106 responses from Mr David Sherratt, United Utilities Group Plc
1. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:20:00
A typed or handwritten document was submitted. This has been scanned and can be downloaded below:
Paragraph No.
2.29
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
[PLEASE NOTE THIS RESPONSE IS THE SUBJECT OF ON-GOING DISCUSSION WITH SLDC]
2. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:26:00
Policy/Site No.
LA1.3 Housing Allocations - R339# ALLITHWAITE LAND SOUTH OF GREEN LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
3. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:44:00
Policy/Site No.
LA1.3 Housing Allocations - R347# ALLITHWAITE LAND REAR OF BANKFIELD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
4. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:48:00
Policy/Site No.
LA1.3 Housing Allocations - RN224 RN86# RN195 ALLITHWAITE LAND REAR OF BARN HEY
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
5. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:50:00
Policy/Site No.
LA1.3 Housing Allocations - RN265# ALLITHWAITE LAND WEST OF BRACKEN EDGE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
6. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:52:00
Policy/Site No.
LA1.3 Housing Allocations - M32#-mod ALLITHWAITE LAND AT LANE ENDS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
7. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:54:00
Policy/Site No.
LA1.3 Housing Allocations - RN79#-mod ALLITHWAITE LAND NORTH OF JACK HILL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
8. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:57:00
Policy/Site No.
LA1.3 Housing Allocations - RN213-mod BRIGSTEER LAND OPPOSITE THE WHEATSHEAF
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
9. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 08:59:00
Policy/Site No.
LA1.8 Local Employment Allocations - MN19-mod BROUGHTON-in-FURNESS FOXFIELD ROAD,
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
10. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:00:00
Policy/Site No.
LA1.3 Housing Allocations - R163M-mod BROUGHTON-in-FURNESS FOXFIELD RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
11. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:02:00
Policy/Site No.
LA1.8 Local Employment Allocations - E32M BURNESIDE LAND ADJ CROPPERS PAPER MILL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
12. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:03:00
Policy/Site No.
LA1.3 Housing Allocations - R489M BURNESIDE LAND ADJ HALL PARK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
13. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:04:00
Policy/Site No.
LA1.3 Housing Allocations - M38M BURNESIDE LAND OPPOSITE HOLME HOUSES
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
14. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:07:00
Policy/Site No.
LA2.13 Mixed Use Allocation at Green Dragon Farm, Burton-in-Kendal
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
15. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:18:00
Policy/Site No.
LA1.3 Housing Allocations - R76M BURTON-in-KENDAL EAST OF HUTTON CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
16. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:20:00
Policy/Site No.
LA1.3 Housing Allocations - RN226 BURTON-in-KENDAL EAST OF BOON TOWN
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
17. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:24:00
Policy/Site No.
LA1.3 Housing Allocations - R112/ ON17 CARTMEL LAND AT HAGGS LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
18. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:46:00
Policy/Site No.
LA2.12 Mixed Use Allocation at Sandside Road, Arnside
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
19. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:48:00
Policy/Site No.
LA1.3 Housing Allocations - R81 ARNSIDE REDHILLS ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
20. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:50:00
Policy/Site No.
LA1.3 Housing Allocations - RN225-mod ARNSIDE HOLLINS LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
21. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:52:00
Policy/Site No.
LA1.3 Housing Allocations - RN337# ARNSIDE STATION RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
22. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:56:00
Policy/Site No.
LA1.3 Housing Allocations - RN14# CARTMEL STABLES, CARTMEL RACECOURSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
23. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 09:58:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN20, EN33# ENDMOOR LAND NORTH OF GATEBECK LANE, GATEBECK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
24. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:01:00
Policy/Site No.
LA1.3 Housing Allocations - R670-mod ENDMOOR SOUTH OF BOWLING GREEN
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
25. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:02:00
Policy/Site No.
LA1.3 Housing Allocations - M41M ENDMOOR NORTH OF SYCAMORE DRIVE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
26. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:04:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN42# CARK STATION YARD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
27. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:06:00
Policy/Site No.
LA1.3 Housing Allocations - R321M FLOOKBURGH LAND E OF WINDER LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
28. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:12:00
Policy/Site No.
LA1.3 Housing Allocations - R685 FLOOKBURGH EAST OF MANORSIDE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
29. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:14:00
Policy/Site No.
