Tendring Colchester Borders Garden Community Development Plan Document (DPD)

Anglian Water welcomes the strategic aims of the policy in addressing the reduction of operational and embodied carbon across the new Garden Community, including through ensuring resource efficiency and prioritisation of renewable energy.

Anglian Water’s own long-term ambition to become net zero business by 2030 and reduce capital (embodied) carbon by 70% against a 2010 baseline, through innovative and optimised designs and material efficiencies, means that we encourage a quantitative approach to assessing growth options. This includes utilising available capacity at our Water Recycling Centres to accommodate future growth at locations informed by a Water Cycle Study or Integrated Water Management Study (IWMS). Anglian Water recognises that the Garden Community exemplifies this approach to utilise existing infrastructure capacity to reduce emissions from building new infrastructure to support growth. Furthermore, the Garden Community represents a quantum of growth that means investment in new infrastructure provides the greatest carbon efficiencies in relation to embodied/capital carbon in water supply and water recycling infrastructure. Our calculations show that developments that represent 5,000 population equivalent (more than 2,000 dwellings) will provide four times the carbon efficiencies than smaller developments.

The strategic masterplan identifying the Salary Brook Country Park as an important corridor for wildlife conservation, informal recreation, and education, with connections to the wider network of green and blue infrastructure is welcomed. Anglian Water considers that good design and on-site green and blue infrastructure can facilitate high quality developments that provide health and wellbeing benefits, manage surface water run-off through effective integration of sustainable drainage systems (SuDS) and deliver biodiversity net gain.

Part K: Planning application requirements

Anglian Water supports the requirement for a comprehensive site wide Garden Community Masterplan, detailed Area Specific Masterplans and Design Codes for relevant phases of development to be prepared by the developers.

Whilst site wide enabling costs and phasing of provision have been considered in the Infrastructure Delivery, Funding and Phasing Plan, Anglian Water would welcome further engagement on masterplans and design codes to ensure that rainwater/stormwater harvesting and greywater recycling opportunities are included as a key component of the strategic infrastructure provision to ensure the garden community demonstrates the fundamental principle of building climate resilient large-scale new communities in terms of utilising water resources sustainably through integrated water management systems.

Anglian Water is part of an innovative project, Enabling Water Smart Communities (www.ewsc.org), which was awarded £5.5 million by Ofwat as part of its Water and Breakthrough Challenge. Anglian Water is working with a range of partners including other water companies, universities, several developers and housing associations to deliver a project that will address the current barriers to integrated water management in residential development. The project would welcome the opportunity to engage with the masterplan and design code process and support implementation of integrated water management solutions for the benefit of the community, wider water resources and supply, and environmental sustainability.

Part D: Biodiversity Net Gain

Anglian Water is supportive of the preference for biodiversity offsetting to be located within the Garden Community to provide additional enhancement to the community as a whole and ensure greater resilience to the impacts of climate change. There are positive benefits for habitat enhancement to be incurred through linking with opportunities presented by Local Nature Recovery Strategies.

Part G: Sustainable Drainage Systems and Blue Infrastructure

Anglian Water welcomes a robust and comprehensive approach to sustainable drainage systems (SuDS) for the garden community, which represents the multi-functional benefits that can be achieved by designing in green-blue infrastructure (including SuDS) as a framework for the overall design of the community and as a foundation for good place-making. We particularly support the reference for SuDS to be used in conjunction with water use efficiency measures and the hierarchy of managing surface water drainage, which prioritises reuse. Where rainwater/stormwater harvesting can be utilised for non-potable uses in new development (residential and employment) this helps reduce potable water use and generate efficiencies not only in water use, but carbon used to store, treat and supply potable water to properties. SuDS have a critical role in not only reducing flood risk, but also for climate resilience and sustaining water resources.

The links in the written justification to GC Policy 8 are welcomed. Whilst a drainage plan and SuDS management and maintenance plan for the whole area is supported – Anglian Water recommends that this is closely linked to the over-arching green and blue infrastructure framework so that the multi-functional benefits and opportunities can be maximised.

Anglian Water suggests that the government’s Environment Improvement Plan (Water Efficiency Roadmap) intention to require 100 l/p/d in water stressed areas should be used as a minimum water efficiency standard with developers required to meet this and encouraged to demonstrate how they can go further utilising integrated water management and a fittings-based approach to minimise potable water use.

We propose that the policy clearly directs a criteria-based approach that is proportionate to new non-household developments and requires applicants to demonstrate water efficiency measures and water reuse have been incorporated in proposals. Where significant non-domestic water use is required, developers should be required to submit a Water Resources Assessment with the planning application following consultation with the relevant water company to ascertain water availability and feasibility of the proposed scheme.

