Written evidence from Anglian Water Services
Ltd (ARSS 78)
The following submission is Anglian Water's memorandum
to the Communities and Local Government Committee Inquiry into
the abolition of Regional Spatial Strategies (RSS).
SUMMARY
1. Anglian Water is geographically the largest
water company in the UK serving over six million customers in
what is the flattest, most low-lying and driest area of the country.
2. Safe and secure water supplies in the
future depend on long-term planning.
3. Our business is managed in five-yearly
regulatory cycles against the framework of a 25-year Strategic
Direction Statement. Both require the approval of our regulators
and are strictly scrutinised.
4. Our business plan submissions are subject
to extensive consultation and are heavily influenced by strategic
engagement with a wide range of bodies, including consumer and
community groups, elected representatives and other key stakeholders.
5. Our ability to plan and invest in infrastructure
helps to underpin regional growth and tackles the impact of climate
changeboth of which are acknowledged as particular challenges
to our region.
6. We operate within a defined framework
to an agreed policy position. This certainty has helped us to
deliver over £5 billion of private investment between 2005
and 2015, and a reduction in average household bills for the period
to 2015.
7. Until a new local planning framework
is in place there will be significant uncertainty in the planning
system, which we see as detrimental to strategic planning and
decision making processes.
8. We are concerned that the current policy
void will lead to stagnation and delay the development of local
plans.
9. We believe that it is imperative for
there to be active co-operation between local planning authorities
(LPA) on strategic (larger than local) planning issues. For example,
river catchments and water resource zones extend beyond LPA boundaries.
Therefore, growth within one LPA area will impact upon the environmental
capacity within another. If the implications of growth and climate
change for such cross boundary issues are to be effectively and
efficiently managed, then we strongly believe that there is a
need for planning at a strategic, sub-national but larger than
local level.
10. We consider the proposed Local Enterprise
Partnerships (LEP) to have the potential to fulfil a strategic
planning function such as this.
11. Long-term water and wastewater infrastructure
planning is dependant on having a robust forecast of future housing
supply. Therefore, we recommend a continuation of Annual Monitoring
Reporting (AMR) for housing delivery and supply, which was previously
a statutory requirement for tracking progress towards RSS housing
targets.
12. The twin challenges of growth and climate
change, coupled with the sensitive nature of our wetland conservation
sites mean that in some areas of the East of England it is becoming
a major challenge to serve new development sustainably. Therefore,
it is important to consider the implications of local development
upon the water environment. To facilitate this we strongly recommend
that the current support for Water Cycle Studies continues.
ANGLIAN WATERCHALLENGES
WE FACE
AND THE
NEED FOR
LONG TERM
STRATEGIC PLANNING
Figure 1
IMPACTS OF GROWTH AND CLIMATE CHANGE ON ANGLIAN
WATER (2007)
Anglian Water is a statutory undertaker for the provision
of water and wastewater services, and is geographically the largest
water and wastewater company; providing services to over 6 million
people and 125,000 businesses in the east of England and the town
of Hartlepool in the north east. Our operational area is bounded
to the south by the River Thames, to the north by the Humber Estuary,
and extends from the east coast to Daventry and Milton Keynes
in the west.
The characteristics of the area that we serve make
it particularly vulnerable to climate change. Predominantly rural
it is also low lying, with around 25% being below sea level. Of
our major assets, 60 are vulnerable to a 0.4 metre rise in sea
levels, and more than 1,000 of our pumping stations are at risk
of flooding. Our area is the driest in the UK, and the Environment
Agency has assessed it as being one of "serious water stress".
This area also has one of the fastest rates of housing growth
in the UK, with a number of growth areas having been defined by
the previous government (Figure 1).
We recognise that under proposed changes to the planning
system, housing targets are likely to change from those outlined
in the former RSS. However, the need for us to continue long term
planning, at a strategic (defined in this context as sub-national
but larger than local) level to meet the challenges of growth
and climate change remains.
ANGLIAN WATERSTRATEGIC
PLANNING FOR
INVESTMENT TO
SUPPORT GROWTH
In our role as a statutory undertaker we have a duty
under Sections 37 and 94 of the Water Industry Act to extend our
services and provide for growth. For our current five year business
planning period (AMP 5) over £450 million is planned for
investment in our water and wastewater services to support growth.
This includes a "step change" in our level of wastewater
investment (Figure 2).