LA1.3 Housing Allocations - R687 FLOOKBURGH NORTH OF ALLITHWAITE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
30. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:16:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
31. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:18:00
Policy/Site No.
LA3.2 Mixed Use Allocation at Land South of Allithwaite Road, Kent's Bank, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
32. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:24:00
Policy/Site No.
LA1.3 Housing Allocations - R110 GRANGE-OVER-SANDS SOUTH OF THORNFIELD ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
33. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:30:00
Policy/Site No.
LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
34. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:34:00
Policy/Site No.
LA3.1 Mixed Use Allocation at Berners Pool, Grange-over-Sands
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
35. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:35:00
Policy/Site No.
LA1.3 Housing Allocations - R449/R74 GRANGE-OVER-SANDS OPPOSITE LITTLE FELL GATE FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
36. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:37:00
Policy/Site No.
LA1.3 Housing Allocations - R672M GRANGE-OVER-SANDS WEST OF CARDRONA ROAD
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
37. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:38:00
Policy/Site No.
LA1.3 Housing Allocations - R89 GRANGE-OVER-SANDS NORTH OF CARTER ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
38. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:48:00
Policy/Site No.
LA1.3 Housing Allocations - M10M & RN216M-mod LITTLE URSWICK MID TOWN FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
39. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:49:00
Policy/Site No.
LA5.5 Community Use Site, Church Road, between Great and Little Urswick
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
40. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:51:00
Policy/Site No.
LA1.3 Housing Allocations - RN152 GREENODD LAND AT THE OLD VICARAGE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
41. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:52:00
Policy/Site No.
LA1.8 Local Employment Allocations - M35M HOLME LAND AT MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
42. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:54:00
Policy/Site No.
LA1.3 Housing Allocations - R653M-mod HOLME EAST OF MILNTHORPE RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
43. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 10:56:00
Policy/Site No.
LA1.3 Housing Allocations - R675M-mod HOLME WEST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
44. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:00:00
Policy/Site No.
LA1.8 Local Employment Allocations - E18M HOLME LAND AT ELMSFIELD PARK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
45. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:02:00
Policy/Site No.
LA1.8 Local Employment Allocations - E31M KENDAL LAND SOUTH OF K SHOES, NATLAND ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
46. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:03:00
Policy/Site No.
LA1.8 Local Employment Allocations - E33 KENDAL LAND AT BOUNDARY BANK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
47. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:05:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E4M KENDAL LAND AT SCROGGS WOOD, MILNTHORPE ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
48. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:14:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN28M KENDAL LAND AT SHAP ROAD INDUSTRIAL ESTATE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
49. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:16:00
Policy/Site No.
LA1.8 Local Employment Allocations - E23K# KENDAL LAND NORTH OF MEADOWBANK BUSINESS PARK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
50. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:20:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M2M-mod KENDAL LAND EAST OF BURTON ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2/3
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
51. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:23:00
Policy/Site No.
LA1.3 Housing Allocations - M41KM KENDAL SOUTH OF LUMLEY ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
52. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:24:00
Policy/Site No.
LA1.3 Housing Allocations - MN27# KENDAL ESKDALE HOUSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
53. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:27:00
Policy/Site No.
LA1.3 Housing Allocations - R103M-mod KENDAL STAINBANK GREEN
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
54. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:28:00
Policy/Site No.
LA1.3 Housing Allocations - R107M mod and R150M KENDAL KENDAL PARKS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
55. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:30:00
Policy/Site No.
LA1.3 Housing Allocations - R121M-mod KENDAL EAST OF CASTLE GREEN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
56. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:32:00
Policy/Site No.
LA1.3 Housing Allocations - R129M KENDAL SOUTH OF UNDERBARROW ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
57. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:37:00
Policy/Site No.
LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
58. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:45:00
Policy/Site No.
LA1.3 Housing Allocations - R31# KENDAL LAND AT VICARAGE DRIVE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
59. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:48:00
Policy/Site No.
LA1.3 Housing Allocations - R44 KENDAL WEST OF HIGH GARTH
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
60. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:51:00
Policy/Site No.
LA1.3 Housing Allocations - R97 /MN34# KENDAL SOUTH OF NATLAND BECK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
61. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 11:53:00
Policy/Site No.
