*This is what I sent to the Secretary of State for Infrastructure (his copy)* Dear Welwyn Hatfield Councillors, *(I have removed 2 names here)*. Please read for yourselves why Panshanger cant be built on or put in the local plan; Panshanger needs this truth to come out! Please read the 2009 WCS own Recommendations below and then compare them to my findings following them from the same WCS and responses from the water company. I then ask you to vote against any development of Panshanger Aerodrome & Hilly Fields in Welwyn Garden City, Hertfordshire. A copy of this letter is sent to the Secretary of State for Infrastructure. Recommendations - 2009 WCS, page 139. Following the completion of this WCS, the following recommendations are made regarding policies and further studies: Developers, water companies and Local Authorities should use this WCS report (and associated guidance) as a tool to inform their existing and future decisions and policies, to ensure that new development and major water infrastructure upgrades are in accordance with the strategy suggested herein; The Local Authorities and water companies should consult with national and regional government (including Ofwat) to ensure that the current economic climate does not constrain growth plans, and that appropriate funds for water infrastructure improvements continue to be made available as highlighted in this WCS report and water company business plans. The significant lead in time involved in planning, securing funds, designing and construction of substantial water infrastructure upgrades within the Rye Meads catchment should be factored in to deliver the ambitious RSS targets within the Rye Meads catchment, which clearly highlights the need for making timely decisions throughout this process; TWU have advised that if appropriate funds are not allocated by Ofwat in PR09 for the required infrastructure upgrades due to the current uncertainty in the housing market then it is strongly recommended that TWU, at their discretion, consider making an interim submission to Ofwat ahead of the PR14 process when the rate of economic recovery is better understood. This will reduce the lead time associated with the planning and delivery of major infrastructure and ensure that growth plans are not further constrained due to lack of infrastructure. Key to the success of this recommendation will be documented support to Ofwat from the relevant LA; Detailed assessments for Stevenage and Harlow sewerage upgrades and increasing Rye Meads treatment capacity should commence soon after the publication of the WCS report; In addition, a detailed assessment of the Beane WwTW and Anglian upgrade options should be undertaken to quantify the economic, social and environmental benefits and costs of such solutions, to ensure the most sustainable long term solution is achieved for collection and wastewater treatment. This will require the input of the EA, TWU, TVW, and AWS, to determine the most sustainable balance between river flows, abstraction, water quality and ecology that best suits the needs of society and the environment (see below); Further assessment of the implications of the WFD, the actions that emerge from the finalised RBMP and what these mean for the forward planning of AWS, TVW and TWU will be required. Water companies should continue to actively engage with the EA during RBMP consultation periods and when implementing the resultant programme of measures; Surface Water Management Plans should be completed by SBC, HDC and EHDC to further understand and mitigate against flood risk from surface water; and Green Infrastructure Strategies should form part of the Local Authorities’ LDFs, to investigate and identify opportunities to enhance the biodiversity of the water (and wider) environment across the entire study area. SUDS design should be linked to these strategies to create an integrated network of flood risk mitigation, pollution control and biodiversity enhancement. Rye Meads Water Cycle Strategy - Detailed Study Report Whilst this WCS satisfies the original brief that was primarily originated as a requirement of the RSS, further work is required to ensure the optimum combination of development and environmental protection/ climate change resilience in the long-term and to provide the additional detailed evidence base for the preparation of ongoing and future LDF documents. The required involvement of the stakeholders in this work is displayed in Table 10-33 below. This table highlights the recommended indicative dates by which these important studies should be completed, and suggests the possible consequences of any delays. A part of this work should be undertaken immediately through independent / parallel studies funded by the WCS stakeholders. The work regarding wastewater treatment options should consider that all current and future wastewater discharges from the Harlow area would be treated at Rye Meads WwTW. Thames Water should conduct a detailed cost benefit analysis for both the likely upgrades to the sewerage network from Stevenage to Rye Meads and a new WwTW on the Beane Valley. Thames Water, in close consultation with the Environment Agency, should also assess the water quality, flood risk and ecological effects of any increase in discharge from Rye Meads on the water environment and how to mitigate such impacts. Anglian Water should also work together with the Environment Agency to conduct a similar study to assess the suitability of the Anglian Hybrid Option. The water companies, in consultation with WCS stakeholders, should then determine the most sustainable and cost effective long-term solution for the collection and treatment of wastewater in the Stevenage and North Herts area. The process of identifying this solution must be transparent, and should also maintain the presence of a third party in order to clearly demonstrate that it is not anticompetitive in any way. Planning applications and/ or permissions for large scale strategic developments are likely in the Stevenage area within the next year, so the detailed or initial feasibility stages of the above work should be carried out within the next 9 to 12 months subject to development locations, dwelling numbers and likely phasing being confirmed by Stevenage Borough Council. In any case, it is important to consolidate this work and present the key outcomes so that it can be easily understood and used as an evidence base to inform the preparation of the ongoing and future LDF documents, and associated infrastructure investment strategies. Therefore, a full review of this WCS is recommended within the next four years. .......................................................................................... My Findings & Responses, see below; .......................................................................................... A rough calculation, assuming an average occupancy rate for the seven Local Authorities of 2.35 weighted by the proportion of