Anglian Water operates in the driest and flattest part of the country, making it particularly vulnerable to the impacts of climate change. As these impacts become more frequent and severe, water scarcity, environmental capacity and flood risk are increasingly important. The Garden Community is within an area identified as seriously water stressed1 which applies both to the natural environment and to public water supplies. Both will be affected by pressures arising from climate change and additional demands associated with new development and population growth. Public water supplies are also under pressure from reductions in abstraction to make them more environmentally sustainable. The Environment Agency (EA)’s abstraction reduction strategy is therefore essential for the health of our environment, but it does present some challenges as changes have been made to the EA’s approach since the last Anglian Water water resources management plan (WRMP19).

Anglian Water develops a revised WRMP every five years setting out how water supplies will be managed to meet our future needs, ensuring our customers remain on resilient water supplies and preventing deterioration to the environment. A twin track approach was developed for WRMP19 (2020- 2045) for demand management and increasing supply, which together ensure our customers have a resilient, safe supply of water. Anglian Water’s draft Water Resources Management Plan 2025-2050 (dWRMP24) outlines that the two reservoirs planned for Lincolnshire and Cambridgeshire are no-regret supply options. However, given the considerable planning, construction, and filling time-frames for these projects, even with the significant early work done, we will have a short-term regional deficit until the reservoirs are in supply. The Essex South water resource zone (WRZ) is based on the supply systems for Colchester and Braintree with water supplied from a combination of groundwater abstractions in the Essex Chalk Aquifer. The deployable output of water resources in this WRZ reduces by 30.7 Ml/day by 2050; driven by abstraction reductions and climate change, as our demand management strategy will offset growth in the region via our water metering programme, leakage reduction and water efficiency measures. In addressing the shortfall of water, a new supply-side option is required before the reservoirs are available. With little to no opportunity to utilise any surplus ground or surface water, the dWRMP24 identifies the need for a water reuse plant in Colchester, with other preferred supply side options including potable water transfer and desalination.

Anglian Water notes that the North Essex Authorities Shared Strategic Section 1 Plan (2021) Spatial Policies 8 and 9 refer to water resources and wastewater within the garden community that refer to the delivery of a smart, innovative and sustainable water efficiency and reuse solutions that foster climate resilience and forward looking approach to water supply, water and wastewater treatment. Anglian Water recognises the relevant policies within the respective Tendring District and Colchester City Section 2 Local Plans regarding flood risk, provision of drainage/sewerage and water efficiency measures. However, we consider that the TCBGC plan should reflect the aims of the Section 1 Local Plan in identifying measures that incorporate the highest standards of innovation in these areas which are reflective of Garden City Principles in terms of resource use and delivering a climate resilient large-scale new community2.

The Integrated Water Management Study Phase 2 (IWMS2) sets out water neutrality scenarios which extend from the baseline position of average per capita consumption to the adopted policy position in the Section 2 Local Plans of the 110 litres per person per day (l/p/d) optional higher standard with some retrofits, and theoretical neutrality. There is no scenario which takes an intermediate position to reflect the more ambitious approach set out in the North Essex Section 1 Local Plan policy approach for highest standards in innovation for water efficiency.

Whilst Anglian Water is supportive of the measures introduced by this policy we propose that the plan should introduce new policy text for water efficiency and reuse given the scope for, and policy drivers to deliver rainwater/stormwater harvesting and reuse and greywater recycling, meaning that the requirement of the optional higher water efficiency standard of 110 litres/person/day (l/p/d) can be more ambitious. Anglian Water suggests that the government’s Environment Improvement Plan (Water Efficiency Roadmap) intention to require 100 l/p/d in water stressed areas should be used as a minimum with developers required to meet this and encouraged to demonstrate how they can go further utilising integrated water management and a fittings-based approach to minimise potable water use.

Anglian Water has a statutory duty to supply water for domestic purposes including any domestic requirements of non-household properties (e.g., drinking water, hand-basins, toilets and showers). In many cases, domestic demand will be the only requirement for many non-household properties. Non-domestic demand refers to water use for industrial processes, (e.g., agri-food production or car washes), and there is no legal requirement for us to supply for this type of water usage where it might put at risk our ability to supply water for domestic purposes. Although Anglian Water do not have a statutory obligation to supply for non-domestic purposes in these circumstances, we factor this into our WRMP and we do everything we can to support businesses in the region, with the help of the water retail market. However, as described above, the situation is now changing, due to water supply being squeezed by abstraction reduction, climate change and a fast-growing population. Therefore, where new and unplanned non-domestic requests are received, there might be the need to decline requests to protect existing supplies and the environment.

