Full text:
Thank you for the opportunity to comment on this consultation. We have reviewed the North East Derbyshire Local plan consultation document in relation to our wastewater services area and sewage treatment capacity. We have some specific comments to make in relation to sewage treatment capacity.
Five Severn Trent wastewater treatment works serve a portion of the North East Derbyshire area. These are to the south and west of the area serving the west of Clay Cross and villages to the south and west of Clay Cross. We have reviewed the development proposals in the consultation document and identified those that would be served by a Severn Trent wastewater treatment works (WwTW). The remainder, where served by public sewerage, we believe will be served by Yorkshire Water. Please see Appendix A for our mapping of development sites to wastewater treatment works.
Ashover WwTW
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Has capacity for the allocations identified.
Ashover – Overton Hall WwTW
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No allocations identified in the catchment.
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Has very limited capacity for infill development.
Clay Cross WwTW
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Has capacity within its discharge permit for the allocations identified. Utilisation of the permit capacity will necessitate significant investment to ensure adequate treatment performance to ensure compliance with all permit limits.
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Approximately one third of the allocation proposals can be accommodated with the improvements already planned during our AMP8 (2025-2030) regulatory period. Were all allocation proposals to be taken forward, we would be grateful to understand a likely completions profile to enable us to plan further investment to ensure capacity is available.
Kelstedge WwTW
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No allocations identified in the catchment.
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Has capacity for limited proportionate development in the catchment.
Westwood Bank WwTW
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Has capacity within its discharge permit for approximately 90% of the allocation proposals identified.
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Environmental capacity of the downstream water course means there is limited scope to provide additional capacity above that already permitted.
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Approximately 60% of the allocation proposals can be accommodated with the improvements already planned during our AMP8 (2025-2030) regulatory period. Were all allocation proposals to be taken forward, we would be grateful to understand a likely completions profile to enable us to plan further investment to ensure capacity is available.
For Ashover, Ashover – Overton Hall and Kelstedge WwTWs, further expansion of these works may be problematic because of the environmental capacity of the downstream water courses, in particular Ogston Reservoir SSSI.
Please keep us informed when your plans are further developed when we will be able to offer more detailed comments and advice.
Position Statement
As a water company we have an obligation to provide water supplies and sewage treatment capacity for future development. It is important for us to work collaboratively with Local Planning Authorities to provide relevant assessments on the impacts of future developments and to provide advice regarding policy wording on other relevant areas such as water efficiency, Sustainable Drainage Systems (SuDS), biodiversity, and blue green infrastructure. Where more detail is provided on site allocations, we will provide specific comments on the suitability of the site with respect to the water and sewerage network. In the instances where there may be a concern over the capacity of the network, we may look to undertake modelling to better understand the potential risk. For most developments there is unlikely to be an issue connecting. However, where an issue is identified, we will look to discuss in further detail with the Local Planning Authority. Where there is sufficient confidence that a development will go ahead, we will look to complete any necessary improvements to provide additional capacity.
For your information we have set out some general guidelines and relevant policy wording that may be useful to you.
Wastewater Strategy
We have a duty to provide capacity for new development in the sewerage network and at our Wastewater Treatment Works (WwTW) and to ensure that we protect the environment. On a company level we have produced a Drainage and Wastewater Management Plan (DWMP) covering the next 25 years, which assesses the future pressures on our catchments including the impacts of climate change, new development growth and impermeable area creep. This plan supports future investment in our wastewater infrastructure and encourages collaborative working with other Risk
Management Authorities to best manage current and future risks. More information on our DWMP can be found on our website https://www.severntrent.com/about-us/our-plans/drainage-wastewater-management-plan/.
Where site allocations are available, we can provide a high-level assessment of the impact on the existing network. Where issues are identified, we will look to undertake hydraulic sewer modelling to better understand the risk and where there is sufficient confidence that a development will be built, we will look to undertake an improvement scheme to provide capacity.
Surface Water
Management of surface water is an important feature of new development as the increased coverage of impermeable area on a site can increase the rainwater flowing off the site. The introduction of these flows to the public sewerage system can increase the risk of flooding for existing residents. It is therefore vital that surface water flows are managed sustainably, avoiding connections into the foul or combined sewerage system and where possible directed back into the natural water systems. We recommend that the following policy wording is included in your plan to ensure that surface water discharges are connected in accordance with the drainage hierarchy:
Drainage Hierarchy Policy
New developments shall demonstrate that all surface water discharges have been carried out in accordance with the principles laid out within the drainage hierarchy, whereby a discharge to the public sewerage system is avoided where possible.
