Water Cycle Study

Showing comments and forms 1 to 8 of 8

Object

Technical Reports

Representation ID: 2018

Received: 25/08/2017

Respondent: Dave Rowell

Representation:

The limit for potton sewage works is listed as 1960 dwellings plus a headroom for an additional 80 but your figures state that potton has 2250 dwellings in 2015 and there are a further 300+ constructed, being constructed or approved.

Given the historical and current problems that the potton sewage works has I suggest that all building work is suspended until this capacity issue is addressed.

Full text:

The limit for potton sewage works is listed as 1960 dwellings plus a headroom for an additional 80 but your figures state that potton has 2250 dwellings in 2015 and there are a further 300+ constructed, being constructed or approved.

Given the historical and current problems that the potton sewage works has I suggest that all building work is suspended until this capacity issue is addressed.

Object

Technical Reports

Representation ID: 2128

Received: 25/08/2017

Respondent: Sue Rowell

Representation:

Objections to the conclusions in this report and concerns as to methodology used.

Full text:

This study highlights a number of deeply concerning consequences of the excessive housing growth figures outlined in the main plan. In order to fulfil their statutory duty to provide water supplies, the water companies will need to revise their plans and invest in upgrades to various infrastructure elements or plan for major new infrastructure over the next 20 years. These plans for investment have to be approved by OFFWAT as these plans will inevitable result in rises in water bills for ALL residents of Bedfordshire. I do not see this as fair or necessary. Therefore the timing of building any of the sites proposed needs to be fully explained with this limitation in mind.
There are also many assumptions made about the feasibility of providing this additional water supply when the Environment Agency states quite clearly we are in an area of severe water stress already. They are seeking to restrict abstraction licences wherever possible with this problem in mind. And this does not take into account climate change over the next 20 year period which will exacerbate the situation. The study does not address this fully or at all in section 9.2.
The water companies also state they are unable to comment on any issues and problems arising until they have more site specific data to work with and they can then assess cumulative impacts across the catchment area. This report states this will be developed for a stage 2 report, presumably released in Spring 2018 with the next version of the main Local Plan. I suggest that the water companies will get early and advance notice of specific sites being taken forward before the public and very soon too in order to give them time to work out their response. How is this democratic? It further suggests that CBC already know which sites they plan to take forward regardless of this consultation process.

The impact of housing growth on waste water treatment capacities and consequent environmental impacts on water quality is based on flawed data as the numbers used for households is considerably out of date. For example Potton has already over 2200 dwellings thus far exceeding the apparent additional 80 that would lead to a deterioration in water quality (table 10.1). I am aware that there is already concern from the ongoing monitoring of the receiving water course as to Ammonia levels exceeding permitted amounts downstream of this sewage works. In addition the methodology for working out any capacity for growth is not clearly explained and therefore is not transparent and is unverifiable. Some of the growth areas proposed would only be able to discharge to groundwater and it is by no means certain that this would be permitted by the Environment Agency.
I have serious concerns regarding the ability of planners to enforce water saving measures be implemented in house designs and surface waters dealt with to prevent flooding. Recent studies have shown many problems in implementing effective SUDS; that they are well designed, then actually built and properly maintained. Particularly once developers are off site and the maintenance falls to the home owners or a management company. Again climate change models suggest periods of intense rainfall will make dealing with surface water even more important in the future.
The whole emphasis of this report is based on accommodating housing growth with very little evidence of forward thinking to improve and enhance our rivers and wetlands for the future for current residents and wildlife.

Object

Technical Reports

Representation ID: 2332

Received: 26/08/2017

Respondent: Mr Darren Brooker

Representation:

The Environment Agency has classified the Central Bedfordshire area as an area already under serious water stress. Planning further, significant growth in this area would irresponsible. In addition, building on green field sites which sustain the aquifers underneath Central Bedfordshire, from where most of our drinking water comes, would be reckless and irresponsible.

Full text:

The Environment Agency has classified the Central Bedfordshire area as an area already under serious water stress. Planning further, significant growth in this area would irresponsible. In addition, building on green field sites which sustain the aquifers underneath Central Bedfordshire, from where most of our drinking water comes, would be reckless and irresponsible.

Comment

Technical Reports

Representation ID: 3776

Received: 29/08/2017

Respondent: Anglian Water Services Ltd

Representation:

The Council's Water Cycle Study (WCS) is an initial assessment which is expected to be followed by a more detailed water cycle study (phase 2).

The current consultation identifies a number of locations as a potential focus for development - we would wish to comment further on the available site options in the context of detailed WCS which has yet to be prepared. (Please see comments relating to Local Plan Spatial Strategy).

Full text:

The Council's Water Cycle Study (WCS) is an initial assessment which is expected to be followed by a more detailed water cycle study (phase 2).

