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The Local Plan for the Broads: Issues and Options Consultation

21.1 Introduction

The East of England is an area of water stress. According to the Environment Agency, if no action is taken between 2025 and 2050, around 3,435 million additional litres of water per day will be needed in England to address future pressures on public water supply; within this figure it is estimated that the East of England will require an additional 570 million litres per day to meet the needs of residents and the agricultural sector, industry and energy sector_[21]. Additionally, given the context of Nutrient Neutrality in which we are operating, less water used could mean less water into the waste water network so less water treated at water recycling centres with impacts on the nutrients released into waterways.

21.2 Current policy and Norfolk Strategic Planning Framework Agreement

The adopted Local Plan policy DM4 sets a water use standard of 110 litres per household per day (l/h/d), which is beyond the current building regulations requirement of 125 l/h/d. Indeed, all Norfolk Local Planning Authorities have agreed to include the 110 l/h/d in their local plans, through the Norfolk Strategic Planning Framework agreement which states at Agreement 22 that ‘Norfolk is identified as an area of serious water stress. The Norfolk Planning Authorities have agreed that when preparing Local Plans to seek to include the optional higher water efficiency standard (110 litres/per person/per day) for residential development’.

21.3 Emerging policy for Greater Cambridge

We are aware that the Greater Cambridge Local Plan is considering going further than the optional standard for water usage of 110 l/h/d and proposing 80 l/h/d unless demonstrated impracticable. Their evidence suggests that current levels of abstraction in the area are believed to be unsustainable. In terms of deliverability of the 80 l/h/d standard, the proposal says ‘the Integrated Water Management Study (IWMS) has shown that 80 litres/person/day is achievable by making full use of water efficient fixtures and fittings, and also water re-use measures on site including surface water and rainwater harvesting, and grey water recycling. It also shows that the cost effectiveness improves with the scale of the project, and that a site-wide system is preferable to smaller installations’.

21.4 Water neutrality

‘Water neutrality’ means that new development should not increase the rate of water abstraction above existing levels. It is an issue being raised and looked into in Sussex. In a position statement sent in October 2021 to Horsham, Crawley and Chichester councils, which fall within the Sussex North Water Supply Zone, Natural England laid out its concern that current levels of water abstraction are having an adverse impact on protected sites in the region and advised that developments within the Zone must not add to this impact. Natural England indicates that the matter should be addressed strategically, in partnership with other local planning authorities. Horsham District Council’s response is at Water Neutrality in Horsham District and its planning implications | Horsham District Council. This matter is early on in its investigation and the Broads Authority will keep informed of how it develops.

21.5 Scale of development in the Broads

It may be more feasible and cost effective to meet stricter water use standards over larger schemes. We do not often have large scale development in the Broads. A scheme in Ditchingham Dam (over 100 dwellings) has recently been completed, a scheme at Pegasus (76 dwellings) has been permitted, and there is an allocation for around 120 dwellings in East Norwich (Utilities Site). Schemes in the Broads, however, usually tend to be for one or two dwellings at a time.

21.6 Options

Do not set a water efficiency standard – the default would be 125 l/h/d.
Continue the current policy approach of 110 l/h/d
Investigate whether it is reasonable or justifiable to seek a standard that designs for less water a day than 110 l/h/d.
Investigate the potential to require water neutrality.

Question 24: Do you have any thoughts on the issues of water efficiency and the options listed above?