Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 13785

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14305
Thank you for your consultation seeking the views of United Utilities Water Limited (UUW) as part of the Local Plan process. UUW wishes to build a strong partnership with all local planning authorities (LPAs) to aid sustainable development and growth within its area of operation. We aim to proactively identify future development needs and share our information. This helps: - ensure a strong connection between development and infrastructure planning; - deliver sound planning strategies; and - inform our future infrastructure investment submissions for determination by our regulator. UUW wishes to highlight the benefit of early, constructive communication with the Council and site promoters to ensure a co-ordinated approach to the delivery of sustainable growth in sustainable locations. When preparing the local plan, new development should be focused in sustainable locations which are accessible to local services and infrastructure. We can most appropriately manage the impact of development on our infrastructure if development is identified in locations where infrastructure is available with existing capacity. We encourage you to direct future developers to our pre-application service to discuss their schemes and highlight any potential issues by contacting: Developer Services – Wastewater Tel: 03456 723 723 Email: SewerAdoptions@uuplc.co.uk Developer Services – Water Tel: 0345 072 6067 Email: DeveloperServicesWater@uuplc.co.uk To supplement this response, we have enclosed an appendix that provides supporting information and example policy wording for you to consider when preparing your new local plan. We have also enclosed evidence to support the implementation of the tighter standard for water efficiency. We would welcome the opportunity to provide our comments on any sites that are suggested to you as potential development sites when available. We are keen to undertake an initial assessment so that this can be fed into your site assessment process and to ensure that any flood risks from our assets are reflected in your Strategic Flood Risk Assessment. Please ensure that you have regard to the main body of the letter and the associated supporting information, which includes recommended policies. Moving forward, we respectfully request that the Council continues to consult with UUW for all future planning documents.

Comment

Representation ID: 13786

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14306
Spatial Strategy We request that sustainability is a ‘golden thread’ running through the local plan strategy. Noting the nature of this consultation, we do not have the information that we require on potential allocations in order to be able to begin to initially assess the potential cumulative impact on our water and wastewater infrastructure in any settlement. We wish to note that smaller settlements are often supported by infrastructure which is proportionate to their size, often in rural locations. UUW wishes to highlight that disproportionate growth in any settlement, especially small settlements, has the potential to place a strain on existing water and wastewater infrastructure. Therefore, when considering your spatial strategy options, we recommend that any strategy which you bring forward delivers growth that is proportionate to the size of each settlement. With regards to growth in all settlements, UUW requests information on anticipated delivery rates as soon as they become available. We would welcome sight of a housing trajectory in a GIS format. If you are to pursue a new settlement or a major urban extension, this will need careful consideration and a co-ordinated approach to delivery. If this evolves into your preferred strategy, we would welcome early discussion given our experiences in the wider region where a new settlement is being promoted.

Comment

Representation ID: 13787

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14307
Investment in Future Infrastructure Investment associated with our water and wastewater infrastructure is influenced by a number of drivers including the construction of new facilities to take account of new environmental requirements, growth, the need to respond to the carbon challenge, or the need to invest in new updated infrastructure. In our current investment period (2025-30), we are proposing the biggest investment in water and wastewater services across the North West in over 100 years. The total expenditure by UUW for the period 2025-2030 is approximately £13 billion. This includes various enhancements and improvements to infrastructure, resilience, and environmental standards The drivers for investment include the Environment Act 2021, which has set a requirement to progressively reduce storm spills into the environment. Such investment will be constrained by engineering circumstances to determine the most appropriate location for additional storage to reduce spills. This may necessitate investment in constrained locations in our urban and rural environments such as in/on land in protected locations (green belt, local green space and open countryside). Consistent with meeting this obligation, UUW requests that the future local plan includes support for investment in water and wastewater infrastructure that is ultimately beneficial to the environment, biodiversity and our watercourses so it can be delivered in the most timely and effective manner. Specifically, we request that policy supports investment in our infrastructure in constrained locations such as local green space, open countryside and green belt. With regard to sites which may be situated in the Green Belt, National policy within the NPPF allows for: the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; limited infilling or the partial or complete redevelopment of previously developed land (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not cause substantial harm to the openness of the green belt; and the development of grey belt land. On this basis, National Policy is broadly supportive of investment at existing operational sites in the Green Belt. However, we ask for this to be specifically referred to in your future planning policies. UUW requests the’s support for investment in infrastructure in order to be able to expeditiously respond to the needs of the borough. The following policy wording is recommended: [See attached wording] In relation to existing water and wastewater infrastructure sites, we request that these are identified on your proposals map and covered by the following policy.  [See attached wording] We can provide plans of sites which are located in open countryside / green belt by separate cover. We request that such sites are specifically identified on the proposals map where investment in future water and wastewater needs would be acceptable. These policies would enable us to ensure we can continue to meet the growth and development aspirations of the borough, and current / future environmental drivers.

