Anglian Water is generally supportive of Policy ISPA2 which identifies strategic priorities for infrastructure provision within the Borough and collaboration with utility companies including Anglian Water to its delivery.

Reference is made to both the water supply network and sewage treatment but not the foul sewerage network.

It is therefore proposed that Policy ISPA2 is amended as follows:

'i) improvements to water supply, foul sewerage and sewage treatment capacity'

Anglian Water fully supports Policy DM1 as it states that all new residential development in the District should achieve the optional technical standard in terms of water efficiency of 110 litres/person/day. The Environment Agency has identified the Anglian Water region as an area of serious water stress, and we therefore support the adoption of the higher standard of water efficiency.

Government research (The Housing Standards Review Cost Impact report, 2014) has shown that the cost of the optional higher water efficiency standard and associated cost can be as low as £6-9 per dwelling. The optional higher water efficiency standard has also been successfully adopted in a number of local plans in Anglian Water company area.

We therefore consider that this does not make the Ipswich Borough Local Plan, or individual development proposals, unviable.

Based upon this evidence and the advice note circulated by Anglian Water and the Environment Agency we consider that the inclusion of the optional higher water efficiency standard is justified.

Similarly we fully support the cross reference to the requirements of Policy DM4 in relation to the provision of Sustainable Drainage Systems and water efficiency measures.

Anglian Water is generally supportive of Policy DM4 particularly the reference to Sustainable Drainage Systems (SuDS) and incorporation of water efficiency measures as part of new development. forming part of the design of new development.

However we would ask that the policy be amended to include a positive reference to the provision of SuDS by making it clear that it is the preferred method of surface water disposal and specific reference to the risk of sewer flooding as outlined in our response to the previous Local Plan consultation.

In respect of water efficiency/re-use we are actively supporting residential developers to include such as part of our Green Water Programme (https://www.anglianwater.co.uk/developers/green-water.aspx). Such measures are not limited to rainwater harvesting and can also include stormwater recycling systems and water recycling systems.

We would therefore suggest that list of measures referred to in the Policy should be extended to include these measures as well as rainwater harvesting.

It is therefore proposed that Policy DM4 is amended as follows:

'a. it does not increase the overall risk of all forms of flooding in the area or elsewhere through the layout and form of the development and appropriate application of Sustainable Drainage Systems (SuDS;
b. That no surface water connections are made to the foul system and connections to the combined or surface water system is only made in exceptional circumstances where it can be demonstrated that there are no feasible alternatives (this applies to new developments and redevelopments);
c. that adequate sewage treatment capacity and foul drainage already exists or can be provided in time to serve the development;
d. it will be adequately protected from flooding in accordance with adopted standards wherever practicable;
e. it is and will remain safe for people for the lifetime of the development; and
f. it includes water efficiency measures such as water re-use, stormwater or rainwater harvesting, or use of local land drainage water where practicable.'

Anglian Water is generally supportive of the Policy DM18 but considers that it should be made clear that new development should not prejudice the continued operation of established uses in Anglian Water's ownership.

We note that Policy DM18 (formerly DM26 of the adopted plan) and has been amended to included reference to satisfactory mitigation of amenity impacts.

It is important to note that in the case of Anglian Water's existing water recycling centres it is not always possible to provide mitigation to address such impacts. For example where residential development is proposed in a location which could give rise to adverse amenity impacts principally.

We would to prevent encroachment of occupied land and buildings which could give rise to future amenity loss and impose additional constraints on the operation of our assets. Planning permission must only be granted where it has been demonstrated that the proposed development would not be adversely affected by the normal operation of our operational assets.

It is therefore suggested that Policy DM18 is amended as follows:

The Council will protect the quality of life of occupiers and neighbours by only granting
permission for development that does not result in an unacceptable loss of amenity. Exceptions
will only be made where satisfactory mitigation measures can be secured or where this is not possible that any identified impacts can be avoided. The factors we will
consider include:

 visual privacy and overlooking
 overbearing impact and sense of enclosure
 sunlight, daylight, overshadowing and artificial light levels
 noise and vibration levels
 odour, fumes and dust
 contamination

Development that would be adversely affected by the conduct of established uses nearby will
not be permitted or where it would prejudice the continued operation of established uses.

Anglian Water notes that the focus of Policy CS17 is the use of planning obligations to secure the required off and on-site infrastructure to support additional development.

Anglian Water as a water and sewerage company seeks fair contributions through charges directly from developers under the provisions of the Water Industry Act 1991 to supply water and/or drain a site effectively. As such we would not, in most cases, make use of planning obligations or standard charges under Planning Legislation for this purpose.

However the use of planning conditions is of importance to Anglian Water. Therefore we would ask that the policy includes reference to use of planning conditions to ensure that development is aligned with the necessary infrastructure e.g. works within the foul sewerage network.

We would therefore ask that Policy be amended to include reference to use of planning conditions as well as Section 106 agreements.

It is suggested that the following wording or similar be included after the second paragraph in the Policy.

Conditions or planning obligations,as part of a package or combination of infrastructure delivery measures, are likely to be required
for many proposals to ensure that development meets this principle.
Consideration must be given to the likely timing of infrastructure provision. As such, development may need to be phased either spatially or in time to ensure the provision of infrastructure in a
timely manner. Conditions or a planning obligation may be used to secure this phasing
arrangement.