Landscape Susceptibility in relation to Energy Generation, Storage and Transmission - SPD

Support

Representation ID: 4369

Received: 01/09/2025

Respondent: Anglian Water Services

4 Energy-related development scenarios
4.5.3 For Solar PV the thresholds for larger scale projects will need to be revised, or a further
reference made, to reflect the change to thresholds for nationally significant infrastructure projects
(NSIPs) - this is moving from 50MW (current capacity threshold) to a capacity threshold of 100MW
or greater from 31 December 2025. The Infrastructure Planning (Onshore Wind and Solar
Generating stations) Order 2025 is a statutory instrument which has been used to amend the NSIP
thresholds of solar projects in the Planning Act 2008. As a result, solar farms up to 99.9MW will be
determined through planning applications to local planning authorities.
Renewable energy is generated from biogas at several of our larger water recycling works, as a
product of the sludge treatment process - this is fed directly into Combined Heat and Power engines.
The heat is used in the anaerobic digestion process, and the electricity is used on site.
Anglian Water has CHP at Whitlingham WRC to treat sludge stocks. As a wastewater site, planning
applications are determined by Norfolk County Council. However, the LPA would be a consultee on
applications coming forward at the site.
This demonstrates that for Anglian Water renewable energy options to meet our net zero ambitions
are constrained by the location and operation of our existing water and water recycling sites This is
highlighted in respect of AD Plants within the NSBPZ in section 7.
Anaerobic digestion is an important component of our sludge treatment process and already exists
at our Whitlingham WRC. Any further applications to improve the functionality of our AD and CHP
processes on the site would be additions to our operational site and therefore the criteria in the SPD
should reflect whether developments that are extensions to existing infrastructure sites and support
the operation of critical infrastructure are an important consideration. Similarly, our most critical
sites are subject to the Water company security and emergency measures: ministerial direction
(2022 and amended in 2024), which means that appropriate and proportionate security measures
must be in place to respond to a civil emergency or event threatening national security.
Furthermore, if located on our operational land, solar PV arrays can be permitted development if the
specific conditions and limitations under the Town and Country Planning (General Permitted
Development) (England) Order 2015 are met.

Object

Representation ID: 4370

Received: 01/09/2025

Respondent: Anglian Water Services

Battery Energy Storage Systems:
Whilst Anglian Water's direct interest in the location of BESS is generally in respect of source
protection zones, and protecting the quality of water abstractions, and the water
supply/connections required to maintain a fire suppression system at a BESS site; it is noted that
some proposals that seek to reduce water use for fire suppression (and containment systems to
prevent potential contaminants from spent firewater entering aquifers) through alternative fire
suppression systems, and increasing the distance between the battery units. Whilst potential landtake for BESS may increase, this is positive for reducing reliance on potable water resources,
improving containment of fire risk and potential contaminants entering aquifers. The landscape
guidelines are helpful considerations when balancing other factors in the decision-making process,
such as appropriate mitigation measures to minimise risks, for the layout and siting for a BESS.

Object

Representation ID: 4371

Received: 01/09/2025

Respondent: Anglian Water Services

Underground cable routes:
The design development guidelines include 'minimising the width of the required corridor' may be
difficult to achieve in practice. From engagement with NSIP promoters we are aware that the width
of these corridors is determined by safety factors and construction methods e.g. the distance
required between the cables (dependent on voltage). In addition, the width can be influenced by the
method of trenching and the depth the cables will need to be buried. As a result of interfaces with
our underground assets (water mains and sewers) and the potential for adverse impacts inter alia
heat dispersion from high voltage cables on our assets may result in the corridors being wider unless
alternative mitigation measures can be identified.

Support

Representation ID: 4372

Received: 01/09/2025

Respondent: Anglian Water Services

7 Policy DM 4.6: Landscape Setting of Norwich
Anglian Water's Whitlingham water recycling centre and sludge treatment centre is within the
Norwich Southern Bypass Protection Zone (NSBPZ). As an existing critical infrastructure site within
the NSBPZ, there will need to be some balance between the aims of protecting the openness of the zone with our associated net zero ambitions, the continued expansion to increase capacity to accommodate wastewater and sludge treatment, and other legislative requirements that need to be met. Whitlingham WRC is also used to provide latent heat from our low carbon heat source to heat
large tomato greenhouses, demonstrating the breadth of renewable and low carbon energy sources
and opportunities that can be provided by wastewater treatment, including to support low carbon
farming. Anglian Water welcomes the reference in the SPD (para. 7.2.8) that AD plants proposed at
sewage works would be accepted as they are constrained in their locations. We agree that our water
recycling centres and sludge treatment centres are critical infrastructure sites where renewable
energy development is an essential factor of the site operation (e.g. Anaerobic digestion)