Draft North East Cambridge Area Action Plan

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Comment

Draft North East Cambridge Area Action Plan

Policy 1: A comprehensive approach at North East Cambridge

Representation ID: 54278

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Figure 10: The Spatial Framework for the Area Action Plan

Anglian Water notes the inclusion of a Spatial Framework Plan for the AAP area (figure 10) which amongst other matters identifies potential locations for new and retained green spaces. Within Anglian Water’s existing Waste Water Treatment Plant (WWTP) site there will need to be an element of retained infrastructure (following rationalisation of the existing rising mains within the site) including surface assets (i.e. manholes) along with connections and associated infrastructure to the new WWTP which will include a new tunnel shaft along with new surface and above ground assets such as venting structures. Access to these assets (retained and new) will be required for maintenance purposes. Associated buffer areas and easements will also be necessary for protection. Anglian Water would welcome the opportunity to work with the Council on the development of the spatial framework plan to ensure that both its retained infrastructure and new assets can be appropriately accommodated within the layout.

Policy 1: A comprehensive approach at North East Cambridge

Anglian Water welcomes the reference to a comprehensive and co-ordinated approach to the development of North East Cambridge including the provision of infrastructure.

Policy 1 refers to the re-location of existing uses. As proposed, it does not specifically refer to the re-location of Cambridge Wastewater Treatment Plant which forms an integral part of the AAP and the proposed spatial strategy following the previous consultation.

The Councils have resolved that the re-location of Cambridge Wastewater Treatment Plan is necessary for the development strategy at Cambridge North East which is to be pursued. It is therefore important that this is made clear in both the AAP and underpinned by the supporting technical evidence e.g. Sustainability Appraisal.

Anglian Water welcomes the reference to a comprehensive and co-ordinated approach to the development of North East Cambridge including the provision of infrastructure.

It is therefore proposed that the first sentence of Policy 1 is amended as follows:

'The Councils will work to secure the comprehensive regeneration of North East Cambridge during the plan period, in particular the creation of a new high quality mixed-use city district, providing at least 8,000 new homes, 20,000 new jobs, and new physical, social and environmental infrastructure that meets the needs of new and existing residents and workers, as well as delivering tangible benefits for surrounding communities. In order to achieve this, the Councils will work in collaboration with the County Council, Greater Cambridge Partnership, other strategic partners [including Anglian Water,] [new text] and landowners to:

a) Secure and deliver the interventions and infrastructure needed to deliver the vision and objectives for the area including: the required modal shift in accordance with the North East Cambridge Transport Study; district-wide networks and services; [relocation of Cambridge Wastewater Treatment Plan (which is required for the proposed spatial strategy) and potentially existing business use]s [new text] and land assembly; environmental, amenity, and community health and wellbeing standards; a network of functional and multi-use open spaces; and innovative approaches to community facilities provision;

Full text:

Figure 10: The Spatial Framework for the Area Action Plan

Anglian Water notes the inclusion of a Spatial Framework Plan for the AAP area (figure 10) which amongst other matters identifies potential locations for new and retained green spaces. Within Anglian Water’s existing Waste Water Treatment Plant (WWTP) site there will need to be an element of retained infrastructure (following rationalisation of the existing rising mains within the site) including surface assets (i.e. manholes) along with connections and associated infrastructure to the new WWTP which will include a new tunnel shaft along with new surface and above ground assets such as venting structures. Access to these assets (retained and new) will be required for maintenance purposes. Associated buffer areas and easements will also be necessary for protection. Anglian Water would welcome the opportunity to work with the Council on the development of the spatial framework plan to ensure that both its retained infrastructure and new assets can be appropriately accommodated within the layout.

Policy 1: A comprehensive approach at North East Cambridge

Anglian Water welcomes the reference to a comprehensive and co-ordinated approach to the development of North East Cambridge including the provision of infrastructure.

Policy 1 refers to the re-location of existing uses. As proposed, it does not specifically refer to the re-location of Cambridge Wastewater Treatment Plant which forms an integral part of the AAP and the proposed spatial strategy following the previous consultation.

The Councils have resolved that the re-location of Cambridge Wastewater Treatment Plan is necessary for the development strategy at Cambridge North East which is to be pursued. It is therefore important that this is made clear in both the AAP and underpinned by the supporting technical evidence e.g. Sustainability Appraisal.