LA1.3 Housing Allocations - RN117M KENDAL WEST OF VALLEY DRIVE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
62. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 12:01:00
Policy/Site No.
LA1.3 Housing Allocations - RN133M KENDAL WEST OF OXENHOLME ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
63. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 12:04:00
Policy/Site No.
LA1.3 Housing Allocations - RN169M+ RN299# KENDAL WEST OF HIGH SPARROWMIRE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
64. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 12:05:00
Policy/Site No.
LA1.3 Housing Allocations - RN228# KENDAL ACRE MOSS LANE GARAGES
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
65. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 12:12:00
Policy/Site No.
LA1.4 Broad Locations for New Housing - APPLEBY ROAD, KENDAL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
66. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 12:13:00
Policy/Site No.
LA1.4 Broad Locations for New Housing - BURTON ROAD, KENDAL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
67. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 14:59:00
Policy/Site No.
LA1.3 Housing Allocations - R29M KIRKBY-in- FURNESS FOUR LANE ENDS
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
68. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 15:00:00
Policy/Site No.
LA1.3 Housing Allocations - RN11# KIRKBY-in- FURNESS LAND ADJACENT TO BURLINGTON C OF E SCHOOL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
69. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 15:02:00
Policy/Site No.
LA2.10 Mixed Use Allocation North of Kendal Road, Kirkby Lonsdale
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
70. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 15:04:00
Policy/Site No.
LA1.3 Housing Allocations - R640# KIRKBY LONSDALE LAND AT TRAM LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
71. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 15:06:00
Policy/Site No.
LA1.3 Housing Allocations - R642M KIRKBY LONSDALE ADJACENT TO BINFOLD COURT (100% Affordable)
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
72. Mr David Sherratt, United Utilities Group Plc : 30 May 2012 15:09:00
Policy/Site No.
LA1.3 Housing Allocations - R317M KIRKBY LONSDALE FORMER CEDAR HOUSE SCHOOL
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
73. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:13:00
Policy/Site No.
LA1.3 Housing Allocations - R51M LEVENS EAST OF GREENGATE CRESCENT
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
74. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:15:00
Policy/Site No.
LA1.3 Housing Allocations - RN121M-mod LEVENS FORMER POULTRY SHEDS, BRIGSTEER ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
75. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:17:00
Policy/Site No.
LA1.8 Local Employment Allocations - E13M MILNTHORPE LAND ADJ MAINLINE BUSINESS PARK
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
76. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:18:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN17-mod MILNTHORPE LAND and BUILDINGS ADJ DALLAM TIMBER YARD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
77. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:20:00
Policy/Site No.
LA1.8 Local Employment Allocations - M9M1-mod MILNTHORPE LAND ADJACENT TO BRIDGE END BUSINESS PARK, PARK ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
78. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:22:00
Policy/Site No.
LA1.3 Housing Allocations - M9M2-mod MILNTHORPE NORTH WEST OF MILNTHORPE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
79. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:23:00
Policy/Site No.
LA1.3 Housing Allocations - R151M-mod MILNTHORPE SOUTH OF MILNTHORPE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
80. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:25:00
Policy/Site No.
LA1.3 Housing Allocations - RN140 MILNTHORPE LAND AT OWLET ASH FIELDS, ACKENTHWAITE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
81. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:27:00
Policy/Site No.
LA1.3 Housing Allocations - RN57M MILNTHORPE ADJ. TO ST ANTHONY'S CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
82. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:28:00
Policy/Site No.
LA1.4 Broad Locations for New Housing - LAND ADJACENT TO FIRS ROAD, MILNTHORPE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
83. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:32:00
Policy/Site No.
LA1.3 Housing Allocations - R62 NATLAND WEST OF SEDGWICK RD, NATLAND
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
84. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:37:00
Policy/Site No.
LA1.3 Housing Allocations - R108M OXENHOLME LAND S OF FELL CLOSE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
85. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:39:00
Policy/Site No.
LA1.3 Housing Allocations - RN223 OXENHOLME LAND E OF BURTON RD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
86. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:41:00
Policy/Site No.
LA1.3 Housing Allocations - M683sM-mod STORTH LAND S OF QUARRY LANE, STORTH
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
87. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:44:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN40-mod SANDSIDE LAND SOUTH OF QUARRY LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 1
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
88. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:46:00
Policy/Site No.
