Comment
Barkway and Nuthampstead Neighbourhood Plan 2018 - 2031
Representation ID: 10499
Received: 26/06/2024
Respondent: Anglian Water Services Ltd
Anglian Water supports neighbourhood plans and their role in delivering environmental and social prosperity in the region. Anglian Water has over 6 million customers as a water supply and water recycling provider. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline.
The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea. Additionally, parts of the area have the highest rate of housing growth in England.
Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.
Anglian Water wants to proactively engage with the neighbourhood plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. Anglian Water has produced a specific guidance note on the preparation of NPs found using this link under our Strategic Growth and Infrastructure webpage - Strategic Growth and Infrastructure (anglianwater.co.uk). The guidance also has sign posting/ links to obtaining information on relevant assets and infrastructure in map form, where relevant.
Anglian Water is the sewerage undertaken for the northern part of the neighbourhood plan area and is identified as a consultation body under the Neighbourhood Planning (General) Regulations 2012. Anglian Water covers the area in the northern part of Barkway village and includes Newsells and extending beyond to include other settlements such as Barley and Royston.
The following comments in relation to ensuring the making of the neighbourhood plan contributes to sustainable development and has regard to assets owned and managed by Anglian Water. Policy BN H5 Framework for BK3
Policy BN H3 Sustainable Construction and Policy BN H4 Design Codes
Water efficiency measures
Anglian Water is pleased to note that water efficiency is referenced within the neighbourhood plan. As a region identified as seriously water stressed, we encourage plans to include measures to improve water efficiency of new development through water efficient fixtures and fittings, including through rainwater/storm water harvesting and reuse, and greywater recycling. Whilst Anglian Water is only the statutory sewerage undertaker for the neighbourhood plan area, measures to improve water efficiency standards and include opportunities for water reuse and recycling (rainwater harvesting and greywater recycling) also reduces the volume of wastewater needed to be treated by our water recycling centres.
The Defra Integrated Plan for Water supports the need to improve water efficiency and the Government's Environment Improvement Plan sets ten actions in the Roadmap to Water Efficiency in new developments including consideration of a new standard for new homes in England of 100 litres per person per day (l/p/d) where there is a clear local need, such as in areas of serious water stress. Given the proposed national approach to water efficiency, Anglian Water encourages this approach. This will help to reduce customer bills (including for other energy bills) as well as reduce carbon emissions in the supply and recycling of water.
Flooding and Sustainable Drainage
Anglian Water is supportive of the measures to address surface water run-off, including the preference for this to be managed using Sustainable Drainage Systems (SuDS) and requiring permeable surfaces for new areas of hardstanding within developments to align with the drainage hierarchy. Such measures help to avoid surface water run-off from entering our foul drainage network, and connections to a surface water sewer should only be considered where all other options are demonstrated to be impracticable. Any requirements for a surface water connection to our surface water sewer network will require the developer to fund the cost of modelling and any upgrades required to accept the flows from the development.
Anglian Water encourages the use of nature-based solutions for SuDS wherever possible, including retrofitting SuDS to existing urban areas to enhance amenity and biodiversity within the neighbourhood plan area and contribute to green and blue infrastructure.
It is the Government's intention to implement Schedule Three of The Flood and Water Management Act 2010 to make SuDS mandatory in all new developments in England in 2024/ 2025. However, we welcome this policy to ensure SuDS measures are incorporated within new developments, until the Schedule is formally implemented and the necessary measures are in place.
Policy BN NE1 Local Green Space (LGS)
The policy designates areas LGS within the neighbourhood plan area. Anglian Water may have assets forming part of our water and water recycling network (e.g., rising mains and sewers) located near or adjacent to designated areas of local green space. It is noted that that the development is restricted to very special circumstances to be demonstrated. We consider that the policy provides scope for Anglian Water to undertake operational development to maintain and repair any underground network assets that may be within these areas, such as mains water pipes, and which would be consistent with this policy test.
Policy BN NE3 Conserve and Enhance Biodiversity
Anglian Water supports the policy objectives of prioritising the delivery of biodiversity net gains within the neighbourhood planning area to support habitat recovery and enhancements within existing areas green and blue infrastructure. Anglian Water has made a corporate commitment to deliver a biodiversity net gain of 10% against the measured losses of habitats on all AW-owned land.
As the neighbourhood plan progresses, there may also be benefit in referencing the emerging Local Nature Recovery Strategy (LNRS) by the Hertfordshire Nature Recovery Partnership, as this will identify priority actions for nature and map specific areas for improving habitats for nature recovery. Hertfordshire Nature Recovery Partnership | Hertfordshire County Council.