remaining RSS allocations for each council, equates this 15,000 PE capacity to around 6,400 homes. *Please note, this point refers to the whole catchment area of 7 boroughs, but there are now 8, not Welwyn Garden City alone. Dean McBride* This assumes that none of the remaining capacity is taken up by an increase in infiltration or additional trade flows. Based on the predicted completion rates (within the Rye Meads catchment, see Appendix E), this equates to less than 4 years worth of residential development. However, by optimising the operational procedures at the WwTW the existing treatment capacity may be able to be extended further. *see my point above* However, it is imperative that TWU are successful in securing funds for capacity upgrades at Rye Meads in AMP5/ 6 to avoid the treatment capacity of the WwTW significantly constraining development. The sewerage network serving the Rye Meads catchment is known to be close to capacity at a number of locations such as in and around Stevenage and Harlow. Also, there is some concern from the WCS stakeholders that solely relying on the wastewater treatment at Rye Meads WwTW is not the most sustainable solution in the long term, especially given the low flow issues in the upper reaches of the rivers in this catchment. This option will also require widespread network upgrades, with the associated social, economical and environmental costs, to solve local capacity issues. In order to convey the wastewater to Rye Meads WwTW, upgrades will be needed to the existing sewerage network. Upgrading the existing WwTW, and associated sewerage network, has been selected as a potential solution because it: _ Allows some development to be connected in the short to medium term; _ Will require a shorter planning period than a new WwTW; _ Does not rely on suitable land becoming available to either TWU or AWS; and _ Utilises an existing discharge consent, which provides more certainty when compared with other options. As the discharge flow from Rye Meads WwTW approaches its consented volumetric limit, and given the implications of climate change, there is a risk that the backing up will occur more frequently and with higher severity. 7.4 Preferred Strategy Conclusion The issue of collecting and treating wastewater from the Stevenage development has been a key concern of all WCS stakeholders as it has a significant influence on the overall catchment, including a number of cross-boundary issues. Upgrades to the Rye Meads network and WwTW are unavoidable, and for the majority of the Local Authorities there are no viable alternatives to this, except developing in other catchments. Stevenage is a special case with several cross-boundary issues, and presents the WCS stakeholders with an opportunity to change the current system. 8.2 Wastewater Treatment and Sewerage network The provision of wastewater treatment and sewerage has been identified as a key constraint throughout this WCS. Following the option development process in Sections 6 and 7, it is recommended that the upgrades of the Rye Meads WwTW and sewerage network proposed by TWU are further assessed and constructed without delay. East of England Plan Policy WAT2 1.1 Considerable obstacles exist in terms of delivering a satisfactory quality of water and sewerage according Policy WAT2 1.1.1 “In parts of the region, existing waste water treatment infrastructure (sewage treatment works and the associated pipe network) operate at the limits of their current discharge consents.”[1] 1.2 No evidence has been provided that the BLG1 / WGC4 site has the necessary water treatment infrastructure to be able to handle an additional 700 homes, or that capacity could be raised in order to support this development, without harming the areas mentioned in section 10.8 of the East of England Plan. ...................................................................................................... And some answers to my questions from the water company; ....................................................................................................... 1/ Is there a Direct Connection to the Southern Outfall’ at Rye Meads? There is no Southern outfall at Rye Meads so there is no proposal for a direct connection to the Southern outfall at Rye Meads. The Southern outfall is at Welwyn Garden City. 2/ It said in the 2009 WCS that It would be better for local authorities to build in other catchment areas. The response to this question was: The comment regarding building in other catchments was targeted towards growth proposals in North Herts District and Stevenage Borough where there was the “option” for draining new development flows to either Anglian Water STW’s or Thames Water STW’s. It was the long lengths of potential upgrades to the existing Thames Water sewers that drove this comment. a/ Can you please tell me what is the ‘Per Capita Consumption’ rates (percentage in addition to the established flows) in the North Herts District and Stevenage Borough since 2009? Clean water for these areas is not supplied by Thames Water so we cannot provide this information. The latest pcc used by Thames Water to estimate flows was 157.6l/hd/d. This is a guideline for estimating future short and long-term flows into Rye Meads STW but our monitoring of performance and decisions on whether to upgrade Rye Meads STW is based solely on records of flows that are actually processed through the STW. b/ Can you please tell me what percentage of these New Development Flows had drainage diverted to Anglian Water STW & Thames Water STW since 2009, to present? No flows have been diverted. If the developments are Anglian Waters side of the boundary they take them into their sewers, If they are our side of the boundary we take them into ours. Diverting Anglian Water flows into Thames Water sewers is an option for the future driven by the scale of developments that may be undertaken in the Anglian Water area. Until the actual development sites in Stevenage and North Herts are confirmed by the planners and the developers announce their drainage strategies for those sites we cannot begin to assess the impact and plan any upgrades. c/ Have the ‘Thames Water Sewers’ been upgraded since this comment in 2008/9 was made? No 3/ How Many Boroughs currently have flows going to Rye Meads WwTw? Some or all of the following Boroughs/Districts drain to Rye Meads STW. Harlow District, Broxbourne Borough, Epping Forest District, Uttlesford District, East Herts District, Stevenage Borough, North Herts District and Welwyn Hatfield District. *That’s 8 boroughs, 1 more since 2009* And the following came after I put together my report on the WCS Report; 4/ Dear Mr McBride Thank you for your patience regarding this matter. Please find response to your enquiry from our Asset Management Team below: The 6,400 new dwellings/homes figure refers to the whole of the Rye Meads catchment.’ Kind Regards, Dean McBride Panshanger Resident.
Posted on: Mon, 08 Sep 2014 19:39:55 +0000