LA1.3 Housing Allocations - RN109M RN315# SWARTHMOOR OFF CROSS-a-MOOR
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
89. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:51:00
Policy/Site No.
LA1.3 Housing Allocations - RN684 SWM SWARTHMOOR ADJACENT TO KINGSLEY AVENUE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
90. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:57:00
Policy/Site No.
LA1.6 Strategic Employment Sites - E30-M26 ULVERSTON LAND AT CANAL HEAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
91. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 08:59:00
Policy/Site No.
LA1.8 Local Employment Allocations - EN22ULVERSTON PHASE 1, LOW MILL TANNERY
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
92. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:01:00
Policy/Site No.
LA1.7 Business and Science Park Sites - M11M - Mod ULVERSTON LAND AT LIGHTBURN ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
93. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:06:00
Policy/Site No.
LA5.3 Mixed Use Allocation, Ulverston, Canal Head
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
94. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:09:00
Policy/Site No.
LA1.3 Housing Allocations - MN29 ULVERSTON WEST END NURSERY
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
95. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:12:00
Policy/Site No.
LA5.5 Community Use Site, Church Road, between Great and Little Urswick
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
96. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:14:00
Policy/Site No.
LA2.16 Community Use Site, Lowgate, Levens
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
97. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:15:00
Policy/Site No.
LA1.3 Housing Allocations - R268 ULVERSTON MORECAMBE ROAD SCRAPYARD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
98. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:17:00
Policy/Site No.
LA1.3 Housing Allocations - R270M ULVERSTON NORTH OF WATERY LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
99. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:26:00
Policy/Site No.
LA1.3 Housing Allocations - R274M, RN313 RN314 ULVERSTON SOUTH LUND FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
Yes
2.4 Use this space to explain your support for the South Lakeland District Council Land Allocations DPD.
Timescale - no change
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
100. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:29:00
Policy/Site No.
LA1.3 Housing Allocations - R689 ULVM ULVERSTON NORTH URSWICK ROAD
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
101. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:30:00
Policy/Site No.
LA1.3 Housing Allocations - MN29 ULVERSTON WEST END NURSERY
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
102. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:58:00
Policy/Site No.
LA1.3 Housing Allocations - RN250 ULVERSTON STONE CROSS MANSION
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
103. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 09:59:00
Policy/Site No.
LA1.3 Housing Allocations - RN3 ULVERSTON SOUTH OF STOCKBRIDGE LANE
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
104. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 10:00:00
Policy/Site No.
LA1.3 Housing Allocations - R690ulv, R691ULV, R126M, RN184, RN234# & part R242 ULVERSTON CROFTLANDS WEST - NOOK FARM
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
105. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 10:02:00
Policy/Site No.
LA1.3 Housing Allocations - R697 & part R242 ULVERSTON CROFTLANDS EAST
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
106. Mr David Sherratt, United Utilities Group Plc : 31 May 2012 10:03:00
Policy/Site No.
LA1.3 Housing Allocations - RN131M,RN141#, RN321# &RN284# Ulverston - Gascow Farm
2.1 Do you consider that the South Lakeland District Council Land Allocations DPD is sound?
No
2.2 If NO please identify which test of soundness your representation relates to by selecting the relevant option(s) below and completing section 2.3.
The DPD is not effective in that the document is not deliverable, flexible or capable of being monitored.
2.3 Please give details of the change(s) you consider necessary to make the South Lakeland District Council Land Allocations DPD sound, having regard to the test you have identified at question 2.2 above.
It would be helpful if you could state your proposed change to the DPD and the reasons why you think it is necessary.
Timescale - change to phase 2
Proposal: South Lakeland District Council- Land Allocations DPD
United Utilities PLC supports growth and sustainable development within the North
West.
United Utilities PLC would like to build a strong partnership with Local Planning
Authorities [LPA) to aid sustainable development and growth.
Our aim is to proactively share our information; assist in the development of sound
planning strategies, to identify future development needs and to secure the
necessary long-term infrastructure investment.
Water and wastewater services are vital for the future health and well-being of your
community and the protection of the environment. When developing your Local
Development Framework [LDF] and future policies LPA should consider the impacts
on the health and well-being its community, environment and ensure infrastructure
capacity is available. If infrastructure deficiencies cannot be addressed, an
alternative location and/or timescale should be sought where infrastructure capacity
is available and it meets the LPA development needs.
