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Babergh Water Cycle Study Stage1/2

Babergh District Council

July 2011 Final Report v2 9V9327

  

     

5th Floor, Radcliffe House Blenheim Court Solihull B91 2AA +44 (0)121 709 6520 Telephone Fax [email protected] E-mail www.royalhaskoning.com Internet

Document title Babergh Water Cycle Study Stage1/2 Document short title Babergh WCS Status Final Report v2 Date July 2011 Project name Babergh Water Cycle Study Project number 9V9327 Client Council Reference 9V9327/R00003/303671/Soli

Drafted by R Ranger

Checked by F Ogunyoye Date/initials check 27th June 2011 Approved by F Ogunyoye Date/initials approval 27th June 2011

CONTENTS

Page

1 INTRODUCTION 1 1.1 General Overview 1 1.2 Scope 1 1.3 Objectives of the Water Cycle Study 2 1.4 Guidance on the use of this Study 2

2 DATA COLLECTION AND METHODOLOGY 5 2.1 Overview 5 2.2 Data Collection 5 2.3 Housing and Employment Growth 6 2.4 Water Resources and Supply 9 2.5 Wastewater Treatment and Collection 15 2.6 Water Quality and the Environment 19 2.7 Flood Risk 26 2.8 Demand Management and SUDS 29 2.9 Data Limitations 32

3 GROWTH OPTION 1: CURRENT SITUATION 33 3.1 Introduction 33 3.2 Water Resources and Supply 33 3.3 Wastewater Treatment and Collection 33 3.4 Water Quality and the Environment 36 3.5 Flood Risk 42 3.6 Demand Management and SUDS 45 3.7 Summary 49

4 OPTIONS FOR GROWTH 51 4.1 Introduction 51 4.2 Water Resources and Supply 51 4.3 Wastewater Treatment and Collection 55 4.4 Water Quality and the Environment 65 4.5 Flood Risk 68 4.6 Demand Management and SUDS 75 4.7 Summary 75

5 GROWTH OPTION 5: MAXIMUM CAPACITY 79 5.1 Water Resources and Supply 79 5.2 Wastewater Treatment and Collection 80 5.3 Water Quality and the Environment 82 5.4 Flood Risk 83 5.5 Demand Management and SUDS 84 5.6 Summary 85

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6 CONSTRAINTS MATRIX AND CONCLUSIONS 87 6.1 Development Location Specific Conclusions and Timelines 87 6.2 Recommendations 93 6.3 Future Updates 94

7 GUIDANCE DOCUMENTS 95 7.1 Flood Risk 95 7.2 Demand Management 97 7.3 SUDS 99 7.4 Developer Contributions 109 7.5 Water Industry Funding 114

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APPENDICES

Appendix A - Figures Appendix B - Data Register Appendix C - Growth Trajectories Appendix D - RBMP Summary Appendix E - WwTW Flow Data Appendix F - Indicative Permit Consents Appendix G - Constraints Matrix Appendix H - FRA Guidance Leaflet

