Conclusions and recommendations
1. We
recommend that the draft NPS be revised to provide comprehensive
and effective sign-posting to assist decision makers in accessing
the full sources of policy advice to which the document refers.
(Paragraph 13)
2. We recommend that
the NPS be revised to define more clearly those terms whose interpretation
is subjective so as to provide decision makers with clarity on
their meaning in the context within which they are used. The NPS
should also be amended to include guidance on the definition of
what constitutes 'associated development' for waste water infrastructure
purposes. (Paragraph 16)
3. We recommend that
the NPS be amended to remove inclusion in an Asset Management
Plan as a criterion for proving need for a project. (Paragraph
23)
4. Inclusion within
the Environment Agency's National Environment Programme is less
contentious a criterion for determining need. However, the NPS
should set out clearly the process by which projects are accepted
for inclusion in the Programme and are thereby deemed to be needed
on environmental grounds. (Paragraph 24)
5. We recommend that
Defra revises the NPS to set out in detail the basis of its assessment
for the potential of alternative approaches to mitigate the need
for new infrastructure, such as the increased use of sustainable
drainage systems and water efficiency measures to reduce the production
of waste water. (Paragraph 30)
6. We recommend that
Defra undertakes within 12 months a full assessment of the potential
national impact of widespread adoption of SUDs and water efficiency
programmes for existing as well as new housing stock on future
waste water infrastructure needs and that this be taken into account
in any future revisions of the Waste Water NPS. (Paragraph 32)
7. We recommend that
the NPS be revised to provide clearer guidance for decision makers
as to how they should balance the relative weights of different
impacts and that it set out the criteria for making judgements
on the extent to which short-term, local impacts should be tolerated
in order to deliver long-term, wider gains. (Paragraph 35)
8. The wording of
the NPS must fully reflect existing statutory provisions which
decision makers would be expected to take into account in order
to protect greenfield spaces. (Paragraph 37)
9. Approval of the
costs which can be passed on to water and sewerage company customers
is rightfully a core Ofwat function under its current regulatory
remit and it is hard to see the benefits to be gained from duplicating
this activity within the spatial planning process. In view of
the alarming increases in estimated costs, Ofwat must fully utilise
its regulatory powers to scrutinise the economic case for the
Thames Tunnel project and be rigorous in determining which costs
should be passed on to Thames Water's customers. (Paragraph 40)
10. We recommend that
Ministers clarify that the NPS does not fetter the IPC or other
decision makers' ability to apply their judgement so as to impose
the standards most appropriate to the local circumstances of specific
projects. (Paragraph 43)
11. The statement
of Imperative Reasons of Overriding Public Interest (IROPI) justifying
development of this NPS should be strengthened to reflect the
considerable environmental benefits which a streamlined planning
regime can deliver through enabling timely completion of necessary
waste water infrastructure projects. (Paragraph 45)
12. The draft NPS
should be revised to make more detailed reference to increases
in greenhouse gas emissions that waste water infrastructure projects
could cause and to provide stronger guidance to decision makers
on the mitigation measures they should consider imposing on project
applicants. (Paragraph 48)
13. We recommend that
the Government urgently brings forward proposals to amend the
Planning Act 2008 to bring large-scale sewage collection and transfer
schemes such as the Thames Tunnel within the planning regime for
Nationally Significant Infrastructure Projects. (Paragraph 53)
14. We recommend that
the draft NPS be revised to produce a purely generic document
by removing Chapters 3 and 4 on the replacement of the Deephams
Sewage Treatment Works and the Thames Tunnel. Defra may wish to
provide material in an annex exemplifying points made in the NPS
by reference to specific schemes, but it should be made clear
that it does not constitute information to which decision makers
must have regard when considering project applications. (Paragraph
61)
15. We recommend that
Defra include in any justification of new waste water infrastructure
projects full explanation as to how they will help to meet national
and European environmental requirements. The Department should
also provide more detail on the potential alternative methods
of achieving environmental outcomes, such as improved water quality,
which new infrastructure is designed to achieve. (Paragraph 66)
16. Defra should clarify
in its response to this Report how it has taken into account responses
to all aspects of its draft NPS consultation in order to fulfil
the Government's requirement that formal consultation should take
place at a stage when there is scope to influence the policy outcome.
(Paragraph 68)
17. We recommend that
any future consultation on a draft NPS is given a higher profile,
particularly with the local authority and planning communities.
(Paragraph 70)
18. The draft NPS
should not have been published for consultation and scrutiny until
more complete. This NPS should not be designated until those deficiencies
are corrected. (Paragraph 72)
19. Given the importance
of this NPS in delivering waste water and water quality objectives,
we recommend that it be subject to a debate on the floor of the
House of Commons on an amendable motion prior to designation.
(Paragraph 73)
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