Inappropriate development could result in the closing of a hospital and/or school etc,
due to the inappropriate development siphoning off the historical water or
wastewater infrastructure capacity; no water supply for washing and catering
facilities and/or sewerage flooding of the property/highway.
United Utilities PLC would like to make the follow specific comments, to be included
in further consultations and if possible, the development of South Lakeland District
Council's [Council] future sustained economic growth plans and polices.
Specific comments
The phasing of development must be based on strong proactive planning processes
that not only identify the needs but the constraints associated with the delivery of
supporting infrastructure; in particularly the provision of water and wastewater
services where a long lead-in-time may be required; the phasing/timescales of
development must therefore reflect these limitations.
Failure to achieve these goals would result in an unsound Land Allocation DPD.
The Council should.consider the constraints [are not limited to, but include] that are
outside the control of United Utilities PLC:
• Regulatory approval
• Environmental constraints
Does the receiving watercourse/environment have the capacity to accept
additional flows without causing environmental damage?
Small river : large development
• Environmental consents and permits
Construction of new processes required to meet new consents and/or permits
• Planning approval
The Land Allocation process has not highlighted and/or specified land for
infrastructure use, therefore future planning applications from utilities
infrastructure may be thwarted or prolonged processes.
o Historical local resistance to the expansion of utilities assets
o Planning application approval restrictions delay implementation of supporting
infrastructure .assets
• Land acquisition
• Access into the highway
Limitations from the highway departments for road works
• Environmental restrictions
bird breeding and/or nesting seasons; great crested newts; badgers etc
• Implementation and commissioning restrictions from planning application;
environmental consents and permits conditions
The Council's Land Allocation DPD and planning policy process needs to identify and
safeguard land for infrastructure use; failure to do so could mean United Utilities PLC
cannot provide the additional capacity required to support your growth plans
therefore an unsound Land Allocation plan.
The Land Allocation and future planning policies must ensure development does not
have a detrimental affect on the existing capacity of the community's supporting
infrastructure; development should not be deemed sustainable and/or sound if it
results in a reduced quality of life and/or risk of environmental damage.
Proactively planning can provide a sustainable cross boundary solution that addresses
the needs of a number of LPA/communities, instead of a reactive solution for a single
development.
When reactive infrastructure investment is used, it is generally a short-term fix to
address a service failure and/or risk of envirohment; the planning process has failed
and the community is already experiencing a reduced quality of life and/or the
environment is damaged.
Reactive short-term investment solution will become abortive when the long-term
sustainable solution is implemented; resulting in an unnecessary increased carbon
footprint; higher customer bills, leading to an increase in deprivation and reduced
quality of life and health for the community.
The Councils' phasing process does not fully align to with United Utilities PLC's Asset
Management Plan [AMP - five yearly capital investment programme approval by
water and wastewater companies financial regulator, the Office of Water Services
(Ofwat); in addition no projects to accommodate additional capacity have been
identified and/or approval for the current AMP period 2010 - 2015 [known as AMPS]
United Utilities PLC propose the following phasing changes to Policy LA1.3: Housing
Allocations and the Land Allocations DPD
Phase 2/3 is the latter stage of phase 2 early stage of phase 3.
The above comments must be read in conjunction with the following remarks and
United Utilities PLC would like these to be taken into consideration and incorporated
into your future policies and/or documents:
General notes:
National Planning Policy Framework [NPPF]
The presumption in favour of sustainable development
LPA should adopt proactive strategy priorities in their Local Plan. This should include
strategic policies to deliver:
• the provision of infrastructure for transport, telecommunications, waste
management, water supply, wastewater, flood risk and coastal change
management, and the provision of minerals and energy (including heat);
• the provision of health, security, community and cultural infrastructure and other
local facilities; and
• climate change mitigation and adaptation, conservation and enhancement of the
natural and historic environment, including landscape.
Crucially, Local Plans should:
• plan positively for the development and infrastructure required in the area to
meet the objectives, principles and policies of the NPPF;
• be drawn up over an appropriate time scale, preferably a 15-year time horizon,
take account of longer term requirements, and be kept up to date;
• be based on co-operation with neighbouring authorities, public, voluntary and
private sector organisations;
• indicate broad locations for strategic development on a key diagram and land-use
designations on a proposals map;
• allocate sites to promote development and flexible use of land, bringing forward
new land where necessary, and provide detail on form, scale, access and
quantum of development where appropriate;
• identify areas where it may be necessary to limit freedom to change the uses of
buildings, and support such restrictions with a clear explanation;
• identify land where development would be inappropriate, for instance because of
its environmental or historic significance; and
• contain a clear strategy for enhancing the natural, built and historic environment,
and supporting Nature Improvement Areas where they have been identified.