Comment

Representation ID: 13788

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14308
Our Assets It is important to outline to the local planning authority (LPA) the need for our assets to be fully considered in development proposals. We will not permit development over or in close proximity to our assets . Our assets will need to be afforded access for maintenance, repair and replacement and be fully considered in the design and masterplanning process for a site. This should include careful consideration of landscaping proposals in the vicinity of our assets and any changes in levels. We strongly recommend that the LPA advises future applicants of the importance of fully understanding site constraints as soon as possible, ideally before any land transaction is negotiated, so that the implications of our assets on development can be fully understood. Where our assets exist on a site, we ask site promoters to contact UUW to understand any implications using the above contact details.  Please note: UUW will not allow building over or in close proximity to a water main. UUW will not allow a new building to be erected over or in close proximity to a public sewer or any other wastewater pipeline. This will only be reviewed in exceptional circumstances. Site promoters should not assume that our assets can be diverted. On occasion, an asset protection matter within a site can preclude delivery.

Comment

Representation ID: 13789

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14309
Site-Specific Policies for Allocations When considering the format of your emerging development plan, we request that your site allocations are guided by detailed site-specific policies / site-specific development requirements. This can be critical to ensuring that the issues which are identified via the site selection process are clear to applicants. When you have sites available for assessment, UUW will be able to highlight any issues for consideration as part of an initial site assessment. For example, large on-site infrastructure which is material to site layout, or the location of a site in a groundwater source protection zone, which may mean that a site needs to be further assessed so that any potential impact on the groundwater environment and public water supply can be appropriately reduced / mitigated. We believe that the identification of such site-specific constraints is critical and therefore, we recommend that your development plan includes these details as site-specific policy / development considerations for all new allocations. UUW also wishes to note a preference to see specific allocations identified as part of the new local plan in preference to a reliance on windfall sites. This helps to add certainty for infrastructure providers.

Comment

Representation ID: 13790

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14310
Our Assets It is important to outline to the local planning authority (LPA) the need for our assets to be fully considered in development proposals. We will not permit development over or in close proximity to our assets . Our assets will need to be afforded access for maintenance, repair and replacement and be fully considered in the design and masterplanning process for a site. This should include careful consideration of landscaping proposals in the vicinity of our assets and any changes in levels. We strongly recommend that the LPA advises future applicants of the importance of fully understanding site constraints as soon as possible, ideally before any land transaction is negotiated, so that the implications of our assets on development can be fully understood. Where our assets exist on a site, we ask site promoters to contact UUW to understand any implications using the above contact details.  Please note: UUW will not allow building over or in close proximity to a water main. UUW will not allow a new building to be erected over or in close proximity to a public sewer or any other wastewater pipeline. This will only be reviewed in exceptional circumstances. Site promoters should not assume that our assets can be diverted. On occasion, an asset protection matter within a site can preclude delivery.

