B&MSDC Supplementary Planning Documents Consultation

Comment

Representation ID: 23589

Received: 19/06/2024

Respondent: Anglian Water Services Ltd

1.1.
Anglian Water is the water and water recycling provider for over 6 million customers in the east of England. 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.
1.2.
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.
2. Anglian Water and Local Plans
2.1.
Anglian Water is the statutory water and sewerage undertaker for Babergh and Mid Suffolk District Council and a statutory consultee under The Town and Country Planning (Local Planning) (England) Regulations 2012. Anglian Water wants to proactively engage with the plan-making process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. As a purpose-led company, we are committed to seeking positive environmental and social outcomes for our region.
3. Commentary on the Biodiversity & Trees SPD
3.1.
Anglian Water is supportive of the overall aim of this supplementary planning document (SPD) to address biodiversity (net gain) and trees within the districts. As a purpose-led company, we are committed to bringing social and environmental prosperity to our region, which is the largest geographical area of any water company in England and Wales. We have significant assets across the region such as Alton Water, including globally, nationally and locally important wildlife habitats. We also rely on the natural environment to help maintain water quality and quantity; therefore, we recognise the importance of our role to protect the natural environment within our region.
3.2.
Our Biodiversity Strategy sets out our strategy for conserving biodiversity across the East of England, meeting our obligations and contributing to the England Biodiversity Strategy 2020. Under the Natural Environment and Rural Communities (NERC) Act 2006, Anglian Water has a duty to have regard to the conservation of biodiversity in exercising its functions.
3.3.
Anglian Water actively manages its assets (land holdings - including 49 sites that are protected because of their wildlife value), for biodiversity outcomes. Some of our sites have areas that are actively managed for biodiversity conservation and enhancement, and these are promoted,
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including through the provision of biodiversity net gain for onsite works, and the preparation of
Local Nature Recovery Strategies.
Biodiversity Net Gain
3.4.
In accordance with our Biodiversity Strategy, we have an AMP7 (2025-2030) commitment to deliver a minimum of 10% biodiversity net gain through our capital programme and land management activities. In 2023, we reported a 281% net gain in biodiversity where there was a material impact upon biodiversity, recognising the responsibility we have towards contributing to nature recovery. Many of the enhancements were delivered via our @one Alliance, and through our land management activities to help ensure we leave the natural environment in a measurably better state than before our intervention. The @one Alliance delivers complex engineering and construction projects across the Anglian Water region, utilising the skills and expertise provided by seven partner organisations. Our capital programme for AMP8 (2025-30) will deliver on our voluntary Biodiversity Net Gain (BNG) commitment, maximising the potential from nature-based solutions, layering benefits, such as carbon and nutrient reductions, creating new habitats and going beyond the Biodiversity Net Gain statutory obligation through providing BNG on capital schemes that are permitted development.
3.5.
We welcome the reference to the location hierarchy for off-site BNG, and the Local Nature Recovery Strategy. We are proactively liaising on the preparation of the LNRS for Suffolk, and we are supportive of utilising the LNRS priority habitats and species to target how and where BNG should be delivered, in addition to informing on-site BNG provision.
3.6.
Para 5.5.7 We note that planning conditions may include a number of requirements including a biodiversity enhancement strategy for species. We would highlight that there may be circumstances where non-residential developments, such as infrastructure development, may be unable to meet specific enhancements. As an essential infrastructure provider, we are required to implement specific security measures for some of our water treatment and water recycling sites which are particularly critical to providing a clean and safe water supply, and wastewater treatment facilities, under the Water Company Security and Emergency Measures Ministerial Direction 2022 (SEMD). Our fencing specifications flow from the requirements of this direction, with the objective is to protect our drinking water supplies and to prevent people tampering with them. There will be some variation in this depending upon the operations on site and the overall scale. Some large critical sites will have a high level of security, whilst other sites the high standard of protection may apply to certain assets, leaving the rest of the site more open. This is intentionally designed to ensure there are no gaps in security fencing, and where there is evidence of rabbit activity or sandy soils, the fence is to be extended and buried to a minimum depth of 300mm. As a result of these security measures, there will be circumstances where we are unable to provide specific species enhancement measures (e.g. those that require gaps in fencing) and if these were required it could lead to circumstances where we would be unable to meet planning conditions and proceed with essential infrastructure delivery.
3.7.
All our construction projects are carefully planned to avoid and minimise harm to wildlife, and our sites are always surveyed to identify the species we need to protect and enhance. For example, when we submit planning applications for infrastructure, we already include standard
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practice for construction within our planning statements regarding covering excavations or
using scaffold ramps to allow safe exit for animals/mammals having fallen into any excavations.