Infrastructure
NPPF 162. Local planning authorities should work with other authorities and
providers to:
• assess the quality and capacity of infrastructure for transport, water supply,
wastewater and its treatment, energy (including heat), telecommunications,
utilities, waste, health, social care, education, flood risk and coastal change
management, and its ability to meet forecast demands; and
• take account of the need for strategic infrastructure including nationally
significant infrastructure within their areas.
To ensure that future development is sustainable; prevents environmental damage
and preserves the quality of life for the existing and future generations,
developments should not be permitted until infrastructure capacity is available.
United Utilities PLC cannot confirm if capacity is available until the connection
point/s, flows and completion dates are available.
If additional supporting infrastructure is required then the LPA should work closely
with United Utilities PLC [and other utility providers] to ensure a sustainable crossboundary
solution is identified and approved by the appropriate Regulators bodies
before granting planning approval; failure may result in the deterioration of the
community's quality of life and/or environmental damage.
The scale and type of development needs to be defined so the appropriate
infrastructure is in place to ensure growth is sustainable.
United Utilities PLC has a number of recent examples where infrastructure has been
provided based on identified growth, but not delivered; this has resulted in major
operational issues; the treatment process is under loaded; it is failing to operate
because it cannot reach its operational capacity.
Additional temporary engineer solutions are in place; this represents a significant
risk to the exiting customers; the environment and United Utilities PLC; not
forgetting the additional financial burden on United Utilities PLC's customers.
The Council has a number of capacity issues; any additional developments in these
and/or adjoining areas without firstly ensuring infrastructure solutions are
implemented could result in an increased number and frequency of sewer flooding
incidents.
[Reason: Ensure timely delivery of development and infrastructure to protect the
good quality of life and the environment]
Surface Water
Site drainage should be a major consideration for LPA and developers when selecting
possible development sites; ground conditions; local flooding issues; development
layout; design and planning policy.
The treatment and processing of surface water [storm water; rainwater] is a not a
sustainable solution; the sites' current natural discharge solution should be continued
and/or mimicked; if the existing surface water does not have an existing natural
solution, United Utilities PLC questions the development of a flooded site.
Surfacewater should be managed at source and not transferred; if not this will only
transfer the issue to another location; generally to a single pinch point, generating
further problems in that location.
Developments must drain on a separate sewerage system, with only foul drainage
connected into the foul sewerage network.
Every option should be investigate before discharging surface water into a public
sewerage network.
Connecting surface water to the public sewerage network is not a sustainable
solution and LPA should discourage this practice.
The priority options for the management of surface water discharges are:
• Continue and/or mimic the site's current natural discharge process
• Store for later use
• Discharge into infiltration systems located in porous sub soils
• Attenuate flows into green engineering solutions such as ponds; swales or other
open water features for gradual release to a watercourse and/or porous sub soils
• Attenuate by storing in tanks or sealed systems for gradual release to a
watercourse
• Direct discharge to a watercourse
• Direct discharge to a surface water sewer
• Controlled discharge into the combined sewerage network~ this option is a last
resort when all other options have been discounted.
Development on greenfield sites shall not discharge surface water into the public
combined sewerage network and shall not increase the rate of run-off into the public
surface water network ~ this statement does not replace the priority options for
surface water management above.
On previously developed land, a reduction of at least 30% will be sought, rising to a
minimum of 50% in critical drainage areas ~ this statement does not replace the
priority options for surface water management above
Any discharge to the public sewerage system must be via approved SuDS and will
require an approved discharge rate.
Consideration should given for green infrastructure, low carbon, soft engineering
SuDS solutions, such as ponds; swales; wet land areas and detention basins etc.
http://www.ciria.com/suds/index.html
A discharge to groundwater or watercourse may require the consent of the
Environment Agency.
[Reason: To ensure that the surface water is properly discharged to prevent flooding
or the overloading of the public sewerage network]
Green Infrastructure
The Council should seek opportunities to use developer financial and/or resources
contributions to meet common objectives.