Anglian Water welcomes the reference to a comprehensive and co-ordinated approach to the development of North East Cambridge including the provision of infrastructure.

It is therefore proposed that the first sentence of Policy 1 is amended as follows:

'The Councils will work to secure the comprehensive regeneration of North East Cambridge during the plan period, in particular the creation of a new high quality mixed-use city district, providing at least 8,000 new homes, 20,000 new jobs, and new physical, social and environmental infrastructure that meets the needs of new and existing residents and workers, as well as delivering tangible benefits for surrounding communities. In order to achieve this, the Councils will work in collaboration with the County Council, Greater Cambridge Partnership, other strategic partners [including Anglian Water,] [new text] and landowners to:

a) Secure and deliver the interventions and infrastructure needed to deliver the vision and objectives for the area including: the required modal shift in accordance with the North East Cambridge Transport Study; district-wide networks and services; [relocation of Cambridge Wastewater Treatment Plan (which is required for the proposed spatial strategy) and potentially existing business use]s [new text] and land assembly; environmental, amenity, and community health and wellbeing standards; a network of functional and multi-use open spaces; and innovative approaches to community facilities provision;

Comment

Draft North East Cambridge Area Action Plan

Policy 4a: Water Efficiency

Representation ID: 54279

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Policy 4a: Water efficiency

Anglian Water as sewerage undertaker for the North East Cambridge area fully supports increased water efficiency and re-use within both residential and commercial developments as these have wider community and environmental benefits.

Policy 4a as drafted seeks to promote increased water efficiency within residential development beyond that which is currently specified in national building standards.

We fully support the intention that residential development proposals will be expected to meet a higher standard for water efficiency rather than be limited to the existing national standard wherever possible. This is particularly important given Defra’s recent consultation on personal consumption of water which included reference to potential changes to existing building regulations on water efficiency.

We would recommend that the wording as proposed should be revised to ensure it is effective and sets out clearly what is the requirement for applicants for residential developments.

Reference is made to rainwater harvesting but it is not clear if this also includes larger scale surface water (stormwater) harvesting (where surface water is captured for re-use). Also, reference is made to water recycling. It is assumed that this term is intended to refer to water recycling systems that capture and treat used water so it can be reused which can include greywater recycling.

It is therefore proposed that the first sentence of Policy 4a is amended as follows:

'All new residential developments must achieve, as a minimum, water efficiency equivalent to 110 litres/person/day. m[delete][M][new text]oving towards a target of water use of no more than 80 litres/person/day giving consideration [by maximising the water re-use measures] [new text] including rainwater harvesting, [surface water harvesting] [new text] and/or water recycling [as part of an integrated approach to water management and green infrastructure delivery.'] [new text]

Full text:

Policy 4a: Water efficiency

Anglian Water as sewerage undertaker for the North East Cambridge area fully supports increased water efficiency and re-use within both residential and commercial developments as these have wider community and environmental benefits.

Policy 4a as drafted seeks to promote increased water efficiency within residential development beyond that which is currently specified in national building standards.

We fully support the intention that residential development proposals will be expected to meet a higher standard for water efficiency rather than be limited to the existing national standard wherever possible. This is particularly important given Defra’s recent consultation on personal consumption of water which included reference to potential changes to existing building regulations on water efficiency.

We would recommend that the wording as proposed should be revised to ensure it is effective and sets out clearly what is the requirement for applicants for residential developments.

Reference is made to rainwater harvesting but it is not clear if this also includes larger scale surface water (stormwater) harvesting (where surface water is captured for re-use). Also, reference is made to water recycling. It is assumed that this term is intended to refer to water recycling systems that capture and treat used water so it can be reused which can include greywater recycling.

It is therefore proposed that the first sentence of Policy 4a is amended as follows:

'All new residential developments must achieve, as a minimum, water efficiency equivalent to 110 litres/person/day. m[delete][M][new text]oving towards a target of water use of no more than 80 litres/person/day giving consideration [by maximising the water re-use measures] [new text] including rainwater harvesting, [surface water harvesting] [new text] and/or water recycling [as part of an integrated approach to water management and green infrastructure delivery.'] [new text]

Comment

Draft North East Cambridge Area Action Plan

Policy 4b: Water quality and demand

Representation ID: 54280

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Policy 4b: Water Quality and ensuring supply

First paragraph: reference is made to the preparation of a water quality assessment to be secured through a planning obligation. It appears to relate to ground contamination from the previous and current uses of the AAP area and the need to utilise appropriate surface water management measures. The policy requirement refers to foul sewerage, ground water and surface water and the potential for mitigation measures for the First Public Drain where necessary.