TABLES

Table 2.1 - Proposed Locations for Growth within Babergh District Table 2.2 - Potential Growth Area WRZ and PZ Table 2.3 - Environment Agency Water Resource Availability Status Categories Table 2.4 - Water Usage Design Flows Table 3.1 - WwTW Current Capacity Table 3.2 - Current WFD Objectives for Principle Rivers within Babergh District (as reported in the Anglian RBMP, December 2009) Table 3.3 - Current Condition of Environmentally Designated Sites Table 3.4 - Current Flood Risk to Babergh Key Settlements Table 3.5 - Settlement Specific SUDS Restrictions Table 3.6 - Summary of Current Situation Table 4.1 - Summary of Growth Options Table 4.2 - Planning Zone Water Supply Deficits Table 4.3 - Planned Mitigation Measures Table 4.4 - Summary of Settlements within each WwTW Catchment Table 4.5 - Growth Option 2, Residential Development WwTW Capacity (inc. commitments & windfalls) Table 4.6 - Growth Option 3, Residential Development WwTW Capacity (inc. commitments & windfalls) Table 4.7 - Growth Option 2, Residential and Employment Development WwTW Capacity (including commitments & windfalls) Table 4.8 - Growth Option 3, Residential and Employment Development WwTW Capacity (including commitments & windfalls) Table 4.9 - Growth Option 4, Residential Development WwTW Capacity (including commitments & windfalls) Table 4.10 - Growth Option 4, Residential and Employment Development WwTW Capacity (inc. commitments & windfalls Table 4.11 - WwTWs Requiring an Increased CDWF or Experiencing Limited Headroom Within the Planning Period Table 4.12 - PPS25 Climate Change Allowances Table 4.13 - Potential Increase in River Flow as a Result of WwTW Discharge Table 4.14 - Key Settlements and Structures Located Downstream of WwTWs Table 4.15 - Impact of Flood Risk on Potential Development Locations Table 4.16 - Ability of WCS to Accommodate Growth Options 2 and 3

Table 5.1 - Maximum WwTW Capacity, Flow and Dwelling Numbers

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Table 5.2 - Maximum Capacity of District for Development Outside Fluvial, Tidal and Surface Water Flood Zones Table 5.3 - Maximum Capacity of WCS Table 6.1 - RAG Key Table 6.2 - Ability of WCS to Accommodate Growth Options 2, 3 and 4 Table 6.3 - Mitigation Measures Required for WCS to Accommodate Growth Options 2, 3 and 4 Table 7.1 - Flood Risk Vulnerability and Flood Zone “Compatibility” (from PPS25) Table 7.2 - Applicable SUDS Techniques Based Upon Soil Type Table 7.3 - Applicable SUDS Techniques Based Upon GWV and SPZs Table 7.4 - Applicable SUDS Techniques as Single Components, Based Upon Drainage Area Table 7.5 - Applicable SUDS Techniques Based Upon Topography Table 7.6 - Applicable SUDS Techniques Based Upon Hydraulic Head Table 7.7 - Applicable SUDS Techniques Based Upon the Availability of Space Table 7.8 - Applicable SUDS Techniques Based Upon the Intended Use of the Land

FIGURES

Figure 1 - Study Area Figures 2a and 2b - Potential Development Locations Figure 3 - Environment Agency ‘Areas of Water Stress’ Figures 4a and 4b - Water Supply Figures 5a and 5b - Wastewater Treatment Works Figures 6a and 6b - Environmentally Designated Sites Figures 7a and 7b - Flood Risk Figure 8 - Groundwater Vulnerability Figure 9 - Source Protection Zones

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EXECUTIVE SUMMARY

Overview and Context i In April 2010 Royal Haskoning was appointed by Babergh District Council (hereafter “the Council”) to produce a Stage 2 Water Cycle Study. This Water Cycle Study considers the District as a whole, updating the findings of the Haven Gateway Water Cycle Study where appropriate. This report has been written to the specification of the Environment Agency’s Water Cycle Study guidance (version 4), being equivalent to an Outline/Detailed level study, and the requirements of the Brief. ii The report considers the following issues, addressing the constraints that they may pose to future development and, where applicable, discusses the improvements necessary to achieve the required level of development throughout the planning period, until 2031:

• Water Resources and Supply; • Wastewater Collection and Treatment; • Water Quality and Environmental Issues; • Flood Risk; and • Demand Management and Sustainable Drainage Systems. iii This Water Cycle Study has been produced for the Council in consultation with the Environment Agency and AWS. Over the duration of the study much data has been requested, received and reviewed from the project consultees. The data included within the study was correct as of the start of May 2011. Due to the nature of this data and study, some of this information will become superseded fairly rapidly. Any limitations of the data are discussed further in the relevant sections of the report.