Figure 2
"STEP CHANGE" IN ANGLIAN WATER
INVESTMENT IN WASTEWATER SERVICES TO SUPPORT GROWTH
In line with our long term strategy it is likely
that this increase in investment to support growth will need to
be sustained over a number of subsequent business planning periods.
This will require support from a wide range of bodies, including
consumer and community groups, elected representatives and other
key stakeholders.
WASTEWATER SERVICES
Below, please find a case study that is typical of
the challenge we face in planning for long-term investment in
our wastewater infrastructure. We believe this underpins the case
we make for long-term co-ordinated strategic planning.
Case studyNorth Northamptonshire (Broadholme
catchment)
Government targets are for 52,000 new homes and 43,000
new jobs in North Northamptonshire by 2021 making it one of the
most concentrated areas of growth in the country. The challenge
of delivering this has prompted a new local partnership with the
five districts coming together to form a joint planning unit to
produce the Local Development Framework (LDF). This work identified
the wastewater infrastructure as a key constraint to growth. As
a result, the Environment Agency lodged objections to the Core
Strategy to ensure this would be addressed.
A team involving the local delivery vehicle, joint
planning unit, the Environment Agency and ourselves have worked
to deliver a water cycle study to address this objection and move
the planning process forward. As well as treatment capacity, there
is a need to provide major reinforcement to the linked sewerage
system connecting the market towns of Desborough, Kettering and
Rothwell. Therefore, we included a proposal for a £17 million
Kettering East Trunk Sewer within our Business plan submission
to Ofwat. To date this is one of the largest sewerage schemes
we have undertaken, but without this infrastructure development
at the head of this wastewater catchment will cause unacceptable
increases in flooding and environmental detriment.
The evidence that such reinforcement is both deliverable,
and contained within our Business plan, enabled the Core Strategy
to pass through the public examination process. Indeed, the collaborative
approach was commended within the Planning Inspector's report.
It is also this strategic approach, and the lateral endorsement
from such a wide range of bodies that ensured support for funding
by Ofwat. This collaborative approach is typical of how we manage
strategic development across our region for the benefit of customers
and the wider community.
WATER RESOURCES
Since 2007, water undertakers have had a statutory
duty to prepare and maintain a Water Resources Management Plan
(WRMP). Our plan informs our regulators how we plan to maintain
a balance between supply and demand for water over the next 25
years, it is based on the 12 Water Resource Zones (WRZ) that make
up the area within our statutory water supply boundaries.
As directed by the Environment Agency, our latest
WRMP and our business plan submission to Ofwat used policy and
trend based projections of population and property growth. These
projections are aligned with central and local government growth
projections. This enabled us to allocate population and property
growth, based on Office of National Statistics population projections,
and RSS/LDF projections respectively.
Using this forecast Ofwat approved funding of over
£200 million for the next five years to meet challenges of
growth, climate change and environmental legislation in the Anglian
Water region. This investment is required on a strategic scale
(sub-national but larger than local) across a number of our WRZ
and includes resource development, strategic transfers, alongside
demand management activities such as enhanced metering, water
efficiency measures and additional leakage control.
IMPLICATIONS
Having regard to our statutory duties we have the
following comments to make on the implications of abolishing RSS.
These comments are in line with specific questions posed by the
Committee:
1. The implications of
the abolition of regional house building targets for levels of
housing development
We have identified a number of challenges that face
the area that Anglian Water serves. The most significant are:
Faster rates of housing and economic growth.
The need to adapt to the impacts of climate change.
Our business is long-term, requiring us to plan often
years ahead for the delivery of some assets, such as reservoirs
and wastewater treatment plants. Hence we need to invest now to
prepare for the future. This investment requires a robust evidence
base, which will require a degree of certainty to be associated
with housing targets. This is particularly important for investment
in wastewater infrastructure, the need for which is also highly
sensitive to the location of development.
Regional house building targets provided a degree
of certainty that facilitated infrastructure planning, particularly
at a strategic level. Once local plans are in place, they will
provide a similar degree of certainty for infrastructure planning.
However, until then there will be significant uncertainty
in the planning system, which will make it difficult to secure
regulatory support for our investment proposals. This may in turn
have implications for the timely delivery of new housing stock.
It is important that the current policy void does not lead to
stagnation in the development of local plans.
2. The likely effectiveness
of the Government's plan to incentivise local communities to accept
new housing development, and the nature and level of the incentives
which will need to be put in place to ensure an adequate long-term
supply of housing
In principle Anglian Water supports the proposals
to incentivise new housing development. However, we strongly believe
that this should not be at the expense of long term sustainability.
