Comment

Representation ID: 23164

Received: 11/10/2021

Respondent: Environment Agency

Section 3) of this policy proposes a limit on water usage to 110l/p/d, and this is welcomed. 10.132 mentions that this is justified by evidence provided in the WCS. In addition to this, when the WCS was written, the water companies were classed as being in areas of ‘moderate‘ water stress. In July 2021, following a consultation exercise, the Secretary of State has determined that both Severn Trent Water (except their Chester zone) and South Staffs Water are now considered to be in areas of ‘serious water
stress’ for the purposes of water resources planning. This change in water stress classification adds further weight to this tighter limit and it may be worth reflecting this new classification within the plan as it is a key driver to tighten water usage in this area.

It should be highlighted however, that this requirement is a minimum only and developments that choose to go beyond this should be supported by the plan. Further limiting water consumption and encouraging re-use would provide additional benefits in relation to managing the pressures of climate change. This links to comments in relation to Policy CC1 - Increasing efficiency and resilience. In light of this we ask that you consider amending the policy to read as follows:

3) New residential development (including conversions from non-residential properties) and houses in multiple occupation will be required to meet water efficiency standards59 of 110 litres per person per day, as set out in Part G2 of current Building Regulations 2010 or any successor legislation. Any scheme that voluntarily proposes to go beyond this requirement would be viewed favourably.