It is unclear whether this is intended to refer to the potential for contaminated land on all sites, what form this should take and how it relates to the requirements outlined in the second paragraph of the policy.

It is therefore proposed that text be amended to make it clear what the requirement is for applicants to ensure it is effective. This would include an explicit reference to ground contamination and the need to consider appropriate surface water management measures.

Second paragraph: we welcome reference made to developers demonstrate that adequate sewerage and sewage treatment capacity is available to serve the development. Therefore, to make the policy effective we would ask that the text refers to the potential for enhancement of the existing foul sewerage network to accommodate additional foul flows arising from development.

It is therefore proposed that the second paragraph of Policy 4b is amended as follows:

'The council will expect developers to demonstrate that all proposed development will be served by an adequate supply of water, appropriate sewerage infrastructure [including any required enhancement] [new text] and that there is sufficient sewage treatment capacity to ensure that there is no deterioration of water quality.

Full text:

Policy 4b: Water Quality and ensuring supply

First paragraph: reference is made to the preparation of a water quality assessment to be secured through a planning obligation. It appears to relate to ground contamination from the previous and current uses of the AAP area and the need to utilise appropriate surface water management measures. The policy requirement refers to foul sewerage, ground water and surface water and the potential for mitigation measures for the First Public Drain where necessary.

It is unclear whether this is intended to refer to the potential for contaminated land on all sites, what form this should take and how it relates to the requirements outlined in the second paragraph of the policy.

It is therefore proposed that text be amended to make it clear what the requirement is for applicants to ensure it is effective. This would include an explicit reference to ground contamination and the need to consider appropriate surface water management measures.

Second paragraph: we welcome reference made to developers demonstrate that adequate sewerage and sewage treatment capacity is available to serve the development. Therefore, to make the policy effective we would ask that the text refers to the potential for enhancement of the existing foul sewerage network to accommodate additional foul flows arising from development.

It is therefore proposed that the second paragraph of Policy 4b is amended as follows:

'The council will expect developers to demonstrate that all proposed development will be served by an adequate supply of water, appropriate sewerage infrastructure [including any required enhancement] [new text] and that there is sufficient sewage treatment capacity to ensure that there is no deterioration of water quality.

Comment

Draft North East Cambridge Area Action Plan

Policy 4c: Flood Risk and Sustainable Drainage

Representation ID: 54281

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Paragraph e: reference is made to brown water harvesting when referring to surface water hierarchy. It is assumed that this term is intended to refer to water recycling systems that capture and treat used water so it can be reused which can include greywater reuse. As such it doesn't relate to surface flows and reference should be made to surface water harvesting as suggested for Policy 4a of the AAP.

Reference is made to the preparation of a Strategic Flood Risk Assessment consistent with the requirements of the NPPF. As SFRAs as normally prepared to support the preparation of local plans it assumed that is intended to refer to a Flood Risk Assessment and the text should be amended to this effect.

It is therefore proposed that Policy 4c is amended as follows;

e) wherever reasonably practical, the destination of the discharge obeys the following priority order: 1) Water reuse: [and brown] [delete text] [surface water] [new text] and rainwater harvesting;

Development proposals will be required to carry out a [Strategic] [delete text] Flood Risk Assessment following the principles of the National Planning Policy Framework (2019).

Full text:

Paragraph e: reference is made to brown water harvesting when referring to surface water hierarchy. It is assumed that this term is intended to refer to water recycling systems that capture and treat used water so it can be reused which can include greywater reuse. As such it doesn't relate to surface flows and reference should be made to surface water harvesting as suggested for Policy 4a of the AAP.

Reference is made to the preparation of a Strategic Flood Risk Assessment consistent with the requirements of the NPPF. As SFRAs as normally prepared to support the preparation of local plans it assumed that is intended to refer to a Flood Risk Assessment and the text should be amended to this effect.

It is therefore proposed that Policy 4c is amended as follows;

e) wherever reasonably practical, the destination of the discharge obeys the following priority order: 1) Water reuse: [and brown] [delete text] [surface water] [new text] and rainwater harvesting;

Development proposals will be required to carry out a [Strategic] [delete text] Flood Risk Assessment following the principles of the National Planning Policy Framework (2019).