Biodiversity Design Case Studies
3.8.
We support the reference to:
3.9.
Sustainable Drainage Systems (SuDS) that help to minimise surface water flows and run-off, and the need for designs to enhance biodiversity as part of wider multifunctional green and blue infrastructure provision on sites.
3.10.
Riparian buffer zones to protect rivers and water courses. Further evidence has been developed for nutrient neutrality (designated nutrient sensitive areas) in Norfolk that identifies riparian buffer zones as effective nutrient mitigation, with wider zones being most effective.
3.11.
The naturalisation of water courses can provide positive benefits for slowing flows and reducing the risk of downstream flooding and can be combined with natural flood management schemes. Such measures can provide improved flood protection for downstream development and associated infrastructure.
3.12.
Rewilding - we agree that restoring wetlands and the introduction of beavers can provide positive benefits for nature, reduce flood risk (including surface water flood risk to our sewers), and improve river quality. As part of our Get River Positive pledge to strive to do no harm to rivers, we are working with other organisations to keep our rivers healthy and allow wildlife to flourish. Our involvement with beaver releases in our region has demonstrated successes with reducing flood risk and avoiding the need for carbon intensive capital projects to address flooding in nearby communities. Beaver dams also help to trap water and release it slowly back to the environment and alleviate low water levels in summer, enabling resilience to drought.
Trees in Development
3.13.
Para 5.10.1 Anglian Water agrees that trees can provide a range of benefits in new developments including carbon sequestration and helping to reduce surface water run-off. Anglian Water is working to reduce our operational and capital (embedded) greenhouse gas emissions through, for example, investing in Water Recycling Centres (WRC) to change treatment processes and reduce emissions from treating and managing residents and businesses sewage. This is part of plan to be net zero by 2030. Our plan is to minimise emissions first, then to generate our own renewable energy and lastly to offset emissions, for example by tree planting where appropriate at our operational sites and as part of infrastructure projects.
3.14.
Tree cover can be used as part of a natural flood management in more flood prone catchments to reduce runoff and manage surface water flows. Through our work on chalk stream restoration and wetland habitat and management we would advise that tree planting may not always be the most appropriate solution when groundwater levels and flows need to be maintained. Therefore, the right tree in the right place is key.
3.15.
Para 5.10.16 We support the preparation of a Tree Planting Strategy, to help identify the right locations and suitable planting to increase tree canopy cover across the districts. We
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would welcome inclusion of measures to take account of minimising impacts on underground
utilities such as water mains and sewers.
3.16.
For trees to thrive they need space for root development in the underlying soil, which must be of sufficient capacity to accommodate the rooting habits of the particular species, without impacting on the functioning of our underground assets. A sewer or lateral drain should not be located closer to trees/bushes/shrubs than the canopy width at mature height, except where special protection measures are provided - such as use of appropriate barriers to resist root ingress to the sewer system. The strategy should consider both the growth of tree roots and increased heave and ground movement due to climate change. A tree should not be planted directly over sewers or where excavation onto the sewer would require removal of the tree. To minimise the risk of root damage, tree planting should provide good growing conditions. Guidance can be found in ‘Trees in Hard Landscapes: A Guide for Delivery’.
3.17.
Anglian Water can provide guidance for developers in considering water mains and sewer design and location which should inform tree protection steps and utility construction.
Developing a new residential site (anglianwater.co.uk)
3.18.
The important role of tree retention and landscaping as part of SuDS should also be emphasised. We agree that tree roots can cause structural problems and so their placement should have regard to the location of utilities.
3.19.
As operational sites it is not always possible to plant additional trees on our sites due to the limitations of the site size, layout, safety buffers and buried infrastructure. With successive applications at some of our sites the maximum level of tree cover will likely have already been achieved and so tree retention and management as part of BNG in some cases will more realistic. There may also be security reasons why tree planting may not be appropriate in some locations.
Green Infrastructure to help enhance biodiversity
3.20.
Para 5.11.1 Anglian Water welcomes the intention to produce a Green Infrastructure Strategy for the districts. We would recommend that this is retitled as a Green and Blue Infrastructure Strategy to emphasise the importance of blue infrastructure in reducing flood risk (SuDS), improving water quality, and creating greater resilience to drought - as well as other important benefits for wildlife and amenity.
3.21.
We agree that links across to the emerging LNRS to maximise the opportunities for nature recovery through BNG should be essential to the preparation of this strategy.
4. Conclusion
4.1.
Anglian Water welcomes the opportunity to comment on the draft Biodiversity and Trees SPD for Babergh and Mid Suffolk district councils. We are broadly supportive of the key objectives of this additional guidance and recognise that there are other strategies currently being prepared that underpin the approach to be taken. Regarding these strategies, we have made comments that are specific to our role as an essential infrastructure provider and support our purpose to provide environmental prosperity to the region.