Anglian Water would therefore propose that the policy clearly directs a criteria-based approach that is proportionate to new non-household developments and requires applicants to demonstrate water efficiency measures and water reuse have been incorporated in proposals. Where significant non-domestic water use is required, developers should be required to submit a Water Resources Assessment with the planning application following consultation with the relevant water company to ascertain water availability and feasibility of the proposed scheme.

Anglian Water recommends that the proposed approach for residential properties and non-household development is incorporated in the Plan as steps need to be taken now to future proof new homes that are coming forward in the next five years and assist business to be more water efficient. Garden Communities are exemplars of sustainable and resilient development and should push boundaries to demonstrate that positive steps can be taken to deliver smarter and more efficient designs.

Anglian Water with the Environment Agency and Natural England are updating a Joint Protocol which has supported the majority of the 59 Councils across the Anglian Water region to adopt or be in the process of adopting a Policy requiring a 110 l/p/d water efficiency standard for all new homes. The updated Protocol will seek a water efficiency standard which goes beyond 110 l/p/d and seek water efficiency in new and expanding business. This will be through a combination of improved fixtures and fittings, education and support underpinned by Anglian Water’s smart metering roll out.

Anglian Water welcomes the policy requirement to ensure developers work positively with other infrastructure providers throughout the planning process to ensure that the cumulative impact of development is considered and then mitigated, at the appropriate time, in line with their published policies and guidance. As outlined in the Infrastructure Delivery, Phasing and Funding Plan, Anglian Water publishes infrastructure charging schedule for connection to our water supply and wastewater networks. As most of the site is under the control of a master-developer, it is considered this should assist with preparing a consistent and efficient approach for planning and phasing infrastructure requirements across the site. We suggest that engagement with Anglian Water is undertaken at the earliest stage.

Infrastructure Delivery, Phasing and Funding Plan (IDPFP):
Anglian Water has reviewed the IDPFP for the garden community in terms of water and wastewater infrastructure which is detailed in Section 8 Sustainable Infrastructure. We suggest that engagement with Anglian Water is undertaken at the earliest stage. It is noted that section 4.2 mentions contact has been made with the relevant utility providers – however, the list of utilities at the beginning of the section should include wastewater or sewerage, rather than only water supply.

4.2.4 Potable Water
The Water Resource Management Plans (WRMP24) have been updated for the period 2025 - 2050 in draft form and are available on the respective water companies’ websites. As the statutory undertaker for water (within Colchester City local planning authority area, and sewerage undertaker for the entire Garden Community area, Anglian Water would welcome similar references to our Strategic Direction Statement and infrastructure funding requirements as per Affinity Water.

It is noted that reference is made to the ability for developers to work with a New Appointment and Variation (NAV) to provide water/wastewater services to a development. The text should also refer to Anglian Water rather than just Affinity Water, particularly in reference to sewerage connections. As the area covers both Anglian Water and Affinity Water water supply areas, there is no clear pathway on which company will supply water, unless a NAV is used by the developer who will then need to obtain a supply from either or both companies.

4.2.5 Wastewater
There is an error at the beginning of this section as it refers to the Anglian Water WRMP which should be referenced under 4.2.4 Potable Water. This section should refer to our recently finalised Drainage and Wastewater Management Plan (DWMP) which covers the period 2025 – 2050. The medium- and long-term strategy for Colchester water recycling catchment is wait and see, with population projected to increase by around 34,000 by 2050. The DWMP is updated every five years and will monitor growth and update with the latest information to guide our investments – this will be informed by growth in adopted development plans and the extent to which pre-development discussions have taken place with developers seeking connections. As we receive updated information, we will regularly review our figures internally to ensure our strategies are being implemented at the correct time and to the correct sizes.

We welcome the reference to engagement with Anglian Water regarding connections to our network and capacity enhancements. Early engagement ensures that the processes are in place and any upgrades can be provided in a timely manner to align with phasing of development across the new community.

Integrated Water Management Study Phase 2 (IWMS):
Anglian Water has published a draft Water Resources Management Plan for the period 2025 – 2050 which identifies strategic supply side options for the Essex South water resource zone, alongside the demand management options that will be taken forward across the Anglian Water region.

The final Drainage and Wastewater Management Plan 2025-2050 has now been published on our website. The medium- and long-term strategies for Colchester WRC have not changed from the draft version used in the study.

Both plans are referenced in further detail in our representation on the Plan and the IDPFP.