Growth Options iv To assist the Council in determining the capacity of the water cycle for sustainable growth, the following five growth options have been considered within this Water Cycle Study:

• Growth Option 1 - the current situation • Growth Option 2 - Former Regional Spatial Strategy Targets • Growth Option 3 - Draft Regional Spatial Strategy Review to 2031 • Growth Option 4 - Alternative Growth Scenarios • Growth Option 5 - the maximum capacity

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Assessment

Water Resources and Supply v The status of water resources and supply has been assessed through consultation with Anglian Water Services and review of their Final Water Resources Management Plan, in addition to the Environment Agency’s relevant Catchment Abstraction Management Strategy reports.

Wastewater Treatment and Network vi Raw data regarding the current and consented flows has been provided by AWS. This has been reviewed using a tool created by Royal Haskoning to assess if and when each Wastewater Treatment Works (WwTW) will exceed its consent. The tool also provides flow information to determine the new consent requirements for each Wastewater Treatment Works. Where a new consent is required, the impact of the new flow upon flood risk has been analysed. The capacity of the sewer network has been assessed through consultation with Anglian Water Services.

Water Quality and Environmentally Designated Sites vii The location and status of nationally and internationally-designated sites within the District has been obtained and the current water quality status of the watercourses has been determined through consultation with the Environment Agency and a review of the Anglian River Basin Management Plan. The effect of development upon water quality has been assessed through calculations of Indicative Consent Limits undertaken by the Environment Agency for Ammonia, Biochemical Oxygen Demand and Phosphates. Through calculation of the required consent limits for these elements (both with and without development) assessment has been made as to whether the proposed growth will impact upon the required Water Framework Directive (WFD) targets and whether the required improvements are within the current “Economic Limit of Conventional Treatment”. It is the responsibility of the Environment Agency as the ‘competent authority’ to ensure the Directive is carried out, although it is also a requirement of Regulation 17 that all public bodies have regard to the RBMPs and their objectives. The impact of the discharges upon the environmentally designated sites has been considered throughout the review.

Flood Risk viii The Environment Agency Flood Zone maps and all flood risk studies that were made available have been reviewed (including the relevant Strategic Flood Risk Assessment, Regional Flood Risk Assessment, Catchment Flood Management Plans and Shoreline Management Plan) to assess the risk of flooding from all sources across the District. The impact of runoff from development sites and increased discharge from Wastewater Treatment Works on flood risk has also been assessed.

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Demand Management and Sustainable Drainage Systems ix Appropriate demand management and Sustainable Drainage System techniques for the study area have been identified and guidance and recommendations for their implementation have been provided.

Conclusions x Most elements of the water cycle have sufficient capacity to accommodate the growth levels considered, although some locations require the implementation of new infrastructure and/or mitigation measures. These are summarised below for each Growth Option:

Growth Option 1 - Current Situation

• The current situation of the water cycle within the District is generally favourable in all locations. • There are currently sufficient water resources to supply the existing requirements. • There are no capacity restrictions within the water supply network. • Dedham, , , Holbrook, Nayland, and Sudbury WwTWs are currently at capacity with no available headroom. An additional seven WwTWs - , Boxford, Bures, , Great Wenham, Hadleigh and - have minimal or limited headroom. • No wastewater network restrictions have been identified by AWS, although some sewer flooding issues have been reported in the Sudbury, Stratford St Mary and areas due to surface water in storm events. • Some water quality issues have been identified within the District. Phosphorous levels are high and most watercourses classified as having ‘moderate’ ecological status. Ammonia levels are very low and should be maintained through implementation of the appropriate WwTW discharge limits, which should also seek to improve the ecological status of the watercourses to ‘good’ by 2027, as specified under the WFD. • Two environmentally designated sites - and - have been identified as currently being in unfavourable condition due to water cycle processes. Partnership working has been identified as being required to assist improvement. • Tidal, fluvial and surface water flood risk affects many areas of the District and, although much of the risk is already mitigated, further study in some areas may assist in future planning. • Some demand management techniques are already in operation across the District, although improvements would assist in improving the current water resources and increase the sustainability of the current development. • Sustainable Drainage Systems schemes should be retrofitted to existing development wherever possible.

