Representation by Anglian Water Services (Anglian Water Services)
- Date submitted
- 12 June 2024
- Submitted by
- Other statutory consultees
Outer Dowsing - Anglian Water Relevant Representation (dated 12/06/24) Anglian Water (AW) is the statutory water and wastewater services provider for the proposed Outer Dowsing project order limits. AW has engaged with Total Energies and Corio Generation (the Applicant) and there are on-going discussions regarding the interfaces between the project and our assets. Interfaces between the project and AW assets (underground and surface assets) AW owns and operates the water supply and sewerage infrastructure within the project area. In locations where the project intersects with AW assets, their protection and continuity of water and water recycling services to customers will be required. Through pre-submission discussions with the Applicant, a set of Protective Provisions has been agreed between both parties. A copy is included of the ‘Draft Development Consent Order’ (document ref. 3.1) Schedule 18, Part 3 For Protection of Anglian Water Services Limited. The AW existing assets identified within the application boundary are identified in the Book of Reference (document ref. 4.1, also covering the details set out in the Onshore Crossing Schedule (document ref. 6.3.3.2). Discussions are taking place between AW and the Applicant on these aspects to confirm, for example, any sensitive plant, open cut locations, access works, likely diversions any above ground plant and shared access locations. These documents will need to be amended accordingly as these matters are agreed. Our intention is that agreement on these Protective Provisions and other matters will be covered by the bilateral Statement of Common Ground which is being progressed. Water supply and water recycling services Water supply AW understands that the Outer Dowsing project will require some water supply for the construction, operation or decommissioning stages of the project. This could be either on a temporary or more permanent basis. The documents submitted with this application state that there will be different requirements for water supply, for example: 1) Project Description: Chapter 3 (document ref. 6.3.3.2) ? Section 8.2.3, para 274, page 104 - for onshore side enabling works services such as water, will be required to support the day-to-day activities. These services are intended to be obtained from a connection to nearby infrastructure or through self-sufficient means. ? Section 9.2.3.3, para. 313, page 113 - for the onshore sub-station potable water will be required at the site for sanitary and mess facilities. This could be obtained from the local water supply utility company. 2) Outline Construction Traffic Management Plan (document ref. 8.1.5) Section 3.2.9, paras. 41 and 64 - refers to a wheel and body wash would be operated at each construction access or haul road crossing. There would also be on-site haul roads dust suppression and water bowsers. The Applicant has been advised of the process to engage with AW regarding water supply require-ments. Further advice on water and wastewater capacity and options can be obtained by contacting AW’s Pre-Development Team (planningliasion@anglianwater.co.uk). As a commercial project if there is a requirement for significant supplies of potable or raw water either for the construction or opera-tional stages AW’s Wholesale services department may be contacted via wsc@anglianwater.co.uk to assist in scoping out options for assessment. In June 2023, AW published a position statement on non-domestic water demands. In summary, this advises that where a request for a new or increased non-domestic water demand may compromise AW’s ability to supply existing and forecast new domestic customers that request is likely to be declined. New water demand requests are currently assessed on a first come, first served and then connected basis and requests are not prioritised based on national policy such as the net zero transition or through cumulative assessment of the impacts and benefits of projects. To support appropriate water resource planning, AW now requires that significant new non-domestic water demands are set out in a Water Resources Assessment (WRA). For applications under the 2008 Act the WRA (or a summary of the WRA) will form part of the Environmental Impact Assessment sufficient to enable regulators including the Environment Agency to advise the Examining Authority and the Secretary of State that the supply of water to the project is potentially deliverable and sustainable. AW requests that the Applicant, provide updates for the Examination and Secretary of State on the project’s water demand calculations. Water recycling The Applicant should confirm if any mains connected foul water drainage systems are likely to be necessary for the different project stages. The document Project Description: Chapter 3 (document ref. 6.3.3.2) states that waste from the onshore sub-station toilets/ cleaning facilities are intended to be discharged to a local sewer/ septic tank. Details on the process for engaging with AW have been provided to the Applicant. Flooding and surface water The submitted outline Surface Water Drainage Strategy (SWDS) (document ref. 8.1.5) states in Section 2 ‘Surface Water Principles’ that the SWDS will be developed according to the principles of the SuDS discharge hierarchy. Generally, the aim will be to discharge surface water runoff as high up the following hierarchy of drainage options as reasonably practicable: ? Into the ground (infiltration); ? To a surface waterbody; ? To a surface water sewer, highway drain or another drainage system; or ? To a combined sewer. It is noted that the final SWDS is expected to maintain the existing drainage to and from surrounding land and reduce the risk of any increase in surface water flood risk to off-site areas. Development of the strategy will include an assessment of the current and proposed runoff rates, volume of storage required, and the proposed approach for discharge of water from each work location. If this requires consideration of the use of the public sewer network to manage additional surface water flows, AW will require it to be included as a consultee to the drainage strategy, including the relevant DCO Order for any discharge of requirements in relation to drainage plans and surface water discharge. Construction Traffic Management Plan (CTMP) We welcome the submission of an outline CTMP and note that the preferred location of haul road crossings within the onshore cable corridor listed in Table 3.3, will need to be discussed and agreed with the local highway authority as part of the final CTMP. The final version should include steps to remove the risk of damage to any of AW’s assets from plant and machinery (compaction and vibration during the construction phase) including any haul and access roads and crossings.