Comment

Draft North East Cambridge Area Action Plan

Policy 5: Biodiversity and Net Gain

Representation ID: 54282

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Anglian Water welcomes the reference to development proposals providing biodiversity net gain having followed the mitigation hierarchy. The requirements of Policy 5 should be consistent with the emerging Environment Bill which is expected to be considered by Parliament later this year.

Full text:

Anglian Water welcomes the reference to development proposals providing biodiversity net gain having followed the mitigation hierarchy. The requirements of Policy 5 should be consistent with the emerging Environment Bill which is expected to be considered by Parliament later this year.

Comment

Draft North East Cambridge Area Action Plan

Policy 8: Open spaces for recreation and sport

Representation ID: 54283

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Anglian Water notes the inclusion of a Spatial Framework Plan for the AAP area (figure 19) which amongst other matters identifies potential locations for existing and proposed public green spaces. Within Anglian Water’s existing Waste Water Treatment Plant (WWTP) site there will need to be an element of retained infrastructure (following rationalisation of the existing rising mains within the site) including surface assets (i.e. manholes) along with connections and associated infrastructure to the new WWTP which will include a new tunnel shaft along with new surface and above ground assets such as venting structures. Access to these assets (retained and new) will be required for maintenance purposes. Associated buffer areas and easements will also be necessary for protection. Anglian Water would welcome the opportunity to work with the Council on the development of the open space network to ensure that both its retained infrastructure and new assets can be appropriately accommodated within the layout.

Full text:

Anglian Water notes the inclusion of a Spatial Framework Plan for the AAP area (figure 19) which amongst other matters identifies potential locations for existing and proposed public green spaces. Within Anglian Water’s existing Waste Water Treatment Plant (WWTP) site there will need to be an element of retained infrastructure (following rationalisation of the existing rising mains within the site) including surface assets (i.e. manholes) along with connections and associated infrastructure to the new WWTP which will include a new tunnel shaft along with new surface and above ground assets such as venting structures. Access to these assets (retained and new) will be required for maintenance purposes. Associated buffer areas and easements will also be necessary for protection. Anglian Water would welcome the opportunity to work with the Council on the development of the open space network to ensure that both its retained infrastructure and new assets can be appropriately accommodated within the layout.

Comment

Draft North East Cambridge Area Action Plan

Policy 9: Density, heights, scale and massing

Representation ID: 54284

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

In view of the proposed building heights which will require deep foundations the future developers will need to work with Anglian Water to ensure that these do not result in any harm to its retained or new infrastructure/assets.

Full text:

In view of the proposed building heights which will require deep foundations the future developers will need to work with Anglian Water to ensure that these do not result in any harm to its retained or new infrastructure/assets.

Comment

Draft North East Cambridge Area Action Plan

Policy 12a: Business

Representation ID: 54285

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Anglian Water site: we own and operate the Cambridge Wastewater Treatment Plant (WWTP) located off Cowley Road which is identified, together with adjacent land owned by Cambridge City Council, for residential led mixed use development and remain committed to working with partners to prepare plans for its redevelopment.

As set out in the AAP the relocation of existing WWTP is to be funded through the Government's Housing Infrastructure Fund. Anglian Water has recently published site options for the re-location of Cambridge WWTP as part of an initial consultation to inform a future DCO application which is expected to be submitted in 2022.

Please note that there will be a requirement before planning permission can be implemented for the EA permit for the site to be formally rescinded.

Other allocated employment sites: there are a number of existing foul and surface water sewers located within the boundary of the sites identified.

It is important that we can continue to access these assets for maintenance purposes following development of these sites for employment. Therefore, the layout of these sites should consider the location of existing assets as part of the design of new development where relevant.

Full text:

Anglian Water site: we own and operate the Cambridge Wastewater Treatment Plant (WWTP) located off Cowley Road which is identified, together with adjacent land owned by Cambridge City Council, for residential led mixed use development and remain committed to working with partners to prepare plans for its redevelopment.

As set out in the AAP the relocation of existing WWTP is to be funded through the Government's Housing Infrastructure Fund. Anglian Water has recently published site options for the re-location of Cambridge WWTP as part of an initial consultation to inform a future DCO application which is expected to be submitted in 2022.

Please note that there will be a requirement before planning permission can be implemented for the EA permit for the site to be formally rescinded.