I have been able to get it confirmed that the assets I had previously referred to lying within the site allocation BK3 have been de-commissioned and the site is outside our statutory water boundary, so I have not needed to refer to this in my comments.
Anglian Water supports neighbourhood plans and their role in delivering environmental and social prosperity in the region. Anglian Water has over 6 million customers as a water supply and water recycling provider. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline.
The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea. Additionally, parts of the area have the highest rate of housing growth in England.
Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.
Anglian Water wants to proactively engage with the neighbourhood plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. Anglian Water has produced a specific guidance note on the preparation of NPs found using this link under our Strategic Growth and Infrastructure webpage - Strategic Growth and Infrastructure (anglianwater.co.uk). The guidance also has sign posting/ links to obtaining information on relevant assets and infrastructure in map form, where relevant.
Anglian Water is the sewerage undertaken for the northern part of the neighbourhood plan area and is identified as a consultation body under the Neighbourhood Planning (General) Regulations 2012. Anglian Water covers the area in the northern part of Barkway village and includes Newsells and extending beyond to include other settlements such as Barley and Royston.
The following comments in relation to ensuring the making of the neighbourhood plan contributes to sustainable development and has regard to assets owned and managed by Anglian Water. Policy BN H5 Framework for BK3
Policy BN H3 Sustainable Construction and Policy BN H4 Design Codes
Water efficiency measures
Anglian Water is pleased to note that water efficiency is referenced within the neighbourhood plan. As a region identified as seriously water stressed, we encourage plans to include measures to improve water efficiency of new development through water efficient fixtures and fittings, including through rainwater/storm water harvesting and reuse, and greywater recycling. Whilst Anglian Water is only the statutory sewerage undertaker for the neighbourhood plan area, measures to improve water efficiency standards and include opportunities for water reuse and recycling (rainwater harvesting and greywater recycling) also reduces the volume of wastewater needed to be treated by our water recycling centres.
The Defra Integrated Plan for Water supports the need to improve water efficiency and the Government's Environment Improvement Plan sets ten actions in the Roadmap to Water Efficiency in new developments including consideration of a new standard for new homes in England of 100 litres per person per day (l/p/d) where there is a clear local need, such as in areas of serious water stress. Given the proposed national approach to water efficiency, Anglian Water encourages this approach. This will help to reduce customer bills (including for other energy bills) as well as reduce carbon emissions in the supply and recycling of water.
Flooding and Sustainable Drainage
Anglian Water is supportive of the measures to address surface water run-off, including the preference for this to be managed using Sustainable Drainage Systems (SuDS) and requiring permeable surfaces for new areas of hardstanding within developments to align with the drainage hierarchy. Such measures help to avoid surface water run-off from entering our foul drainage network, and connections to a surface water sewer should only be considered where all other options are demonstrated to be impracticable. Any requirements for a surface water connection to our surface water sewer network will require the developer to fund the cost of modelling and any upgrades required to accept the flows from the development.
Anglian Water encourages the use of nature-based solutions for SuDS wherever possible, including retrofitting SuDS to existing urban areas to enhance amenity and biodiversity within the neighbourhood plan area and contribute to green and blue infrastructure.
It is the Government's intention to implement Schedule Three of The Flood and Water Management Act 2010 to make SuDS mandatory in all new developments in England in 2024/ 2025. However, we welcome this policy to ensure SuDS measures are incorporated within new developments, until the Schedule is formally implemented and the necessary measures are in place.
Policy BN NE1 Local Green Space (LGS)
The policy designates areas LGS within the neighbourhood plan area. Anglian Water may have assets forming part of our water and water recycling network (e.g., rising mains and sewers) located near or adjacent to designated areas of local green space. It is noted that that the development is restricted to very special circumstances to be demonstrated. We consider that the policy provides scope for Anglian Water to undertake operational development to maintain and repair any underground network assets that may be within these areas, such as mains water pipes, and which would be consistent with this policy test.
Policy BN NE3 Conserve and Enhance Biodiversity
Anglian Water supports the policy objectives of prioritising the delivery of biodiversity net gains within the neighbourhood planning area to support habitat recovery and enhancements within existing areas green and blue infrastructure. Anglian Water has made a corporate commitment to deliver a biodiversity net gain of 10% against the measured losses of habitats on all AW-owned land.
As the neighbourhood plan progresses, there may also be benefit in referencing the emerging Local Nature Recovery Strategy (LNRS) by the Hertfordshire Nature Recovery Partnership, as this will identify priority actions for nature and map specific areas for improving habitats for nature recovery. Hertfordshire Nature Recovery Partnership | Hertfordshire County Council.
I have been able to get it confirmed that the assets I had previously referred to lying within the site allocation BK3 have been de-commissioned and the site is outside our statutory water boundary, so I have not needed to refer to this in my comments.