Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 11983

Received: 28/08/2025

Respondent: Welsh Water

I&O_12497
We note that the suggested policy approach is to plan for the delivery of a minimum of 1,914 new homes each year with 3 options (A, B & C) under consideration regarding how best to spatially distribute this growth. To ensure development is deliverable it is essential that there is adequate sewerage infrastructure.  Welsh Water’s capital investment is undertaken through a five-yearly Asset Management Plan (AMP) programme.  The AMP8 programme is currently being delivered which covers investment for the period 2025-30, this will be followed by AMP9 for 2030-2035, AMP10 for 2035-2040 etc.  Funding for capital investment is raised through customers’ bills. We aim to ensure that sufficient infrastructure exists for domestic development, and we seek to address deficiencies through capital investment in our AMP.  We must put forward a business plan for investment for each AMP cycle, and to ensure that customer’s money is invested appropriately we require some certainty in terms of growth areas and site development proposals.  An adopted Local Plan with allocated growth helps strengthen the case Welsh Water can put forward to our regulator Ofwat in relation to projects requiring AMP funding.  The Local Plan is anticipated to have a 15-year timeframe therefore any infrastructure investment required at our Wastewater Treatment Works (WwTWs) can be considered for delivery in future AMPs.  The impact of new housing on our sewerage networks will be dependent on the spatial distribution of this proposed growth, and the impact of development on our Wastewater Treatment Works (WwTW) will be dependent on the amount of growth within their catchment areas.  Where the total growth identified exceeds the theoretical design capacity of our WwTWs then reinforcements to provide further capacity will be required during the Local Plan period.

Comment

Representation ID: 11985

Received: 28/08/2025

Respondent: Welsh Water

I&O_12499
We note that the suggested policy approach is to plan for the delivery of a minimum of 1,914 new homes each year with 3 options (A, B & C) under consideration regarding how best to spatially distribute this growth. To ensure development is deliverable it is essential that there is adequate sewerage infrastructure.  Welsh Water’s capital investment is undertaken through a five-yearly Asset Management Plan (AMP) programme.  The AMP8 programme is currently being delivered which covers investment for the period 2025-30, this will be followed by AMP9 for 2030-2035, AMP10 for 2035-2040 etc.  Funding for capital investment is raised through customers’ bills. We aim to ensure that sufficient infrastructure exists for domestic development, and we seek to address deficiencies through capital investment in our AMP.  We must put forward a business plan for investment for each AMP cycle, and to ensure that customer’s money is invested appropriately we require some certainty in terms of growth areas and site development proposals.  An adopted Local Plan with allocated growth helps strengthen the case Welsh Water can put forward to our regulator Ofwat in relation to projects requiring AMP funding.  The Local Plan is anticipated to have a 15-year timeframe therefore any infrastructure investment required at our Wastewater Treatment Works (WwTWs) can be considered for delivery in future AMPs.  The impact of new housing on our sewerage networks will be dependent on the spatial distribution of this proposed growth, and the impact of development on our Wastewater Treatment Works (WwTW) will be dependent on the amount of growth within their catchment areas.  Where the total growth identified exceeds the theoretical design capacity of our WwTWs then reinforcements to provide further capacity will be required during the Local Plan period.

Comment

Representation ID: 11986

Received: 28/08/2025

Respondent: Welsh Water

I&O_12500
Welsh Water is the statutory sewerage undertaker for parts of Cheshire West & Chester, the main settlements that we serve are  Chester Neston & Parkgate Tattenhall Farndon, and Malpas. At this early stage of the Local Plan process, without knowing the level of growth in each settlement and the specific location of proposed development sites, we will not be able to accurately assess the capability of our WwTWs to accommodate proposed growth.  Nonetheless, we acknowledge that the inclusion of potential growth areas within this Issues and Options consultation are currently illustrative only and does not indicate that the Council supports their development. The amount of residential and employment growth that is under consideration for these settlements are substantial and where the total growth identified exceeds the theoretical design capacity of our WwTWs then reinforcements to provide further capacity will be required during the Local Plan period.  Where specific infrastructure reinforcements are required to bring a development site forward in advance of any investment at our WwTWs through the AMP there are provisions available for developers to make financial contributions to deliver the necessary works subject to the outcome of a Developer Impact Assessment (DIA). Given the potential number of new homes that could be allocated within our WwTW catchment areas we welcome early dialogue regarding the options.  Each of the options being considered will have a different impact on our assets. Option A – Retain the Green Belt Growth around Tattenhall, Malpas and Farndon. Option B – Follow current Local Plan level and distribution of development Large urban extension around Chester, limited development at Farndon, Malpas, Neston & Parkgate, and Tattenhall. Option C – Sustainable Transport Corridor Modest urban expansion of Chester, with Neston & Parkgate taking a bigger role in accommodating development.  Potential for further development in Farndon, Malpas and Tattenhall. In terms of making best use of existing WwTW capacity, Chester WwTW is best placed to accept strategic growth.  Whilst there is some capacity available at Malpas, Neston, Tattenhall and Farndon WwTWs, these treatment works are sized according to the settlements that they serve, therefore substantial growth at these settlements will exceed the available capacity at the WwTWs. 