Use green and open spaces, sports and recreation facilities to address surfacewater
and climate change issues.
Building green infrastructure assets such as ponds, swales and wetlands will not only
meet the Council's Green Space needs but also their local existing and/or future
surface water/ climate change issues.
Artificial pitches; cycle paths; play areas mutli-use games areas and skate parks can
be used to local underground civil engineering SuDS solutions.
SuDS solutions that incorporate irrigation systems will help support and maintain the
Council's allotments, parks and garden areas.
The Council's should identify opportunities for the installation retrofitting SuDS.
[Reason: To ensure that the development is sustainable, properly drained; prevents
flooding and environmental damage]
Climate change adaptation
Climate change is a major consideration on the future available capacity of sewerage
networks; wastewater treatment works and watercourses.
Planners and Developers should consider that the impacts of climate change on
future development, existing infrastructures, and the environment.
Developments to be designed to reduce the impacts of climatic change on the
development itself, the existing infrastructure and the environment; with
consideration for hotter, drier summers, greater flood risk and more severe weather
events.
To reduce the impacts of climate change on the existing infrastructure LPA should
seek a significant reduction in the discharge from developments.
Urban creep has a significant impact on capacity; the paving over of gardens
contributes to flood risk and should therefore be discouraged.
[Reason: To ensure that the development is properly drained; prevents flooding and
environmental damage]
Water Resources Planning
On 12 March 2012, seven water companies [Anglian Water, South East Water,
Southern Water, Sutton and East Surrey Water, Thames Water, Veolia Water
Southeast and Veolia Water Central] announced they are consulting on temporary
restrictions to be in place by 5 April 2012.
The number of drought measures highlights the need to manage water resources
effectively, given increasing pressure on water supply because of population
increase, changing household usage patterns and by climate change.
All this despite the UK having a reputation as being a rainy country, we may face a
future with less rainfall and less certainty about when that rain will fall.
United Utilities PLC's Water Resources Management Plan published in 2009, sets out
our strategy for water resources management for the next twenty-five years and
highlights areas where there is likely to be a supply deficit and what activities will be
put in place to mitigate any shortfall in supply.
The plan can be accessed here:
http://www. united uti I ities. com/WaterResou rcesPia n. aspx
United Utilities PLC would encourage all developers and planners to contact United
Utilities PLC at the earliest opportunity to enable identification of points of connection
with least cost to the developer.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Increased Water Capacity
The developer is required to pay for their increased capacity (up to the point of a
treatment works) and they are only allowed to connect at specific points identified by
United Utilities PLC and following approval to connect.
Planners and Developer should obtain local capacity information from the United
Utilities PLC Area Teams\Connections who would be able to identify areas where
there is current capacity for development; this would be on a case by case basis and
developers are required to pay a fee for this service (a pre development enquiry).
[Reason: To maintain the public water supply and to provide satisfactory /sustainable
development]
General Water Efficiency Guidance
United Utilities encourages the use of water efficient designs and development
wherever this is possible. There are a number of actions developers can undertake to
ensure that their developments are water efficient. The most up to date advice for
water efficiency and water efficiency products can be found at Waterwise who have
recently published a best practise guide on water efficiency for new developments.
United Utilities PLC would encourage utilisation of the following water efficiency
activities:
• Installing of the latest water efficient products, such as a 4.51 flush toilet instead
of the 61 type.
• Minimise run lengths of hot and cold water pipes from storage to tap/shower
areas. This minimises the amount of waste during the time the water goes from
cold to hot.
• Utilising drought resistant varieties of trees, plants and grasses when
landscaping.
• Install water efficient appliances such as dishwashers, washing machines.
[Reason: To maintain the public water supply and to provide satisfactory/sustainable
development]
Responding Strategic Housing Land Availability Assessment [SHLAA]
Responding to an individual site identified in a SHLAA will not give a true reflection
on impact on the existing infrastructure or provide a clear investment plan for the
future.
A single plot will not be constructed, a number of plots will and therefore numerous
build scenarios can be created from the list of sites identified in a SHLAA.
What if:
Plots A, B, C and Z are constructed
Or
Plots B; C; D; Y and Z are constructed.