Therefore, we consider it to be very important that the proposed
presumption in favour of sustainable development is based on well
developed national standards, which have been subject to a rigorous
process of consultation.
3. The arrangements which
should be put in place to ensure appropriate cooperation between
local planning authorities on matters formerly covered by regional
spatial strategies (eg waste, minerals, flooding, the natural
environment, renewable energy, etc)
The East of England has one of the highest long-term
economic growth rates in the UK, with seven of the UK's top 15
companies choosing to base themselves here, alongside over 430,000
other businesses. Taken together, they represent a significant
engine for growth and attract thousands of people to come and
live in the area. This sustained level of economic growth provides
an area of focus for housing developers, and the strength of the
local economy delivers to the Exchequer an annual contribution
of around £6 billion year-on-year (East of England Business
Forum, "Space for Ideas" 2010).
Although RSS have been abolished, the challenges
that face the former East of England region remain. To tackle
them and underpin economic growth will require the consistent
application of policy across all 63 district councils within our
area. Such policy will need to be specific to the particular challenges
that we face at sub-national level. Achieving this consistency
will require support from government. However, it may be difficult
to incorporate such specific support within a simplified National
Planning Framework, and we consider it unlikely that this framework
will have the capacity to make specific provision for the particular
strategic issues that we face.
Therefore, we would be very supportive of any provision
that is made for co-operation between local planning authorities
(LPA) on strategic planning issues. River catchments and water
resource zones extend beyond LPA boundaries, so growth within
one LPA area could impact upon the environmental capacity within
another. For such cross-boundary issues to be effectively and
efficiently managed, we believe that a strategic planning function
should be established.
4. The adequacy of proposals
already put forward by the Government, including a proposed duty
to co-operate and the suggestion that Local Enterprise Partnerships
may fulfil a planning function
We support the principle that LEP could fulfil a
planning function. However, we believe that this function will
need to take full account of the wider strategic perspective required
for water and wastewater planning. In our view, investment decisions
on issues like housing growth, transport infrastructure and water
resource planning require this broader, more strategic coordination.
5. How the data and research
collated by the now-abolished Regional Local Authority Leaders'
Boards should be made available to local authorities, and what
arrangements should be put in place to ensure effective updating
of that research and collection of further research on matters
crossing local authority boundaries
We recommend that the current statutory requirement
for local planning authorities to produce an AMR on progress towards
delivery of their local plan continues. This would ensure ongoing
visibility of this information for infrastructure planning purposes.
The twin challenges of growth and climate change,
coupled with the sensitive nature of our wetland conservation
sites mean that in some areas of the East of England it is becoming
a major challenge to serve new development sustainably. This has
been recognised in work previously carried out to support the
review of the East of England Regional Plan, which called for
a properly resourced programme of Water Cycle Studies to determine
whether growth at a local level is sustainable.
We recognise that under proposed changes to the planning
system, housing targets are likely to change from those outlined
in the former RSS. However, the need to consider the local implications
of development upon the water environment remains, irrespective
of any revisions to housing targets. Therefore, we recommend that
the current Water Cycle Study approach to local planning continues,
as it will help facilitate sustainable growth, and long term water
planning.
RECOMMENDATIONS
1. That in line with current guidance, to
fill the planning policy void at local level, we recommend that
planning authorities are encouraged to continue allocating sites
for development using the Local Development Framework process.
2. To fill the planning policy void at sub-national
level, we strongly recommend that a strategic planning function
be established to ensure co-operation between local planning authorities
on strategic issues, such as the provision of water and wastewater
infrastructure.
3. If Local Enterprise Partnerships fulfil
a planning function, we would strongly recommend that it is a
strategic one that takes full account of the wider implications
of growth and climate change upon long term water and wastewater
planning.
4. That planning authorities continue to
be required to produce an AMR for delivery of their local plans.
5. That a properly resourced programme of
Water Cycle Studies continues to inform long term planning for
the delivery of sustainable water and wastewater infrastructure.
REFERENCES
1. Anglian Water (2010) Water Resource Management
Plan http://www.anglianwater.co.uk/environment/water-resources/resource-management/
2. Anglian Water (2007) Strategic Direction
Statement. http://www.anglianwater.co.uk/about-us/statutory-reports/strategic-direction/index.aspx
3. Space for Ideas (2010) Blueprint for
growth. http://www.eastofengland.uk.com/blueprint
September 2010
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