Policy BN NE3 Conserve and Enhance Biodiversity

This comment seeks to emphasise the importance of Barkway for Swifts and to amend the wording of policy BN NE3 to reflect this.

It is pleasing to see that Swift bricks are mentioned in the design codes for the two sites specified for development.

Barkway has been surveyed by local Swift groups in 2023 and 2024, and a minimum of 15 nests have been found so far, mainly on the High Street. We suspect that there may be quite a few more yet to be found. For a settlement of this size, this amounts to a very high density of nesting Swifts, and means that Barkway is emerging as a key area for this species in the North Herts Council area.

All of these nests are under the eaves of older buildings, but are vulnerable should the building owners seek to repair or improve their properties, in which case the nests would be lost. Swifts have declined nationally by over 50% since 1995, with loss of nest sites being a key factor in this reduction.

To help mitigate such losses, Swift bricks integrated within the walls of new buildings are an ideal solution. They are inexpensive and last the lifetime of the building, requiring no maintenance. In addition, Swift bricks conform to the British Standard for integrated nest boxes, BS42021:2022, meaning that they are effectively universal, providing nest cavities for a number of small birds, including four red-listed species of conservation concern: Swift, House Martin, House Sparrow and Starling.

To promote such a biodiversity enhancement, please consider specifying Swift bricks in policy BN NE3. A suggested addition could be as follows:

Development will be supported where:
"f) Swift bricks are proposed in all suitable buildings"

This wording would not mandate Swift bricks, given the drafting of policy BN NE3 overall, but will encourage developers to include Swift bricks at the design stage of planning applications throughout the Neighbourhood Plan area, and not just in the two specified development areas.

This proposal will also not conflict with the provisions of North Herts Local Plan policy NE4 11.24, which specifically encourages the use of integrated Swift boxes as promoting Biodiversity Net Gains

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.

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