The current consultation identifies a number of locations as a potential focus for development - we would wish to comment further on the available site options in the context of detailed WCS which has yet to be prepared. (Please see comments relating to Local Plan Spatial Strategy).

Comment

Technical Reports

Representation ID: 3887

Received: 29/08/2017

Respondent: J Price Williams

Representation:

The Water Cycle Study (April 2017) has identified that the Water and Waste Water infrastructure is currently under stress. Improvements to the infrastructure will only be in place towards the end of the Local Plan Period thus large development of any sort prior to this will exacerbate the stress with potential negative outcomes. Surely any improvements must be made prior to major development to reduce or eliminate the stress on the infrastructure.

Full text:

The Water Cycle Study (April 2017) has identified that the Water and Waste Water infrastructure is currently under stress. Improvements to the infrastructure will only be in place towards the end of the Local Plan Period thus large development of any sort prior to this will exacerbate the stress with potential negative outcomes. Surely any improvements must be made prior to major development to reduce or eliminate the stress on the infrastructure.

Object

Technical Reports

Representation ID: 5062

Received: 25/08/2017

Respondent: Sue Rowell

Representation:

Water Cycle Study

water companies will need to revise their plans and invest in upgrades to various infrastructure elements or plan for new major projects,
EA state we are in an area of severe water stress,
Study does not address this issue in section 9.2,
impact on housing growth on waste water treatment capacities,
Climate Change impacts

Full text:

This study highlights a number of deeply concerning consequences of the excessive housing growth figures outlined in the main plan. In order to fulfil their statutory duty to provide water supplies, the water companies will need to revise their plans and invest in upgrades to various infrastructure elements or plan for major new infrastructure over the next 20 years. These plans for investment have to be approved by OFFWAT as these plans will inevitable result in rises in water bills for ALL residents of Bedfordshire. I do not see this as fair or necessary. Therefore the timing of building any of the sites proposed needs to be fully explained with this limitation in mind.
There are also many assumptions made about the feasibility of providing this additional water supply when the Environment Agency states quite clearly we are in an area of severe water stress already. They are seeking to restrict abstraction licences wherever possible with this problem in mind. And this does not take into account climate change over the next 20 year period which will exacerbate the situation. The study does not address this fully or at all in section 9.2.
The water companies also state they are unable to comment on any issues and problems arising until they have more site specific data to work with and they can then assess cumulative impacts across the catchment area. This report states this will be developed for a stage 2 report, presumably released in Spring 2018 with the next version of the main Local Plan. I suggest that the water companies will get early and advance notice of specific sites being taken forward before the public and very soon too in order to give them time to work out their response. How is this democratic? It further suggests that CBC already know which sites they plan to take forward regardless of this consultation process.

The impact of housing growth on waste water treatment capacities and consequent environmental impacts on water quality is based on flawed data as the numbers used for households is considerably out of date. For example Potton has already over 2200 dwellings thus far exceeding the apparent additional 80 that would lead to a deterioration in water quality (table 10.1). I am aware that there is already concern from the ongoing monitoring of the receiving water course as to Ammonia levels exceeding permitted amounts downstream of this sewage works. In addition the methodology for working out any capacity for growth is not clearly explained and therefore is not transparent and is unverifiable. Some of the growth areas proposed would only be able to discharge to groundwater and it is by no means certain that this would be permitted by the Environment Agency.
I have serious concerns regarding the ability of planners to enforce water saving measures be implemented in house designs and surface waters dealt with to prevent flooding. Recent studies have shown many problems in implementing effective SUDS; that they are well designed, then actually built and properly maintained. Particularly once developers are off site and the maintenance falls to the home owners or a management company. Again climate change models suggest periods of intense rainfall will make dealing with surface water even more important in the future.
The whole emphasis of this report is based on accommodating housing growth with very little evidence of forward thinking to improve and enhance our rivers and wetlands for the future for current residents and wildlife.

Comment

Technical Reports

Representation ID: 6374

Received: 29/08/2017

Respondent: Environment Agency

Representation:

We are surprised to see this final version of the WCS on the web portal. Several months ago we made some significant comments and actions required on the first draft that we were consulted on. In our opinion that document was not fit for purpose as it was impossible to ascertain how the assessments had been carried out and therefore how the conclusions had been drawn. To our knowledge there has been no further consultation. Some of our comments have been taken on board, and it is clear that there have been some substantial changes, .... see attachment

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Comment

Technical Reports

Representation ID: 6556

Received: 25/08/2017

Respondent: CPRE

Representation:

We note that the Environment Agency has classified the Anglian Water and Affinity Water supply regions, which includes Central Bedfordshire, as already in "serious water stress".
Planning for this level of housing growth in an area of severe drinking water supply issues is in our view, the height of irresponsibility.

We note in section 6.6.4 Conclusions (regarding wastewater discharges):
see attachment

Full text:

see attachment

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