Comment

Representation ID: 11990

Received: 28/08/2025

Respondent: Welsh Water

I&O_12504
Once sites are identified we will be able to determine whether there is sufficient capacity within the sewerage network to accommodate the growth proposed.  Hydraulic Modelling Assessments (HMAs) may be required to determine an adequate point of connection to the public sewer and developers would be strongly recommended to fund investigations during pre-planning stages.  The findings of a hydraulic modelling assessment would identify the extent of any necessary reinforcement to the network which can be requisitioned through the provisions of the Water Industry Act 1991 (as amended).

Comment

Representation ID: 11993

Received: 28/08/2025

Respondent: Welsh Water

I&O_12507
We note that the suggested policy approach is to plan for the delivery of a minimum of 9.9 hectares of employment land each year, over the plan period.  The capability of Welsh Water’s infrastructure to service future employment allocations will be assessed when the potential demand on our infrastructure is known.  Should any proposal require to discharge trade effluent into the public sewer then the consent of the statutory sewerage undertaker is required (Section 118 Water Industry Act 1991).  Additionally, dependant on the processes involved, an element of pre-treatment may also be required.

Comment

Representation ID: 11995

Received: 28/08/2025

Respondent: Welsh Water

I&O_12509
We note that the suggested policy approach is to plan for the delivery of a minimum of 9.9 hectares of employment land each year, over the plan period.  The capability of Welsh Water’s infrastructure to service future employment allocations will be assessed when the potential demand on our infrastructure is known.  Should any proposal require to discharge trade effluent into the public sewer then the consent of the statutory sewerage undertaker is required (Section 118 Water Industry Act 1991).  Additionally, dependant on the processes involved, an element of pre-treatment may also be required.

Comment

Representation ID: 11996

Received: 28/08/2025

Respondent: Welsh Water

I&O_12510
We support the provision within the supporting text of policy approach ID 1 which highlights that developers will be expected to fund any shortfall in infrastructure provision to sustain a new development site.  Where existing infrastructure is inadequate to serve the development, new or improved infrastructure must be provided to mitigate any adverse impacts.  In circumstances where the development generates the need for infrastructure reinforcements that are not programmed for delivery by infrastructure providers then it must be funded by the development, and appropriate contributions may be sought for sewerage infrastructure.  We note and support that it is proposed to strengthen existing policy STRAT11 to include greater environmental protection and to recognise the infrastructure needs of water and sewerage providers.   We also support the approach set out in policy FW1 that current policy requirements to ensure that development proposals do not have an unacceptable impact on wastewater infrastructure capacity will be retained.

Comment

Representation ID: 11998

Received: 28/08/2025

Respondent: Welsh Water

I&O_12512
We support the provision within the supporting text of policy approach ID 1 which highlights that developers will be expected to fund any shortfall in infrastructure provision to sustain a new development site.  Where existing infrastructure is inadequate to serve the development, new or improved infrastructure must be provided to mitigate any adverse impacts.  In circumstances where the development generates the need for infrastructure reinforcements that are not programmed for delivery by infrastructure providers then it must be funded by the development, and appropriate contributions may be sought for sewerage infrastructure.  We note and support that it is proposed to strengthen existing policy STRAT11 to include greater environmental protection and to recognise the infrastructure needs of water and sewerage providers.   We also support the approach set out in policy FW1 that current policy requirements to ensure that development proposals do not have an unacceptable impact on wastewater infrastructure capacity will be retained.

Comment

Representation ID: 12000

Received: 28/08/2025

Respondent: Welsh Water

I&O_12514
We are pleased that both SD1 ‘Sustainable Development’ and FW 1 ‘Flood risk and water management’, in conjunction with the Council’s Surface water management and SuDS guidance, highlight the importance of incorporating Sustainable Drainage Systems (SuDS) into the design of schemes.  In addition, we welcome the approach to amend Policy DM 41 to remove reference to the requirement for SuDS on major development sites only.  Managing surface water in a sustainable manner protects the environment, minimises pollution from surface water runoff and assists in ensuring that there is sufficient capacity available in the public sewerage network for foul-only sewage flows arising from development sites.  

Comment

Representation ID: 12002

Received: 28/08/2025

Respondent: Welsh Water

I&O_12516
We are pleased that both SD1 ‘Sustainable Development’ and FW 1 ‘Flood risk and water management’, in conjunction with the Council’s Surface water management and SuDS guidance, highlight the importance of incorporating Sustainable Drainage Systems (SuDS) into the design of schemes.  In addition, we welcome the approach to amend Policy DM 41 to remove reference to the requirement for SuDS on major development sites only.  Managing surface water in a sustainable manner protects the environment, minimises pollution from surface water runoff and assists in ensuring that there is sufficient capacity available in the public sewerage network for foul-only sewage flows arising from development sites.