Comment

Representation ID: 23590

Received: 19/06/2024

Respondent: Anglian Water Services Ltd

1.1.
Anglian Water is the water and water recycling provider for over 6 million customers in the east of England. 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.
1.2.
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.
2. Anglian Water and Local Plans
2.1.
Anglian Water is the statutory water and sewerage undertaker for Babergh and Mid Suffolk District Council and a statutory consultee under The Town and Country Planning (Local Planning) (England) Regulations 2012. Anglian Water wants to proactively engage with the plan-making process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. As a purpose-led company, we are committed to seeking positive environmental and social outcomes for our region.
3. Commentary on the Intensive Livestock and Poultry SPD
3.1.
Anglian Water welcomes the introduction of this supplementary planning document (SPD) following the adoption of the Part 1 Joint Local Plan, to provide further guidance on the implementation of Policy LP14, particularly regarding water resources and water quality. Anglian Water is the statutory water provider (together with Essex & Suffolk Water) across both districts, and we have several water abstraction locations, which are sensitive receptors to water quality issues.
3.2.
Anglian Water’s East Suffolk WRZ covers an area of 1241 sq. km and extends inland from Stour, Orwell and Deben estuaries and includes the supply systems for Ipswich, Felixstowe, Hadleigh, Stowmarket and Woodbridge. Supplies in the WRZ are obtained from a combination of sources that include groundwater abstracted from the Suffolk and Essex Chalk aquifers and surface water which is pumped from the River Gipping into Alton Water reservoir.
3.3.
Our revised draft Water Resources Management Plan (October 2023) recognises that non-household demand for water resources continues to grow and the efficient use of water in this sector is becoming increasingly important. Non-household consumption accounts for
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approximately 27% of our overall demand. This demand is difficult to forecast due to lack of
visibility of developers' plans as well as the variability of the wider socio-economic environment we operate in, which is in considerable flux. Identifying the timing and scale of new non-household requirements for water is still a problematic area, as requests for large volumes of water can significantly impact the supply/demand balance.
3.4.
As a result, Anglian Water can no longer guarantee to supply non-domestic water requirements for intensive/high water consumptive uses such as manufacturing/ food processing and production. Our regulatory position means we are unable to supply new non-domestic demands if this jeopardises domestic supplies for existing and new residential customers and businesses. As a result of limited water availability, we are undertaking more modelling and decisions on non-household growth looking at available headroom in the water resource zones. We are looking to work together with new or expanding non-household users that are requesting significant non-domestic water supplies to find solutions such as opportunities for water recycling, reuse, and final effluent reuse. Longer term supply options are dependent on bringing forward two new reservoirs in Lincolnshire and Cambridgeshire, among other options such as desalination and water reuse.
3.5.
Para 1.4: We support the identification of ground water protection and drinking water abstraction points as sensitive land uses and environments, where particular care would need to be undertaken when locating pig and poultry farms due to potential pollutant impacts. In our region, we face significant challenges when addressing raw water quality and ensuring improvements are made both for the environment and the water we treat for our customers. Pollutants such as nitrates, phosphates and pesticides can end up in groundwater aquifers and watercourses as a result of activities such as private discharges (point source pollution) and agricultural practices (diffuse pollution). This can often cause harm to the aquatic environment such as eutrophication, as well as posing challenges to our reservoirs that receive direct input of river flows.
5.4: c) consider and address the impact of water resources and the capacity of the water supply infrastructure network
3.6.
Para 5.4.1: We welcome the recognition of the demand constraints for future non-domestic water supplies to non-household customers within the Anglian Water region. We would request that the following sentence in the paragraph is amended to read:
"Water Resource Zones within the The Anglian Water Resource Zones region also has have constraints in terms of available headroom for non-domestic water resource requests".
3.7.
Para 5.4.3: We note the reference to unsustainable water usage in vulnerable groundwater areas which reflects the Environment Agency's Restoring Sustainable Abstraction (RSA) programme, Water Framework Directive River Basin Management Plan objectives, and long-term sustainable abstraction ambition (National Framework for Water Resources), together
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with other legislative requirements. These environmental measures
result in abstraction reduction and capping of abstraction licence quantities for both water companies and private abstractors to enable more water to be left in sensitive environments.
3.8.
Anglian Water recognises that all our abstractions must be environmentally sustainable. We have and continue to address issues where our abstractions have the potential to cause environmental problems or risks, through our Water Industry National Environment Programme (WIINEP). In our region, we have a significant part to play with the largest WINEP plan of any water company, totalling at £800 million across schemes such as sustainable abstraction, river restoration and improving water quality in AMP7 (2020-2025). Our revised draft WRMP24 identifies how we will continue to meet our sustainable abstraction objectives; aligned with ensuring the security of water supply is not compromised.
3.9.
Para 5.4.4: Anglian Water supports the requirement of a Water Supply Management Statement/Water Resource Assessment to be approved by the local planning authority, in consultation with the relevant water company and the Environment Agency. This will enable us to assess whether there is sufficient headroom available to supply the identified demand for non-domestic water supply, and whether identified water efficiency and integrated water management measures have adequately addressed reductions in overall demand.
3.10.
Para 5.4.5: We note the specific requirements of the methodology to be employed in the Water Resources Assessment, and we are supportive of measures that would demonstrate water neutrality.
3.11.
Para 5.4.6: We agree that water resources from all sources should be accounted for in the Water Resource Assessment, including private boreholes (noting that abstraction from a surface or underground water source of up to 20m3/day can be undertaken from the same source without an abstraction licence) and agricultural reservoirs.
4. Conclusion
4.1.
Anglian Water welcomes the opportunity to comment on the draft Intensive Livestock and Poultry SPD for Babergh and Mid Suffolk district councils. We are broadly supportive of the key objectives of this additional guidance, particularly regarding the requirements for the sustainable use of water resources and ensuring adequate measures for protecting water quality.