Supporting Text:
Planning Practice Guidance Paragraph 80 (Reference ID: 7-080-20150323) states:
“Generally the aim should be to discharge surface water run off as high up the following hierarchy of drainage options as reasonably practicable:
1. into the ground (infiltration);
2. to a surface water body;
3. to a surface water sewer, highway drain, or another drainage system;
4. to a combined sewer.”
Sustainable Drainage Systems (SuDS)
Sustainable Drainage Systems (SuDS) represent the most effective way of managing surface water flows whilst being adaptable to the impact of climate change and providing wider benefits around water quality, biodiversity, and amenity. We therefore recommend that the following policy wording is included within your plan regarding SuDS:
Sustainable Drainage Systems (SuDS) Policy
All major developments shall ensure that Sustainable Drainage Systems (SuDS) for the management of surface water run-off are included, unless proved to be inappropriate.
All schemes with the inclusion of SuDS should demonstrate they have considered all four areas of good SuDS design: quantity, quality, amenity and biodiversity.
Completed SuDS schemes should be accompanied by a maintenance schedule detailing maintenance boundaries, responsible parties and arrangements to ensure the SuDS are managed in perpetuity.
Supporting Text:
Sustainable Drainage Systems (SuDS) should be designed in accordance with current industry best practice, The SuDS Manual, CIRIA (C753), to ensure that the systems deliver both the surface water quantity and the wider benefits, without significantly increasing costs. Good SuDS design can be key for creating a strong sense of place and pride in the community for where they live, work and visit, making the surface water management features as much a part of the development as the buildings and roads.
Blue Green Infrastructure
We are supportive of the principles of blue green infrastructure and plans that aim to improve biodiversity across our area. Looking after water means looking after nature and the environment too. As a water company we have launched a Great Big Nature Boost Campaign which aims to revive 12,000 acres of land, plant 1.3 million trees and restore 2,000km of rivers across our region by 2027. We also have ambitious plans to revive peat bogs and moorland, to plant wildflower meadows working with the RSPB, National Trust, Moors for the Future Partnership, the Rivers Trust, National Forest and regional Wildlife Trusts and conservation groups.
We want to encourage new development to continue this theme, enhancing biodiversity and ecology links through new development so there is appropriate space for water. To enable planning policy to support the principles of blue green Infrastructure, biodiversity and protecting local green open spaces we recommend the inclusion of the following policies:
Blue and Green Infrastructure Policy
Development should where possible create and enhance blue green corridors to protect watercourses and their associated habitats from harm.
Supporting Text:
The incorporation of Sustainable Drainage Systems (SuDS) into blue green corridors can help to improve biodiversity, assisting with the wider benefits of utilising SuDS. National Planning Policy Framework (2021) paragraph 174 States:
“Planning policies and Decisions should contribute to and enhance the natural and local environment by:
a)
protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their Statutory Status or identified quality in the development plan);
b)
recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;
c)
maintaining the character of the undeveloped coast, while improving public access to it where appropriate;
d)
minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;”
Green Open Spaces Policy
Development of flood resilience schemes within local green spaces will be supported provided the schemes do not adversely impact the primary function of the green space.
Supporting Text:
We understand the need for protecting Green Spaces, however open spaces can provide suitable locations for schemes such as flood alleviation schemes to be delivered without adversely impacting on the primary function of the open space. If the correct scheme is chosen, the flood alleviation schemes can result in additional benefits to the local green space through biodiversity and amenity benefits.
Water Quality and Resources
Good quality watercourses and groundwater is vital for the provision of good quality drinking water. We work closely with the Environment Agency and local farmers to ensure that the water quality of our supplies are not impacted by our operations or those of others. Any new developments need to ensure that the Environment Agency’s Source Protection Zones (SPZ) and Safeguarding Zone policies which have been adopted by Natural Resources Wales are adhered to. Any proposals should take into account the principles of the Water Framework Directive and River Basin Management Plan as prepared by the Environment Agency.
Every five years we produce a Water Resources Management Plan (WRMP) which focuses on how we plan to ensure there is sufficient supply of water to meet the needs of our customers whilst protecting our environment over the next 25 years. We use housing target data from Local Planning Authorities to plan according to the projected growth rates. New development results in the need for an increase in the amount of water that needs to be supplied across our region. We are committed to doing the right thing and finding new sustainable sources of water, along with removing unsustainable abstractions, reducing leakage from the network and encouraging the uptake of water meters to promote a change in water usage to reduce demand.