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Growth Options 2, 3 and 4

• Most elements of the water cycle have sufficient capacity to accommodate Growth Options 2, 3 and 4, although some locations require infrastructure upgrades, dependent upon the site specifics at each settlement. • AWS are confident that sufficient water resources are available for the potential developments, although mitigation measures are required for a number of locations. • No major improvements are required to the water supply network, although all sites will require on-site connection, funded through developer contributions. • (Growth Option 4 only), Dedham, Elmsett, Glemsford, Hadleigh, Holbrook, Nayland, Sproughton and Sudbury require increased consents to accommodate the proposed growth. For all Growth Options Dedham, Elmsett, Glemsford, Holbrook, Nayland, Sproughton and Sudbury cannot accept any growth from the start of the planning period. Either increased consents are required or the growth within these catchments must be redistributed. For Growth Options 2 and 3, Hadleigh WwTW requires an increased consent in the latter half of the planning period. Without increased consent, redistribution of growth from this WwTW catchment will be required. In the Growth Option 4 scenario (sub option 2), the Brantham WwTW cannot accommodate the proposed residential growth, in combination with the proposed employment growth, from 2022. If this growth option is progressed, some of the growth will require redistribution. A number of other WwTWs are identified as having limited headroom early in the planning period. Development within the catchments of these WwTWs may be delayed and/or require additional developer contributions due to the upgrades required to meet stricter discharge consent limits (see joint position statement in Section 7). The village of is not connected to the WwTW network and, as such, the suitability of connection or installation of septic tanks should be assessed when planning applications are received. • The entire sewer network requires some upgrade in all locations. However, the capacity in Sudbury and is very limited and requires resolution before any additional development can take place. Funding should be sought from developers and AWS should be informed of final growth trajectories and site locations as early in the planning process as possible. • The Indicative Consent Limits identify that the maximum proposed growth scenarios are not currently constrained by the WFD ‘no deterioration’ objective. The proposed level of growth is also not constrained by the WFD ‘Good’ status, with the exception of Sproughton, for which the full quota of growth proposed in Growth Option 4 cannot be accommodated. • No significant effect of the potential development upon the environmentally designated sites is expected, although confirmation is required through consultation with Natural as part of the Habitats Regulation assessment of the Core Strategy. • Location of development within some settlements will be restricted by flood risk and development should be located in Flood Zone 1 as far as possible.

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• Demand management techniques, including rainwater harvesting and greywater recycling, should be implemented, with an aim for water neutrality. Water meters should be promoted. • Suitable Sustainable Drainage Systems schemes are required with all new development applications (in accordance with the Floods and Water Management Act), which ensure all surface water is dealt with on site and no pollution enters the waterbodies.

Growth Option 5 - Maximum Capacity

• Due to their natures, it is difficult to quantify the maximum capacity of many elements of the water cycle, although as far as possible this has been undertaken. • The maximum capacity of the water resources is assessed on a regional scale, but is greater than Growth Options 3 and 4. • The maximum capacity of the water supply network, is deemed to be slightly greater than Growth Options 3 and 4. • Maximum flow capacity of the Wastewater Treatment Works varies by location and seven WwTWs are currently at maximum capacity. The capacity of the all the other WwTWs is greater than the Growth Option 3 figures, with the exception of Hadleigh, which has a maximum capacity just less than Growth Option 2 and Brantham, which has a maximum capacity just less than Growth Option 4. • The overall capacity of the WwTW network is considered to be greater than Growth Options 3 and 4.. However, without the implementation of any improvements, it can be assumed that the sewer network is already operating at maximum capacity, especially within the Sudbury and Great Cornard network • For most of the WwTWs the maximum capacity with regards to water quality is greater than Growth Options 3 and 4.. However, Growth Option 3 represents the maximum capacity at Nayland and Dedham WwTWs and Sproughton’s maximum capacity is slightly lower than Growth Option 4. • The maximum capacity in terms of area located outside the Flood Zones 2 and 3 has been estimated and is far in exceedence of Growth Options 3 and 4.. • It is not possible to estimate the maximum capacity of the environment for demand management or Sustainable Drainage System, but both are greater than Growth Option 3, providing the identified restrictions are adhered to.