Comment

Representation ID: 13791

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14311
Co-ordinated Infrastructure Provision We wish to note that any growth needs to be carefully planned to ensure new infrastructure provision does not cause any unexpected delays to development delivery. The full detail of the development proposals are not yet known. For example, the detail of the drainage proposals, the points of connection or the water supply requirements. As a result, it is important that we highlight that in the absence of such detail, we cannot fully conclude the impact on our infrastructure over a number of 5-year investment periods and therefore as more detail becomes available, it may be necessary to co-ordinate the timing for the delivery of development with the timing for delivery of infrastructure. Once more information is available with respect to specific development sites, which is often only at the planning application stage, we will be able to better understand the potential impacts of development on infrastructure and, as a result, it may be necessary to coordinate the delivery of development with the timing for the delivery of infrastructure improvements. We recommend that you include a development management policy in your draft plan to this effect. Our recommended policy is below  [See attached wording].

Comment

Representation ID: 13792

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14312
Sites in Multiple Ownership UUW has concerns regarding any site allocations which are in multiple land ownerships. The experience of UUW is that where sites are in multiple ownership, the achievement of sustainable development can be compromised by developers/applicants working independently. We therefore encourage you to make early contact with all landowners/site promoters and challenge those landowners on how they intend to work together, preferably as part of a legally binding delivery framework and/or masterplan. You should give early consideration to the extent to which land ownership is fragmented on sites and whether this will be likely to compromise a co-ordinated approach to the delivery of sustainable development. We believe that raising this point at this early stage is in the best interest of achieving challenging delivery targets from allocated sites in the most sustainable and co-ordinated manner. We recommend that future policy requires applicants to provide drainage strategies for foul and surface water. For larger sites, we recommend that policy requires applicants to prepare an infrastructure phasing and delivery strategy. For strategic sites, we recommend that early consideration is given to the infrastructure strategy as part of the preparation of the local plan and to ensure a co-ordinated approach to the delivery of new development and infrastructure. We would recommend the following policy is considered for inclusion in any future local plan: [See attached wording].

Comment

Representation ID: 13793

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14313
Climate Change Policy UUW wishes to highlight its support for any climate change policy. Sustainable surface water management and the efficient use of water must be critical elements of any such policy. We also encourage the policy on climate change to be intrinsically linked to wider policies in the local plan including those relating to the detailed design of new developments and the provision of green and blue infrastructure. We are keen to ensure that any climate change policy gives appropriate emphasis to green and blue infrastructure, natural flood management techniques, multi-functional sustainable drainage, designing new development so that it is resilient to the challenges of future climate change and the incorporation of water supply efficiency measures. As the LPA will be aware, green infrastructure can help to mitigate the impacts of high temperatures, combat emissions, maintain or enhance biodiversity and reduce flood risk. Green / blue infrastructure and landscape provision play an important role in managing water close to its source. If the necessary link between green/blue infrastructure, surface water management and landscape design is outlined as a strategic requirement, it will help ensure that sustainable surface water management is at the forefront of the design process.

Comment

Representation ID: 13794

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14314
Climate Change Policy UUW wishes to highlight its support for any climate change policy. Sustainable surface water management and the efficient use of water must be critical elements of any such policy. We also encourage the policy on climate change to be intrinsically linked to wider policies in the local plan including those relating to the detailed design of new developments and the provision of green and blue infrastructure. We are keen to ensure that any climate change policy gives appropriate emphasis to green and blue infrastructure, natural flood management techniques, multi-functional sustainable drainage, designing new development so that it is resilient to the challenges of future climate change and the incorporation of water supply efficiency measures. As the LPA will be aware, green infrastructure can help to mitigate the impacts of high temperatures, combat emissions, maintain or enhance biodiversity and reduce flood risk. Green / blue infrastructure and landscape provision play an important role in managing water close to its source. If the necessary link between green/blue infrastructure, surface water management and landscape design is outlined as a strategic requirement, it will help ensure that sustainable surface water management is at the forefront of the design process.