New developments have a role to play in protecting water resources, we encourage you to include the following policies:
Protection of Water Resources Policy
New developments must demonstrate that they will not result in adverse impacts on the quality of waterbodies, groundwater and surface water, will not prevent waterbodies and groundwater from achieving a good status in the future and contribute positively to the environment and ecology.
Where development has the potential to directly or indirectly pollute groundwater, a groundwater risk assessment will be needed to support a planning application.
Supporting Text:
National Planning Policy Framework (July 2021) Paragraph 174 states:
“Planning policies and decisions should contribute to and enhance the natural and local environment by: …
e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans;”
Water Efficiency Policy
We are supportive of the use of water efficient design of new developments fittings and appliances and encourage the optional higher water efficiency target of 110 litres per person per day within part G of building regulations. Delivering against the optional higher target or better provides wider benefits to the water cycle and environment as a whole. This approach is not only the most sustainable but the most appropriate direction to deliver water efficiency. We would therefore recommend that the following wording is included for the optional higher water efficiency standard:
New developments should demonstrate that they are water efficient, incorporating water efficiency and re-use measures and that the estimated consumption of wholesome water per dwelling is calculated in accordance with the methodology in the water efficiency calculator, not exceeding 110 litres/person/day.
Supporting Text:
National Planning Policy Framework (July 2021) Paragraph 153 states:
“Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, costal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. Policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.”
This need for lower water consumption standards for new developments is supported by Government. In December 2018, the Government stated the need to a reduction in Per Capita Consumption (PCC) and issued a call for evidence on future PCC targets in January 2019, with an intention of setting a long term national target. The National Infrastructure Commission (NIC) has already presented a report including recommendations for an average PCC of 118 l/p/d. In Wales, the 110 l/p/d design standard was made mandatory in November 2018. In 2021 the Environment Agency classed the Severn Trent region as Seriously Water Stressed – link.
We recommend that all new developments consider:
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Single flush siphon toilet cistern and those with a flush volume of 4 litres.
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Showers designed to operate efficiently and with a maximum flow rate of 8 litres per minute.
•
Hand wash basin taps with low flow rates of 4 litres per minute or less.
•
Water butts for external use in properties with gardens.
Water Supply
For the majority of new developments, we do not anticipate issues connecting new development, particularly within urban areas of our water supply network. When specific detail of planned development location and sizes are available a site-specific assessment of the capacity of our water supply network could be made. Any assessment will involve carrying out a network analysis exercise to investigate any potential impacts. If significant development in rural areas is planned, this is more likely to have an impact and require network reinforcements to accommodate greater demands.
Developer Enquiries
When there is more detail available on site-specific developments, we encourage developers to get in contact with Severn Trent at an early stage in planning to ensure that there is sufficient time for a development site to be assessed and if network reinforcements are required that there is time to develop an appropriate scheme to address the issues. We therefore encourage developers to contact us, details of how to submit a Developer Enquiry can be found here - https://www.stwater.co.uk/building-and-developing/new-site-developments/developer-enquiries/
We hope that this information has been useful to you and we look forward to hearing from you in the near future.
Appendix A – Mapping Allocation Proposals to WwTW
Priority 1 – Edge of Chesterfield/Sheffield, New Settlement/Strategic Sites and Level 1 Settlements – Main Towns
Yorkshire Water - Edge of Sheffield, Edge of Chesterfield, Strategic Sites – Duckmanton Moor, Eckington South, Dronfield, Eckington, Killamarsh
