Issues and Options

Water Resources Bedford lies within the area traditionally sourced by Anglian Water. The Local Plan needs to address the timings of the projected growth with the availability of potable water supply and any necessary improvements to infrastructure. Anglian Water has published (November 2019) a revised draft water resources management plan (WRMP), which sets out how the company will maintain customer supplies over the period 2020- 2045. The plan can be viewed here: https://www.anglianwater.co.uk/about-us/our-strategies-and-plans/draft-water-resources-management-plan/ The company’s assessment is that it will have sufficient supplies to meet this growth but will need to develop a strategic grid to achieve this. This will involve transferring water from Lincolnshire to areas where deficits in supply are predicted. They also seek to reduce individual customer demands and reduce leakage. We recommend that your Authority considers the long term viability of supplying any new development and how the phasing of growth links to the timings of this planned new strategic scheme. The Anglian River Basin Management Plan https://www.gov.uk/government/publications/anglian-river-basin-district-river-basin-management-plan considered the status of all rivers and aquifers in the Region and looked at what it would take to ensure they met good ecological status and reverse the over abstraction related to historical licensing of water. The measures required to make these improvements were subject to a cost benefit test. The assessment of the measures needed to get the entire aquifer and river system back to supporting good ecological status were deemed to be disproportionately expensive. The plan did approve some measures to improve the status of the rivers that were failing to meet their ecological flow needs where it was cost beneficial. Given the pressure the Chalk aquifer faces, we cannot rule out future further reductions in the supplies available to Anglian Water to prevent deterioration of the water related ecology. At this point, we are not planning on any further reductions before 2025, but there is a high likelihood that further reductions could be required after this period. Any resultant loss in available supplies would need to be addressed in the company’s next WRMP (2024). The Sustainability Assessment Scoping report (July 2020) states in section 10.26 that ‘ Water companies are expected to be able to maintain adequate water supply and wastewater management over the plan period. The requirements of the Water Framework Directive are likely to lead to continued improvements to water quality within the area’. As noted above water companies are only expected to meet increased demands from development by the means of new strategic schemes and the timings of these schemes will be crucial in the phasing of growth. It is important that the Sustainability Assessment evaluates the need to prevent deterioration in Water Framework Directive targets which will prevent water companies from using headroom to increase supply to new developments. Considering that current levels of abstraction are causing environmental damage, we recommend that that the Local Plan considers water resources as a key issue and your Authority recognises the damage of long term increases in abstraction due to growth. We also recommend any new development takes into account the combined effect of growth across the region, including in neighbouring authorities, and therefore the overall increase in demand for water. We note that the last water cycle study was published in 2012 for this area (Bedford & Central Beds Water Cycle Study, Halcrow). Are there any plans to commission a new study or to take into account new information and obligations? Additional Comments on Adopted Local Plan: Policy 51S - Climate change Para 9.19 states that ‘Development will be expected to address both adaptation and mitigation through water and energy efficiency, appropriate layout, design and landscaping, and the use of renewable energy’. We welcome this, but could more detail be added along the lines of ‘New homes and development need to be future proofed in terms of their resource use and efficiency, location, design, construction, orientation and access to nature, for instance ensuring roofs are sufficiently strengthened to allow the future installation of solar panels and green roofs. Proximity to trees, other vegetation, ponds and lakes which provide natural cooling and improve local air quality is also important’ ? Policy 52 - Water demand We welcome the current policy for new development to achieve the higher water efficiency standard. The current wording is ‘Unless it can be demonstrated that it would make the development unviable, new residential development will be required to achieve the higher water efficiency standard in the Building Regulations’. The joint AWS/EA/NE water efficiency position statement points out that although ‘the Local Planning Authority should consider viability taking account of local circumstances and policy requirements, research has shown that the cost of the optional higher water efficiency standard and associated cost can be as low as £6-94 per dwelling. We therefore consider that this does not make Local Plans, or individual development proposals, unviable’. would you consider removing the reference to viability? Call for Sites We would appreciate being consulted on proposed new sites, once you have undertaken the sequential test. In addition to the above comments, we still support the comments and recommendations we previously made under the Adopted Local Plan.