The Greater Norwich Local Plan (GNLP) is being produced by Broadland District Council, Norwich City Council and South Norfolk Council working together with Norfolk County Council through the Greater Norwich Development Partnership (GNDP).

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Representation 16762 on Evidence Base by Anglian Water Services Ltd (Mr Stewart Patience)

Support / Object: COMMENT
Document Link: Evidence Base - Interim Habitats Regulations Assessment (HRA)
Representation: Comments raised on the Interim Habitats Regulation Assessment with comments on, increased pressure on water resources, pollution impacts, water pollution and recommendations for future study. Please see attached full rep.

Original submission

Evidence Base: Interim Habitats Regulation Assessment
Para 3.2.1 - Increased pressure on water resources (page 30)
Reference is made to a need for an additional borehole to supply potable (drinking) water. It is unclear on what basis this assumption has been made. Anglian Water has recently published a Draft Water Resource Management Plan which subject to approval by Defra is intended to replace the approved WRMP 2015. We would ask that the Habitats Regulation Assessment makes reference to the findings of this document particularly in relation to the proposals for the relevant Water Resource Zones for the Greater Norwich area.
Para 3.2.1 - Pollution impacts (page 30)
Similarly reference is made to the potential for pollution to the introduction of additional foul flows from new development in the Greater Norwich area to water recycling centres in Anglian Water's ownership. It should not be assumed that a deterioration of water quality to designated European sites will result from additional development draining to existing WRCs.
WRC permits have a variety of conditions including the permitted dry weather flow(DWF) and the chemical standard of discharge. Permits are issued by the Environment Agency and the conditions applied are site specific, set at a level to ensure sufficient water quality at the discharge point. WRCs are designed to meet the specific conditions within their permit. We regularly monitor our position against both the DWF and the standards, promoting investigation, a change in working practices and investment through our business planning process where required.
Anglian Water through our business planning process promotes investment at WRCs and/or within the sewerage catchment to ensure our water recycling infrastructure is aligned with new development and to ensure we can comply with the permits issued by the Environment Agency.
For the purposes of the Habitats Regulation Assessment it is recommended that that only the WRCs which discharge directly or indirectly to a watercourse which is of European significance should be considered as part of the assessment.
Section 3.4 - increased pressure on water resources (pages 34-36)
This section should be updated to take account of Anglian Water's Draft WRMP 2018 which is intended to replace the existing WRMP published in 2015.
Section 3.4 - pollution impacts: water pollution (pages 36)
Reference is made to the potential for pollution to the introduction of additional foul flows from new development in the Greater Norwich area to water recycling centres in Anglian Water's ownership. It should not be assumed that a deterioration of water quality to designated European sites will result from additional development draining to existing WRCs. Anglian Water through our business planning process promotes investment at WRC and/or within the sewerage catchment to ensure our water recycling infrastructure is aligned with new development.
WRC permits have a variety of conditions including the permitted dry weather flow(DWF) and the chemical standard of discharge. Permits are issued by the Environment Agency and the conditions applied are site specific, set at a level to ensure sufficient water quality at the discharge point. WRCs are designed to meet the specific conditions within their permit. We regularly monitor our position against both the DWF and the standards, promoting investigation, a change in working practices and investment through our business planning process where required.
Para 4.8 - recommendations for further study (page 46)
Reference is made to the preparation of a Water Cycle Study to assess further the water quality and impacts from additional abstraction.
Proposals for additional water abstraction and any associated sustainability reductions set out by the Environment Agency are normally considered as part of the Water Resource Management Plan process. We are also preparing a Long Term Water Recycling Plan as part of which are considering how we can continue to comply with permits issued by the EA.
Reference is made to the need for a Water Cycle Study to support the preparation of the Greater Norwich Local Plan in the Habitats Regulation Assessment Scoping report. We would welcome further discussions with the Greater Norwich Local Plan Team regarding the scope of any technical study in the context of the Draft Water Resource Management Plan and Draft Long Term Water Recycling Plan which are being prepared by Anglian Water. We would wish to agree the scope of any further technical work with the Local Plan Team to ensure it doesn't duplicate any information already set out in Anglian Water's documents.

Attached Files for this Submission


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