Response from Ms Jenny Hope, United Utilities Limited
1. Ms Jenny Hope, United Utilities Limited : 20 Dec 2017 11:21:00
Policy Reference
AS15 - Housing Allocations
1.3 Do you consider the AONB DPD to be sound?
No
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Thank you for seeking the views of United Utilities as part of the Development Plan Document preparation.
In accordance with national planning policy (specifically paragraph 162 of the National Planning Policy Framework and its predecessor PPS12), as well as the status of United Utilities Water Limited as a statutory consultee in the preparation of Development Plan Documents, we would like to continue engagement with South Lakeland District Council throughout the preparation of your planning documents.
United Utilities Water Limited is the statutory water and wastewater undertaker for the North West of England. This includes working with Planning Authorities on the creation of appropriate planning policies and developers on detailed proposals to most appropriately manage the impact on infrastructure.
In the full spirit of the plan-making process and in accordance with paragraph 162 of the NPPF, United Utilities remains engaged in meaningful discussions with South Lakeland District Council regarding their aspirations for future development.
United Utilities wishes to build a strong partnership with all Planning Authorities to aid sustainable development and growth within its area of operation.
We aim to proactively identify future development needs and share our information. This helps:
- ensure a strong connection between development and infrastructure planning;
- deliver sound planning strategies; and
- inform our future infrastructure investment submissions for determination by our regulator.
When preparing the Development Plan and future policies, we can most appropriately manage the impact of development on our infrastructure if development is identified in locations where infrastructure is available with existing capacity. It may be necessary to co-ordinate the delivery of development with the delivery of infrastructure in some circumstances.
SPECIFIC COMMENTS
We wish to highlight to the Council and any other interested parties, the following information which should be taken into consideration and included in the final version of the document.
Draft Policy AS15 – Housing Allocations
We wish to reiterate our comments that were submitted previously (United Utilities’ representations to the Draft Plan Consultation Document – Arnside & Silverdale AONB, letter dated 2nd February 2017).
We do have significant concerns about the deliverability of some of the sites, which we wish to discuss further with the Council in more detail as soon as possible. Without repeating in full our previous comments, the two sites which appear to be most constrained by our assets and may result in development not be deliverable comprise:
AS17 (A6) Land off Queen’s Drive, Arnside; and
AS25 (B35/ B38/ B81/ B125) Land on Sandside Road and Quarry Lane
United Utilities requests that each of the ‘Site Mini-Briefs’ should include a summary of relevant constraints as a means to ensure potential developers are aware of their possible impact at an early stage, particularly in advance of any negotiations involving land values.
We also advise any interested parties to contact United Utilities Developer Services (WastewaterDeveloperServices@uuplc.co.uk) to discuss the site allocations in more detail to understand how we can provide water and wastewater services. United Utilities offers a free pre-application enquiry service.
Summary
Moving forward, we respectfully request that South Lakeland District Council continues to consult with United Utilities during the ongoing preparation of all their planning policies and documents. We are keen to continue working in partnership with the Council to ensure that all new growth can be delivered sustainably, and with the necessary infrastructure available, in line with delivery targets.
1.6 Please set out what modification(s) you consider necessary to resolve your objection and make the DPD legally compliant or sound, having regard to the matter(s) you have identified above. (Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination). You will need to say why this modification will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.
United Utilities requests that each of the ‘Site Mini-Briefs’ should include a summary of relevant constraints as a means to ensure potential developers are aware of their possible impact at an early stage, particularly in advance of any negotiations involving land values.
We also advise any interested parties to contact United Utilities Developer Services (WastewaterDeveloperServices@uuplc.co.uk) to discuss the site allocations in more detail to understand how we can provide water and wastewater services. United Utilities offers a free pre-application enquiry service.
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