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GLOSSARY

Asset Management Asset Management Planning is the process by which the Plans Office of Water Services (Ofwat) determines the programme of water infrastructure and environmental improvements that are to be funded over a five year period and the water bill price rises that have to be allowed to fund this.

Catchment The area contributing flow or runoff to a particular point on a watercourse.

Climate change Long-term variations in global temperature and weather patterns, both natural and as a result of human activity (primarily due to greenhouse gas emissions).

Defra UK Government department responsible for policy and regulations on the environment, food and rural affairs.

Development The carrying out of building, engineering, mining or other operations in, on, over or under land or the making of any material change in the use of any buildings or other land.

Dry Weather Flow Peak water demand flow expected during hot, dry weather conditions.

Enmained Watercourse designated as a Main River

Environment Agency Government Agency charged with the protection of the environment.

Exception Test Following the application of the Sequential Test, the Exception is required in the circumstances set out in Tables D.1 – D.3 of PPS 25. There are three parts to the Exception Test which are set out in paragraph D9 of PPS 25

Flood defence Flood defence infrastructure, such as flood walls and embankments, intended to protect an area against flooding, to a specified standard of protection.

Flood Hazard The potential risk to life and potential damage to property resulting from flooding.

Flood probability The estimated likelihood of a flood of a given magnitude occurring or being exceeded in any specified time period.

Flood risk An expression of the combination of the flood probability and the magnitude of the potential consequences of the flood event.

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Flood risk A study to assess the risk of a site or area flooding, and to assessment assess the impact that any changes or development in the site or area will have on flood risk.

Flood Zones Flood Zones are defined in Table D.1 of Planning Policy Statement (PPS) 25: Development and Flood Risk. They indicate land at risk by referring to the probability of flooding from river and sea, ignoring the presence of defences.

Floodplain Area of land that borders a watercourse, an estuary or the sea, over which water flows in time of flood, or would flow but for the presence of flood defences where they exist.

Fluvial Water Water contained or flowing within a river or stream.

Functional floodplain Land where water has to flow or be stored in times of flood. It includes the land which would flood with an annual probability of 1 in 20 (5%) or greater in any year or is designed to flood in an extreme (0.1%) flood, or at another probability to be agreed between the LPA and the Environment Agency, including water conveyance routes.

Groundwater Water in the ground, usually referring to water in the saturated zone below the water table.

Groundwater flooding Flooding caused by groundwater escaping from the ground when the water table rises to or above ground level.

Headroom Buffer between supply and demand targets

LiDAR Data set that provides a 3D image of the surface of the earth.

Local Development Documents that set out the spatial strategy for local planning Documents authorities which comprise development plan documents.

Local Development Framework which forms part of the statutory development Framework plan and supplementary planning documents which expand policies in a development plan document or provide additional detail.

Local Planning Body responsible for planning and controlling development, Authority through the planning system.

Main River A watercourse designated on a statutory map of Main rivers, maintained by the Environment Agency.

Mitigation measure A generic term used in this guide to refer to an element of development design which may be used to manage some risk to the development, or to avoid an increase in risk elsewhere.

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Ofwat The Water Services Regulation Authority, which is the economic regulator of the water and sewerage industry in England and Wales.

Ordinary watercourse A watercourse which is not a private drain and is not designated a Main river.

Ramsar Sites defined under the ‘Ramsar Convention". The convention is an intergovernmental treaty that embodies the commitments of its member countries to maintain the ecological character of their Wetlands of International Importance and to plan for the "wise use", or sustainable use, of all of the wetlands in their territories.

Regional Spatial A document produced as part of the national planning system Strategy (former) with the main purpose to provide a long term land use and transport planning framework for the Region. It guides the preparation of local authority development plans and local transport plans. N.B. These were revoked by the Coalition Government on the 6th July 2010 and currently subject to a legal challenge with an alternative mechanism for strategic planning not yet concluded.

