Evidence

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.

Comment

Representation ID: 45933

Received: 11/10/2021

Respondent: Environment Agency

[draft outline Water Cycle Study]

Appendix 1

Comments made in relation to draft outline WCS which require addressing

1.4 – Objectives

• There doesn’t appear to be any mention of impact of the additional growth on the environment as a result of increased discharge volumes from sewage treatment works

3.5.3 – Drainage and Wastewater Management Plans

• Still no mention in the final paragraph of using DWMPs to assess environmental impact

7.3 – Figure 7.3

• I believe the storm tank capacity should read ‘2 hours at maximum flow’ or ’68 litres of storage per head per day’.
• Inlet CSO should be set at ‘Formula A’.

7.3.1 – Introduction

• It may be worth noting that any increase in DWF as a result of population growth is also likely to trigger a tightening of sanitary determinand and nutrient limits.

9 – Water Quality

• Why have the tables seemingly got Objectives by 2015 listed in the various tables? This is out of date information
• It is also misleading that these ‘objectives’ appear to suggest we are not aiming to achieve a classification of ‘Good’

9.4.3 – Gospel End

• Can it be confirmed that the discharge goes to the Merryhill Beck and not Merryhill Brook. Plus, I am not sure it is a direct tributary of the River Severn. I believe it joins the Wom-Penn Bk and then probably the River Smestow?

General Point – The report references capital works and improvements scheduled for Goscote WwTW that should improve WQ but it fails to note that similar improvement schemes are being carried out at numerous other works mentioned in the report (AMP6 schemes due for delivery by April 2020)

9.6 – Water Quality Conclusions

• It should be noted that there is zero leeway for deterioration within a WFD WB
which is already classed as Bad
• It is also equally important to consider the impact of growth in all WBs and not just those classed as Poor or Bad. The WFD requires that there should be no change in class and also should seek to limit deterioration with class to less than
10%.

11.3.4 – SuDS
• It could be noted that SuDS systems also keep surface water out of the sewer network creating capacity in the network for the conveyance of sewage instead of rainwater. In turn, this should improve the performance of storm related assets
on the network such as CSOs

13 – Summary and Overall Conclusions

• The table refers to certain sites having ‘environmental headroom’. I don’t see how this can be stated as I cannot see that any WQ impact assessment has been completed in this report.
• It should also be noted that if a WwTW receives increased flows then the WQ aspect of the permit may need tightening. This could result in the need for very tight, possibly unobtainable, permit limits for WQ.
• WQ Impact assessment – this needs to be changed in accordance with the point raised in 9.6 above.
• I believe the recommendations suggest that SuDs should be employed wherever there is a risk of direct connection to the environment yet elsewhere in the report, it recommends SuDs use in all locations, irrespective of a direct pathway

Table 13.2

• The wastewater collection section could do with specific mention of the need to assess the impact of growth on storm water related discharges


Appendix 2: Environment Agency flood alleviation schemes

Name of scheme NGR
Cartbridge Lane FAS, Bloxwich SK0232100518
Collins Road Sheet Pile Refurbishment SP00049541
Dawley Brook Flood Alleviation Scheme, Kingswinford SO8751989251
Ford Brook South FAS, Walsall SP0049796230
Halesowen, River Stour, Property level Protection Scheme SO9688084180
Hobnail Brook FRMS, West Bromwich SP0208894523
Kelverley Grove flood defence repairs SP0220094140
Ocker Hill Flood Storage Area SO98089423
River Stour headwater storage and INNS eradication SO9603882413
Smestow Brook FRMS, Wolverhampton SO8908499752
Tame Tunnel Flood Risk Management Scheme, Willenhall SO94589782
Thimblemill Brook Flood Alleviation Scheme, Smethwick SP0221087920
Tipton & Swan Brook Flood Alleviation Scheme SO9787293262
Waddens and Bentley Flood Relief Culvert FRMS, Willenhall SO96859924
Waddens Brook Flood Risk Management Scheme, Willenhall SO96289862
Whiteheath Brook FRMS, Tipton SO9837588669
Wordsley and Lye, Stourbridge Property level Protection
Scheme
SO8927086690