Clay Cross spans the boundary between Severn Trent Water and Yorkshire Water wastewater services, with the area boundary running along the High Street. Therefore, we have assumed the proposed allocations will drain as follows:
Severn Trent Water (Clay Cross STW)
45003 – 19b High Street, Clay Cross 25 dwellings
45052 - Land to the west of A61 Derby Road, Clay Cross 560 dwellings
45099 – Land north of Rykneld House, Stretton Road, Clay Cross 20 dwellings
45567 – Land north of Rykneld House, Stretton Road, Clay Cross 8 dwellings
45919 - Kenning Park land, located to the west of High Street, Clay Cross 120 dwellings
Yorkshire Water
45060 – Clay Cross South
45447,45763, 45806, 45809, 45810 Former Biwaters Site
45920 – Land north of Biwater, Clay Cross
45445 – Plot H, Coney Green Business Park, Clay Cross
45446 – Land off Upper Mantle Close, Bridge Street Industrial Estate, Clay Cross
45448 – Land off Bridge Street, Clay Cross
Priority 2- Level 2 Settlements – Larger Villages
Yorkshire Water - Calow, Grassmoor, Holmewood, North Wingfield, Lower Pilsley, Renishaw, Wingerworth
Severn Trent Water
Pilsley (Westwood Brook STW)
45011 – Land to the rear of Station Road, Pilsley 130 dwellings
45234 – Land to the rear of 2 to 68 Queen Street……, Pilsley 90 dwellings
45015 – Land to the rear of Manor House, Manor Close, Pilsley 25 dwellings
45824 – Commercial Inn, Bridge Street, Pilsley 10 apartments
Mickley (Shirland Cluster) (Westwood Brook STW)
45290 – Land east of Mickley Infant School, Mickley, Stretton 140 dwellings
45850 – Ainmoor Grange Caravan Park, Mickley Lane, Mickley, Stretton 31 caravans
Shirland (Shirland Cluster) (Westwood Brook STW)
45045 – Land north of Park Lane, Shirland 45 dwellings
45089 – Land at Cross Lane, Shirland 60 dwellings
45207 – Land east of Park Close, Park Lane, Shirland 80 dwellings
45904 – Land west of Main Road and North of Cross Lane, Shirland 120 dwellings
45841 – Land to the south of Hallfieldgate Lane, Shirland 90 dwellings
Stonebroom (Shirland Cluster) (Westwood Brook STW)
45080 – Land South of Carlyle Road, Stonebroom, Alfreton 30 dwellings
45081 – Land South of Carlyle Road and Shelley Grove, Stonebroom, Alfreton 170 dwellings
45255 - Land to the south of Kingsley Cresent, Stonebroom 250 dwellings
45230 – Land to the Noth of West Street/Quarry Lane, Stonebroom 50 dwellings
45231 – Land off Pasture Lane Stonebroom 55 dwellings
45848 – Land to the rear of 14A-54 High Street, Stonebroom 30 dwellings
45593 – Land at Stonebroom, Alfreton 200 dwellings
45851 – Land to the Northwest of 101 Birkinstyle Lane, Shirland 10 dwellings
45918 – Street Record, The Bungalows, Stonebroom, Shirland 69 dwellings
Tupton spans the boundary between Severn Trent and Yorkshire Water. We have assumed the proposed allocations will drain as follows.
Severn Trent Water (Clay Cross STW)
45075 – Land West of Coupe Lane, Old Tupton 250 dwellings
45894 – Woodlands, Marton Lane, Old Tupton, Chesterfield 60 dwellings (could be Yorkshire Water)
Yorkshire Water
45058 – Land west of Derby Road, Tupton
45059 – Land east of A61, Tupton
45494 – Land on the west side of Nethermoor Road, New Tupton
45585 – Land to side of 48 Nethermoor Road, Tupton
45215 – Land at 26 Queen Victoria Road, New Tupton, Chesterfield
45642 – Land off Holmgate Road, Clay Cross
45764 – Land to the north and west of the Poplars, Ankerbold Road, Tupton
45770 – Land at rear of 263 Nethermoor Road, Wingerworth
45771 – South of Sunningdale Park and Birkin Park, Birkin Avenue, Tupton
45893 – Land lying to the north of Ashover Road, Old Tupton, Chesterfield 35 dwellings (could be Severn Trent)
Priority 3- Level 3 Settlements – Smaller Villages
Yorkshire Water - Arkwright Town, Heath, Holmesfiled, Holymoorside, Long Duckmanton, Stretton*,Unstone, Unstone Green
* Stretton sits on the boundary of Severn Trent Water and Yorkshire Water waste service areas. As Severn Trent doesn’t serve Stretton today, we assume this development adjacent to existing properties will be served by Yorkshire Water.
Severn Trent Water
Ashover (Ashover STW)
45743 – Land South West of Grange Farm, Milken Lane, Ashover 10 dwellings
45745 – Land at the Junction of Narrowleys Lanes and Moor Road, Ashover 26 dwellings
Morton (Westwood Brook STW)
45105 – Land off Stretton Road, Morton, Derbyshire 130 dwellings
45912 – Fields south of Maltby Avenue and Oak View Gardens 140 dwellings
Wessington (Westwood Brook STW)
45083 – Land east of Brackenfield Lane, Wessington, Alfreton 50 dwellings
45084 – Land north of Back Lane, Wessington, Alfreton 90 dwellings
45907 – Land abutting Matlock Road, Wessington 40 dwellings
Priority 4- Level 4 Settlements – Very Small Villages/Hamlets
Yorkshire Water - Barlow Commonside, Old Brampton
