Comment

Representation ID: 594

Received: 18/01/2024

Respondent: Environment Agency

A number of studies have since been udpated (see submission). Having said that we support the recommendations on water efficiency for new developments which have informed your draft Policy xxxxx. Whilst our plans and strategies have been updated, the primary reason for reviewing the study is to consider the latest water company plans as stated above.

We do welcome the reference to the hierarchy for foul drainage, and that proposals will not be permitted if they result in unacceptable risk to the quality or quantity of a waterbody. The policy could be improved by requiring proposals to consider how they can improve water quality as well as mitigate.

Water Water Treatment Works have limited capacity. Further work is required and is recommended by the Phase 1 to undertake a Phase 2 Outline Study (page 95). This would be a water quality assessment of how the proposed development in the draft local plan could impact the receiving waterbodies from increased discharges. We strongly recommend this is taken forward. We would not be able to accept a scenario where increased discharges would risk deterioration of waterbodies given our duties under The Water Environment (Water Framework Directive) Regulations 2017. Similarly, local authorities must, when exercising their duties, have regard to River Basin Management Plans under section 33 of this legislation.

SuDs should be considered on sites that do not have a direct pathway to a SSSI. Could be linked to DLP45 and DLP46, which does not mention water quality.

Paragraph 12.59 refers to the Water Framework Directive and the objective for no deterioration. We think this section could be improved by summarising the current classification of waterbodies in Dudley and reasons for not achieving good as further context/evidence. The WFD surface waterbodies crossing Dudley have the following names and classification status:
• Stour (Worcs) source to conf Smestow Bk (GB109054044750) – status ‘poor.’
• Bobs-Holbeche Bk source to conf Smestow Bk (GB109054044830) – status ‘poor.’
• Birmingham to Wolverhampton Canal, Wolverhampton Level (GB70410516) – status ‘moderate.’ • Stourbridge Canal (GB70910519) – status ‘moderate.’
• Dudley Canals (GB70910535) – status ‘moderate.’
The waterbodies are unable to achieve good status for a variety of reasons (urban runoff, outfall discharges, physical modifications). The Black Country Councils Water Cycle Study Phase 1 Scoping (2020) will likely have information on this and there’s also the Severn River Basin Management Plan (2022) and associated Catchment Data Explorer.

Comment

Representation ID: 752

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests the inclusion of a list of potential receptors for water quality impacts, and inclusion of our network within it. Alternatively, incorporation of cross-referencing to Canal Policy DLP36.

Comment

Representation ID: 875

Received: 09/04/2024

Respondent: Severn Trent

Agent: Severn Trent

Water Quality and Resources
Good quality watercourses and groundwater is vital for the provision of good quality drinking water. We work closely with the Environment Agency and local farmers to ensure that the water quality of our supplies are not impacted by our operations or those of others. Any new developments need to ensure that the Environment Agency’s Source Protection Zones (SPZ) and Safeguarding Zone policies which have been adopted by Natural Resources Wales are adhered to. Any proposals should take into account the principles of the Water Framework Directive and River Basin Management Plan as prepared by the Environment Agency.

Every five years we produce a Water Resources Management Plan (WRMP) which focuses on how we plan to ensure there is sufficient supply of water to meet the needs of our customers whilst protecting our environment over the next 25 years. We use housing target data from Local Planning Authorities to plan according to the projected growth rates. New development results in the need for an increase in the amount of water that needs to be supplied across our region. We are committed to doing the right thing and finding new sustainable sources of water, along with removing unsustainable abstractions, reducing leakage from the network and encouraging the uptake of water meters to promote a change in water usage to reduce demand.

New developments have a role to play in protecting water resources, we encourage you to include the following policies:
Protection of Water Resources Policy
New developments must demonstrate that they will not result in adverse impacts on the quality of waterbodies, groundwater and surface water, will not prevent waterbodies and groundwater from achieving a good status in the future and contribute positively to the environment and ecology. Where development has the potential to directly or indirectly pollute groundwater, a groundwater risk assessment will be needed to support a planning application.

Supporting Text:
National Planning Policy Framework (July 2021) Paragraph 174 states:
“Planning policies and decisions should contribute to and enhance the natural and local environment by:
e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans;”

Water Efficiency Policy
We are supportive of the use of water efficient design of new developments fittings and appliances and encourage the optional higher water efficiency target of 110 litres per person per day within part G of building regulations. Delivering against the optional higher target or better provides wider benefits to the water cycle and environment as a whole. This approach is not only the most sustainable but the most appropriate direction to deliver water efficiency. We would therefore recommend that the following wording is included for the optional higher water efficiency standard:

New developments should demonstrate that they are water efficient, incorporating water efficiency and re-use measures and that the estimated consumption of wholesome water per dwelling is calculated in accordance with the methodology in the water efficiency calculator, not exceeding 110 litres/person/day.

Supporting Text:
National Planning Policy Framework (July 2021) Paragraph 153 states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, costal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. Policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.”

This need for lower water consumption standards for new developments is supported by Government. In December 2018, the Government stated the need to a reduction in Per Capita Consumption (PCC) and issued a call for evidence on future PCC targets in January 2019, with an intention of setting a long term national target.

The National Infrastructure Commission (NIC) has already presented a report including recommendations for an average PCC of 118 l/p/d. In Wales, the 110 l/p/d design standard was made mandatory in November 2018. In 2021 the Environment Agency classed the Severn Trent region as Seriously Water Stressed – link.

We recommend that all new developments consider:
• Single flush siphon toilet cistern and those with a flush volume of 4 litres.
• Showers designed to operate efficiently and with a maximum flow rate of 8 litres per minute.
• Hand wash basin taps with low flow rates of 4 litres per minute or less.
• Water butts for external use in properties with gardens.

Water Supply
For the majority of new developments, we do not anticipate issues connecting new development, particularly within urban areas of our water supply network. When specific detail of planned development location and sizes are available a site-specific assessment of the capacity of our water supply network could be made. Any assessment will involve carrying out a network analysis exercise to investigate any potential impacts. If significant development in rural areas is planned, this is more likely to have an impact and require network reinforcements to accommodate greater demands.