Object

Representation ID: 9773

Received: 22/07/2022

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy DS1(S) has many positive elements to it and we support the Council’s aim to be carbon neutral and deliver climate change mitigation and adaptation.

The development strategy (paragraphs 4.3 and 4.7) explains that to meet assessed needs to 2040, there has been an uplift of the housing requirement of 40% from 970 dwellings per annum (2030 plan) to 1355 dwellings per annum. We have reviewed sections 5.3 Potable Water and 5.4 Wastewater of the Infrastructure Delivery Plan dated May 2022. We are concerned that the IDP doesn’t provide sufficient evidence to demonstrate that the proposed growth put forward by the plan can be delivered sustainably, and not place further pressures on a water environment (notably rivers and groundwater) which is already under pressure from abstraction for public water supply and wastewater discharges. We are therefore concerned that Policy DS1(S) ‘Resources and Climate Change’ and potentially Policy DS3(S) ’Amount and timing of growth’ are unsound as they are not consistent with paragraphs 20 and 153 of the NPPF. Paragraph 20 sets the baseline in requiring that strategic policies should make sufficient provision for (b) infrastructure for water supply and wastewater (amongst other strategic issues). Paragraph 153 is requiring that plans take a pro-active approach to mitigating and adapting to climate change, taking into account the long-term implications for (amongst various issues) water supply.

Section 5.3 (Potable Water) of the IDP describes the predicted deficits in future water supply faced by Anglian Water as detailed in their Water Resources Management Plan (2019). A draft update to the company’s WRMP is about to be published in Autumn 2022, with the final plan expected in 2024. The Council at the earliest opportunity should seek advice from Anglian Water on how relevant the 2019 WRMP remains as a long-term planning tool. This particularly relates to the figures quoted in 1.4.12 and 5.3. We advise extreme caution in using the figures quoted in the 2019 WRMP unless they are demonstrated to remain relevant in the context of the company’s forthcoming WRMP24. The 2015 Anglian Region River Basin Management Plan (RBMP) that current levels of water abstraction are causing, or risk causing, environmental damage in various river catchments across East Anglia and measures have been identified in the RBMP to address this. We have recently undertaken abstraction licence reviews to ensure waterbodies comply with the Water Framework Directive objectives. Given the water resource pressures in the region, we cannot rule out further reductions in the supplies available to Anglian Water to prevent deterioration of water related ecology. Any resultant loss in available supplies will need to be addressed in the company’s WRMP24. It should be noted that replacement supplies are likely to require strategic supply options (for example, reservoirs and long-distance transfers) that could have significant delivery times. This should be an important consideration and inform Policy DS3(S) which sets out the amount and timing of growth. The stepped trajectory noted in Local Plan paragraph 4.25 refers to ‘critical infrastructure’ and paragraph 4.27 alludes to transport infrastructure. However, for the plan’s policies to be effective and deliverable, it needs to be proven that water supplies can be delivered sustainably and review the trajectory of growth accordingly.

Whilst section 5.3 of the IDP notes that Bedford is not the only local authority supplied by the Ruthamford Water Resource Zone, the effects of growth need to be considered at the company/regional scale and in combination with the other authorities’ local plans to assess the overall effect on the ability to supply water whilst meeting environmental obligations. Spare capacity in the Ruthamford resource zone may already be allocated to 1. Growth in resources zones elsewhere in the company’s network, 2. Transfers to other companies in the region, or 3. To offset supply reductions to protect the environment. The local plan needs to take account of the combined effect of growth across the region, including in neighbouring authorities, and therefore the overall increase in demand for water and not just that of Bedford Borough area.

For wastewater we are concerned that the IDP relies on Anglian Water’s now out-of-date Water Recycling Long Term Plan 2018 which will be reviewed as part of the forthcoming Drainage and Wastewater Management Plan due in Autumn 2022. It’s not demonstrated whether the proposed level of growth in the 2040 (or indeed 2030) plan has been accounted for in the water companies plans and the in-combination effects of proposed growth in neighbouring districts whilst utilising infrastructure in Bedford has been accounted for. It needs to be demonstrated that the delivery of the 2040 plan will not result in a breach of environmental legislation due to the increase in foul drainage generated (and discharged via sewerage infrastructure into local watercourses). Assessments carried out should highlight locations where upgrades to the foul water infrastructure are necessary and identify measures, including phasing new development, so that wastewater infrastructure will be in place to avoid creating local environmental problems.

There also doesn’t appear to be an assessment of whether there are likely to be significant effects from the plan’s proposed growth on habitat sites or features from a reduction in water quality because of increased discharges of sewage and surface water drainage. Although the existing Local Plan 2030 policies 33, 34 and 48 do provide a means of protecting the local water environment from increased volumes of wastewater generated from new development, the strategic assessment to ensure growth can be accommodated by wastewater infrastructure is insufficient.