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

Current data shows limited capacity at Barford Water Recycling Centre (WRC). While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Barford WRC.
We therefore recommend including within policies VC BAR1 and VC BAR2 the requirement for developers of the site to enter into early engagement with Anglian Water in order to demonstrate there is sufficient capacity in the network and receiving WRC to accommodate foul flows from the development.

Current data shows limited capacity at Barford Water Recycling Centre (WRC). While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Barford WRC.
We therefore recommend including within policies VC BAR1 and VC BAR2 the requirement for developers of the site to enter into early engagement with Anglian Water in order to demonstrate there is sufficient capacity in the network and receiving WRC to accommodate foul flows from the development.

Paragraph 2.10 highlights the fact that site allocation VC BAW1REV is located within the catchment of Whitlingham WRC and suggests that “the in-combination effects with development identified in the GNLP may require phasing of this site beyond the early years of the Plan… early engagement between Anglian Water and the developer is also advised.”
We support this suggestion and therefore question the proposed removal of the following text from the policy wording of VC BAW1REV: “Early engagement with Anglian Water regarding the need to phase development within the catchment of Whitlingham Water Recycling Centre.” Given the potential capacity issues around Whitlingham WRC, we request that this developer requirement is retained in the policy text.

As mentioned in our response to the VCHAP Alternative Sites & Focused Changes Regulation 18 Consultation, there are currently capacity issues at Ditchingham WRC. We are pleased to see the potential need for phasing to allow for upgrades to Ditchingham WRC due to the cumulative impact of recent and planned growth referred to in paragraph 3.18, although reference to potential phasing has been removed from the policy wording for VC DIT1REV. This now simply requires developers to ensure early engagement with Anglian Water to identify “connection to the local water recycling network”.
Policy VC BRM1, which is also served by Ditchingham WRC, requires the developer of the site to ensure “Early engagement with Anglian Water (AW) to ensure that there is adequate capacity, or capacity can be made available, in the wastewater network”. This wording seems stronger and more appropriate than the proposed wording for VC DIT1REV, which is for a significantly larger allocation. For consistency and clarity, we therefore recommend the wording of VC DIT1REV is changed to reflect the wording for VC BRM1.

Current data shows limited capacity at Earsham WRC. While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Earsham WRC.
We therefore recommend including within policies VC EAR1 and VC EAR2 the requirement for developers of the site to enter into early engagement with Anglian Water in order to demonstrate there is sufficient capacity in the network and receiving WRC to accommodate foul flows from the development.

We are pleased to see the inclusion in paragraph 5.14 of the current capacity issues at the Beccles-Marsh Lane WRC, and the recommendation that developers enter in early engagement with Anglian Water in order to demonstrate there is sufficient capacity in the network and receiving WRC to accommodate foul flows from the development.
However, it is not clear why this is not set out as a requirement for the developer in the policy wording of VC GIL1REV. We recommend this section is amended to include this requirement, as it is in other site specific policies within this document. This will ensure consistency in the way this issue is addressed in the Addendum at all affected sites, as well as providing clarity.

Current data shows limited capacity at Ellingham WRC. While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Ellingham WRC.
We therefore recommend including within policy VC GEL1 the requirement for developers of the site to enter into early engagement with Anglian Water in order to demonstrate there is sufficient capacity in the network and receiving WRC to accommodate foul flows from the development.

Paragraph 7.18 highlights the fact that site allocation VC ROC1 is located within the catchment of Whitlingham WRC and suggests that “the in-combination effects with development identified in the GNLP may require phasing of this site beyond the early years of the Plam. Early engagement between Anglian Water and the developer is also advised.”
We support this suggestion and therefore question the proposed removal of the following text from the policy wording of VC ROC1: “Early engagement with Anglian Water regarding the need to phase development within the catchment of Whitlingham Water Recycling Centre.” Given the potential capacity issues around Whitlingham WRC, we request that this developer requirement is retained in the policy text.

We are pleased to see the constraints surrounding Spooner Row WRC mentioned in paragraph 8.10. This WRC was originally sized for a small number of local authority properties in the area and is therefore not currently suitable to accommodate the additional growth proposed by allocation VC SPO1REV.
We agree that early engagement with Anglian Water is therefore required and that developers may need to consider alternative on-site treatment, subject to the necessary permits. We would advise developers to seek early engagement with the Environment Agency to discuss permitting for any foul drainage arrangements other than connection to the mains sewer network. We also suggest connection to a different WRC should be considered.
We are satisfied to see “Early engagement with Anglian Water (AW) regarding connecting to the local water recycling network” listed as a developer requirement in the policy text for VC SPO1REV and VC SPO2.

Current data shows limited capacity at Forncett End WRC. It is not clear why reference to this has been removed from paragraph 9.12. Nevertheless, we are satisfied that policies VC TAC1REV and VC TAC2 both include the requirement for “early engagement with Anglian Water (AW) to ensure that there is adequate capacity, or capacity can be made available, in the local Water Recycling Centre (WRC).”