030, and development would need to be phased accordingly.

The additional area identified to increase capacity of the site, impacts on another sewer (surface water) crossing the site, in addition to the foul sewer and water main. The policy requirement is therefore essential to ensure the protection of our assets and that they are appropriately accommodated within the development layout design.

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC BRM1: Land west of Old Yarmouth Road

Representation ID: 4174

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Anglian Water supports the policy requirement for early engagement for development at this site.There is limited dry weather flow permit headroom at the WRC to accommodate future growth in the catchment. As a result, this additional site, together with VC DIT1REV and any additional windfall development coming forward, may cumulatively result in insufficient headroom being available at the WRC. Ditchingham WRC does not have an identified growth scheme for AMP8 (2025-2030) in our PR24 Business Plan. Therefore, should a growth scheme be required it would not be delivered until beyond 2030, and development would need to be phased accordingly.

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC EAR2: Land north of The Street

Representation ID: 4175

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

The site is on the edge of the Earsham-Bungay Road WRC. There is capacity for the proposed level of growth as there is sufficient dry weather flow headroom available at the WRC. The developer would need to engage with Anglian Water regarding connections for water supply and wastewater in the usual way.

We support the need for a site-specific flood risk assessment because of the identified groundwater flood risk. Groundwater flooding and elevated water table levels can inundate our underground infrastructure and result in sewer flooding and loss of service for some properties/communities in periods of prolonged/intensive rainfall. Unfortunately, there is a lack of legislation that governs this type of scenario (where high groundwater levels impact sewerage assets, but do not cause an ‘above ground’ flood), and so we have held multiple workshops and discussions with Norfolk Strategic Flood Alliance partner organisations, in particular the Environment Agency, about managing groundwater differently in the future. Ensuring that new development is resilient to all forms of flood risk is therefore critical, and flood risk is managed appropriately to minimise cumulative impacts including on our existing and new infrastructure networks.

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

5.14

Representation ID: 4176

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Anglian Water welcomes reference to the limited capacity of the Beccles-Marsh Lane WRC and the need for early engagement to determine whether there is sufficient capacity in the network and receiving WRC. Beccles-Marsh Lane WRC has been identified for investment in a growth scheme to increase dry weather flow capacity in the PR24 Business Plan for AMP8 (2025-2030). Our Business Plan is subject to final determination by our regulator, Ofwat – this is expected in December 2024.

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC SWA2REV: Land on Main Road

Representation ID: 4177

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

The site is on the edge of the Swardeston Common WRC catchment. There is capacity for the proposed level of growth as there is sufficient dry weather flow headroom available at the WRC. The developer would need to engage with Anglian Water regarding connections for water supply and wastewater in the usual way. We have no objection to the removal of the policy requirement relating to wastewater capacity due to current capacity availability.

Swardeston Common WRC has been identified as a nutrient significant plant and will require phosphate and nitrogen removal upgrades to technically achievable levels by 1st April 2030. This will reduce the amount of nutrient mitigation required for developments occupied after this date.

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Support

Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC ROC1: Land south of New Inn Hill

Representation ID: 4178

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Anglian Water notes the statement regarding potential phasing of this site beyond the early years of the Plan given that it is located within the catchment of Whitlingham WRC. Anglian Water has a proposed growth scheme to increase dry weather flow capacity at Whitlingham WRC within our PR24 Business Plan for delivery in AMP8 (2025-2030). However, this is subject to final determination our Business Plan by Ofwat, which is due in December 2024. Whitlingham WRC has been identified as a nutrient significant plant and will require phosphate and nitrogen removal upgrades to technically achievable levels (TAL) by 1st April 2030. An accelerated infrastructure delivery scheme will deliver the phosphate upgrade to TAL by 31st March 2027. This will reduce the amount of nutrient mitigation required for developments occupied after these dates.

It is noted that the policy requirement for early engagement with Anglian Water has been removed from the policy and is only referred to in the text. We have no objection to the removal of this clause.

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC SPO1REV: Land west of Bunwell Road

Representation ID: 4179

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

No comments.

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Village Clusters Housing Allocations Plan - Reg. 19 Pre-submission Addendum

Policy VC SPO2: South of Station Road

Representation ID: 4180

Received: 07/10/2024

Respondent: Anglian Water Services

Representation Summary:

Due to the very small WRC at School Lane Spooner Row that is subject to a descriptive permit, and the limited capacity of these small works to accommodate significant growth, we agree with the need for early engagement to assess the feasibility of a wastewater connection. See also our commentary on the Water Cycle Study.

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