Other allocated employment sites: there are a number of existing foul and surface water sewers located within the boundary of the sites identified.

It is important that we can continue to access these assets for maintenance purposes following development of these sites for employment. Therefore, the layout of these sites should consider the location of existing assets as part of the design of new development where relevant.

Comment

Draft North East Cambridge Area Action Plan

Policy 13a: Housing

Representation ID: 54286

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Anglian Water site: we own and operate the Cambridge Wastewater Treatment Plant (WWTP) located off Cowley Road which, together with adjacent land owned by Cambridge City Council, is identified for residential led mixed use development and remain committed to working with partners to prepare plans for its redevelopment.

As set out in the AAP the relocation of existing WWTP is to be funded through the Government's Housing Infrastructure Fund. Anglian Water has recently published site options for the re-location of Cambridge WWTP as part of an initial consultation to inform a future DCO application which is expected to be submitted in 2022.

Please note that there will be a requirement before planning permission can be implemented for the EA permit for the site to be formally rescinded.

Other allocated housing sites: there are a number of existing foul and surface water sewers located within the boundary of the sites identified.

It is important that we can continue to access these assets for maintenance purposes following re-development of these sites for housing. Therefore, the layout of these sites should consider the location of existing assets as part of the design of new development where relevant.

Full text:

Anglian Water site: we own and operate the Cambridge Wastewater Treatment Plant (WWTP) located off Cowley Road which, together with adjacent land owned by Cambridge City Council, is identified for residential led mixed use development and remain committed to working with partners to prepare plans for its redevelopment.

As set out in the AAP the relocation of existing WWTP is to be funded through the Government's Housing Infrastructure Fund. Anglian Water has recently published site options for the re-location of Cambridge WWTP as part of an initial consultation to inform a future DCO application which is expected to be submitted in 2022.

Please note that there will be a requirement before planning permission can be implemented for the EA permit for the site to be formally rescinded.

Other allocated housing sites: there are a number of existing foul and surface water sewers located within the boundary of the sites identified.

It is important that we can continue to access these assets for maintenance purposes following re-development of these sites for housing. Therefore, the layout of these sites should consider the location of existing assets as part of the design of new development where relevant.

Comment

Draft North East Cambridge Area Action Plan

Policy 19: Safeguarding for Cambridge Autonomous Metro and Public Transport

Representation ID: 54287

Received: 05/10/2020

Respondent: Anglian Water Services Ltd

Representation Summary:

Land is safeguarded for the 'North Portal' located in the vicinity of existing Cambridge North Station as part of proposals for Cambridge Autonomous Metro as identified on Figure 38 of the AAP.

We own and operate the Cambridge Wastewater Treatment Plant (WWTP) located off Cowley Road which, together with adjacent land owned by Cambridge City Council, is identified for residential led mixed use development and remain committed to working with partners to prepare plans for its redevelopment.

We welcome further discussion with the Combined Authority about the detailed design of ‘North Portal’ and associated northern tunnel in relation to the location of any infrastructure which is expected to remain in situ following the redevelopment of Cambridge WWTP.

The indicative area for the North Portal as identified in the AAP does not appear to raise any issues for Anglian Water as it appears to be focused on existing Cambridgeshire Guided Busway route and land adjacent to the busway and there is no existing water recycling infrastructure in this location. We would wish to comment further in the event that the extent of the safeguarded area as shown in the AAP is to be revise

Full text:

Land is safeguarded for the 'North Portal' located in the vicinity of existing Cambridge North Station as part of proposals for Cambridge Autonomous Metro as identified on Figure 38 of the AAP.

We own and operate the Cambridge Wastewater Treatment Plant (WWTP) located off Cowley Road which, together with adjacent land owned by Cambridge City Council, is identified for residential led mixed use development and remain committed to working with partners to prepare plans for its redevelopment.

We welcome further discussion with the Combined Authority about the detailed design of ‘North Portal’ and associated northern tunnel in relation to the location of any infrastructure which is expected to remain in situ following the redevelopment of Cambridge WWTP.

The indicative area for the North Portal as identified in the AAP does not appear to raise any issues for Anglian Water as it appears to be focused on existing Cambridgeshire Guided Busway route and land adjacent to the busway and there is no existing water recycling infrastructure in this location. We would wish to comment further in the event that the extent of the safeguarded area as shown in the AAP is to be revise

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