3 responses from Ms Jenny Hope, United Utilities Limited
1. Ms Jenny Hope, United Utilities Limited : 20 Dec 2017 11:40:00
Policy Reference
DM6 - Flood Risk Management and Sustainable Drainage Systems
1.3 Do you consider the DM 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 Local Plan 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 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.
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 on any policy or text. Please be as precise as possible.
Draft Policy DM6 –Flood Risk Management and Sustainable Drainage Systems
We request the inclusion of the following additional text within the draft policy:
On previously developed land, applicants should target a reduction of surface water discharge in accordance with the non-statutory technical standards for sustainable drainage produced by DEFRA. In demonstrating a reduction, applicants should include clear evidence of existing positive connections from the site with associated calculations on rates of discharge.
Whilst we note the inclusion of paragraph 2.6.3 relating to wider drainage strategies for larger development sites within the text, our preference would be for this to be included as part of the draft Policy wording.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
2. Ms Jenny Hope, United Utilities Limited : 20 Dec 2017 11:43:00
Paragraph No.
2.6.4
1.3 Do you consider the DM 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 Local Plan 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 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.
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 on any policy or text. Please be as precise as possible.
Also within the accompanying text, we suggest the following additional text, possibly included as part of paragraph 2.6.4:
When preparing the detailed layout for new development sites, the applicant should consider whether they wish to offer the site for adoption by the public sewerage undertaker. The detailed layout should be prepared with consideration of what is necessary to secure a development to an adoptable standard. This is important as drainage design can be a key determining factor of site levels and layout. When discharging to a watercourse, the detail of the design of a development should ensure that it is possible to achieve a discharge to watercourse having regard to the level of the outfall necessary to meet the requirements of the Lead Local Flood Authority, the Environment Agency and the public sewerage undertaker.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
3. Ms Jenny Hope, United Utilities Limited : 20 Dec 2017 11:45:00
Policy Reference
DM7 - Addressing Pollution, Contamination Impact, and Water Quality
1.3 Do you consider the DM 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 Local Plan 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 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.
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 on any policy or text. Please be as precise as possible.
Draft Policy DM7 – Addressing Pollution, Contamination Impact, and Water Quality
United Utilities’ strong preference is for development to take place outside of any Environment Agency designated Groundwater Source Protection Zone 1 (SPZ1). Accordingly, we recommend the following specific policy is included within the emerging Local Plan Part 3 in regards to groundwater protection:
New development sites are more appropriately located away from locations which are identified as Groundwater Source Protection Zone 1 (SPZ1). Groundwater is a vital resource, supplying around one third of mains drinking water in England, however groundwater supplies are under pressure from development associated with an increasing population. The details of groundwater protection zones can be viewed on the website of the Environment Agency.
Any proposals for new development within Groundwater Source Protection Zones must accord with Environment Agency guidance set out in its document titled ‘Groundwater Protection: Principles and Practice (GP3) August 2013’, or any subsequent iteration of the guidance.
New development within Groundwater Source Protection Zones will be expected to conform to the following:
MASTERPLANNING – careful masterplanning is required to mitigate the risk of pollution to public water supply and the water environment. For example, open space should be designed so it is closest to the boreholes so as to minimise the potential impact on groundwater. In addition, an appropriate management regime will be secured for open space features in the groundwater protection zone.
RISK ASSESSMENT - a quantitative and qualitative risk assessment and mitigation strategy with respect to groundwater protection will be required to manage the risk of pollution to public water supply and the water environment. The risk assessment should be based on the source-pathway-receptor methodology. It shall identify all possible contaminant sources and pathways for the life of the development and provide details of measures required to mitigate any risks to groundwater and public water supply during all phases of the development. The mitigation measures shall include the highest specification design for the new foul and surface water sewerage systems (pipework, trenches, manholes, pumping stations and attenuation features).
CONSTRUCTION MANAGEMENT PLAN - Construction Management Plans will be required to identify the potential impacts from all construction activities on both groundwater, public water supply and surface water and identify the appropriate mitigation measures necessary to protect and prevent pollution of these waters.
Within Source Protection Zone 1, pipework and site design will be required to adhere to a high specification to ensure that leakage from sewerage systems is avoided.
Please tick the box if you wish to be notified when the document is submitted, when recommendations are published and when the document is adopted.
Please notify me.
