Comment

Representation ID: 23177

Received: 11/10/2021

Respondent: Environment Agency

Water Cycle Study: Phase 1 Scoping Study (May 2020)
At the time of preparing this Phase 1 Scoping Study proposed site allocations were not available so the WCS evidence at this point is high level only. No limitations on the provision of water supply infrastructure were identified by STW or SSW. The WCS states that once proposed Black Country Plan allocations are available, the total forecast growth should be compared to water company plans to ensure sufficient water resource available.
Development in areas where there is limited wastewater network capacity will increase pressure on the network, increasing the risk of a detrimental impact on existing customers, and increasing the likelihood of CSO operation. Is it essential therefore that in addition to the strategic proposals linking in with the sewerage provider, the plan and its policies ensures that developers have early engagement with Severn Trent Water Ltd.

The WCS states that across the sewer catchments that cover the study area there is hydraulic capacity for an equivalent of 260,000 new houses. However, much of this capacity is within the Minworth / Ray Hall catchments that also serves much of Birmingham’s growth over than period. As such a strategic assessment of proposed growth levels will be required as Birmingham’s plan comes in for review with further assessment of infrastructure improvements which will be required to be undertaken by the sewerage provider to support the proposed levels of growth and specific allocations. This additional work should be fed into the IDP (which currently includes no detail relating to such matters) and appropriate policies will be required to ensure that development is phased accordingly with any required infrastructure works in order to ensure no pollution of the water environment occurs as a result of untimely development putting undue pressure of existing systems.

The work undertaken in relation to water quality at this point is particularly lacking in the policy section. We look to the Phase 2 WCS work to provide assessment to help address this. The Phase 2 WCS should also include data that addresses issues raised by the Environment Agency in relation to the Draft Outline WCS last year which do not appear to have been reflected in the published draft (see Appendix 1).

The WCS should include a WFD impact assessment to inform water quality policies within the plan which are currently absent or lacking. As discussed in our informal
advice provided previous to this consultation, we would also expect the plan to include a more general River Basin Management Plan policy linked to the WCS evidence and pulling together all the water environment constraints and opportunities that the plan will need to take into consideration. Potential wordings for such a policy have been provided previously.

The following points are to be noted in undertaking this updated and more detailed
WCS work:

4.2 Resource Availability Assessment: since the WCS was written, the Staffs Trent Valley Abstraction Licensing strategy (ALS) has been updated and the Tame, Anker & Mease ALS will be updated in the next few months, followed by the Worcs Middle Severn ALS update. Any subsequent WCS should take these updates into consideration.

4.4.1 Water Stress: 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. The consultation response document dated 1 July 21 response contains this:

The government is currently considering its approach to building standards and how to enable greater water efficiency in new developments and retrofits. Local authorities can use the water stress
determination to inform whether they can require the tighter standard of
110 litres of water per head per day in new developments. Otherwise the use of the water stress determination is only to allow water companies to consider compulsory metering in their water resources management plans. It should not be used for other purposes such as development planning or water resources planning.