United Utilities PLC can not provide a true impact assessment on the development
plots identified in your SHLAA, United Utilities PLC would prefer to meet a member of
your team to discuss this in further detail.
[Reason: To ensure that no foul or surface water discharges take place until proper
provision has been made for their disposal and to provide satisfactory/sustainable
development]
Development adjacent to infrastructure assets
The future expansion of infrastructure assets to meet the needs of future
development and changes in legalisation could create a potential conflict with
development plans, this may result in £Millions of customers money being spent in
building a new infrastructure outside the locality; therefore developments adjacent to
United Utilities PLC assets should be discouraged by LPA
Water and sewerage companies have a legal right of access to their assets; this can
be for their operational and/or maintenance therefore United Utilities PLC will not
permit the building over and/or near its infrastructure assets.
By their nature, wastewater processes generate odour levels, which the public may
deem to be unacceptable; in addition, the filter processes attract flies.
To avoid any conflict historically these facilities have been sited away from the
general population. •
To protect the public from these by-products United Utilities PLC would ask that the
Environmental Health Authority be consulted in any future developments adjacent to
wastewater infrastructure assets. In most cases, the distance of 400 metres from the
WWTW is used as a guide, but this can differ due to local topography, climatic
conditions, size and nature of the wastewater infrastructure asset and development
in question.
The Council must ensure United Utilities PLC is kept informed of any waste
management related development and/or planning application within SOOm of a
Large Diameter Trunk Main (LDTM). Prior consent will be required from United
Utilities PLC before granting approval. It is also essential that this information is
included in future planning policy
United Utilities PLC would seek the support of LPA in the LDF and planning
application processes to protect/secure land for infrastructure use. Failure could
mean United Utilities PLC cannot provide the additional capacity required to support
your growth plans therefore a failed and/or unsound development plan.
[Reason: To protect existing and future infrastructure and maintain service]
Infillland
You should be aware that, on occasion, gaps are left between properties; this is due
to the presence of underground utility assets. United Utilities PLC will not allow the
building over or near to these assets and development will not be acceptable in these
locations.
[Reason: In order to allow sufficient access for maintenance and repair work at all
times]
Carbon impact
LPA and developers should consider to the total carbon impact of future
developments; not only the footprint of the development but also the carbon impact
for additional infrastructure assets; their associated treatment processes and their
future maintenance and operation requirements. To meet future reduction targets
LPA and Developers should considered the wider carbon impact when determining
the location of future developments.
[Reason: Satisfactory and sustainable development]
Windfall Sites
Windfall sites siphon investment and resources away from defined development
plans; sabotaging infrastructure investment identified to address specific water and
wastewater infrastructure needs.
For LPA this could greatly impact their development plans to address areas of
deprivation; poor housing; high unemployment; education and health care issues.
A single development site [windfall] must not impair and/or sabotage the time;
resources; infrastructure investment and partnerships developed to support the
future growth of a LPA and/or number of LPAs.
[Reason: Protect investment, well being of the community and deliver sustainable
development]
LIABILITY
United Utilities PLC does not promise that the data will provide any particular
facilities or functions. You must ensure that the data meet your needs. You are
entirely responsible for the consequences of any use of the data, United Utilities PLC
give you no warranty about the fitness for purpose or performance of any part of the
data.
If an electronic format has been used, United Utilities PLC do not promise that the
media on which the data are provided will always be free from defects, computer
viruses, software locks or other similar code or that the operation of the data will be
uninterrupted or error-free. You should carry out all necessary virus checks prior to
loading the data on to your computer system.
United Utilities PLC does not guarantee that the data will always be accurate, correct,
complete, up to date or valid. United Utilities PLC gives you no warranty about the
condition or satisfactory quality of any part of the Data.
United Utilities PLC is only able to undertake to use reasonable endeavours to ensure
that United Utilities PLC is providing you with an accurate a copy from our records.
United Utilities PLC are not in any circumstances (including if United Utilities PLC
have been negligent) liable for any damage to property, loss of business capital,
earnings, profit, reputation, goodwill or enjoyment or any other indirect or
consequential loss or damage at all arising out of or in connection with this
Agreement or its subject matter.
\
You accept that United Utilities PLC shall not be under any liability to you of any kind,
which arising directly or indirectly, for any conditions, warranties, undertakings or
representations of any kind, express or implied, statutory or otherwise, relating to
the data.