Return period A term sometimes used to express flood probability. It refers to the estimated average time gap between floods of a given magnitude, but as such floods are likely to occur very irregularly, an expression of the annual flood probability is preferred.

River Basin Plans that set out the environmental objectives for all Management Plan groundwater and surface waterbodies and Protected Areas (RBMP) within a River Basin District.

Runoff Water flow over the ground surface to the drainage system.

Sequential Test The Sequential Test refers to the application of this approach by Local Planning Authorities (LPAs) in determining land uses that are compatible with the level of flood risk at each allocated development site within a Local Authority area. Development should be directed to Flood Zone 1 wherever possible, and then sequentially to Flood Zones 2 and 3, and to the areas of least flood risk within Flood Zones 2 and 3, as identified by the Strategic Flood Risk Assessments (SFRA) (see Table D.1 and Table D.2 of PPS25).

Standard of The estimated probability of an event occurring which is more protection severe than those against which an area is protected by flood defences.

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Strategic Flood Risk A study to examine flood risk issues on a sub-regional scale, Assessment (SFRA) typically for a river catchment or local authority area during the preparation of a development plan.

Source Protection Defined areas showing the risk of contamination to selected Zone (SPZ) groundwater sources used for public drinking water supply, from any activities that might cause pollution in the area.

Surface Water Water collected or flowing over the ground not contained within a watercourse. Usually results from heavy rainfall.

Sustainable Drainage ‘Drainage Systems’ are defined in Schedule 3 of the Floods Systems (SUDS) and Water Management Act 2010 as structures designed to receive rainwater, with the exception of a public sewer or natural watercourse. ‘Sustainable Drainage’ is defined as managing rainwater (including snow and other precipitation) with the aim of: a) reducing damage from flooding; b) improving water quality; c) protecting and improving the environment; d) protecting health and safety; and e) ensuring the stability and durability of drainage systems.

Watercourse Any natural or artificial channel that conveys surface water.

Water Cycle Study Provides a plan and programme of Water Services (WCS) Infrastructure implementation. It is determined through an assessment of the environment and infrastructure capacity for: water supply; sewage disposal; flood risk management; and surface water drainage.

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ABBREVIATIONS

AMP Asset Management Plan

AWS Anglian Water Services

BOD Biological Oxygen Demand

CAMS Catchment Abstraction Management Strategy

CDWF Consented Dry Weather Flow

CFMP Catchment Flood Management Plan

CIRIA Construction Industry Research and Information Association

CSO Combined Sewer Overflow

DWF Dry Weather Flow

DVA Derwent Valley Aqueduct

ECSFDI England Catchment Sensitive Farming Delivery Initiative

EU European Union

FRA Flood Risk Assessment

FWMA Floods and Water Management Act

FWRMP Final Water Resource Management Plan

GIS Geographical Information System

GQA General Quality Assessment

GWV Ground Water Vulnerability

GWMU Ground Water Management Unit

HOF Hands-Off Flow

LDF Local Development Framework

LiDAR Light Detecting and Ranging

LPA Local Planning Authority

NVZ Nitrate Vulnerable Zones

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OS Ordnance Survey

PPS25 Planning Policy Statement 25 – Development and Flood Risk

PZ Planning Zone

RBMP River Basin Management Plan

RFRA Regional Flood Risk Appraisal

RoC Review of Consents

RQO River Quality Objective

RSS Regional Spatial Strategy

SAB SUDS Approval Board

SFRA Strategic Flood Risk Assessment

SMP Shoreline Management Plan

SPA Special Protection Area

SPZ Source Protection Zone

SRP Soluble Reactive Phosphorous

SSSI Sites of Special Scientific Interest

SUDS Sustainable Drainage Systems

UWWTD Urban Wastewater Treatment Directive

WCS Water Cycle Study

WFD Water Framework Directive

WRMU Water Resource Management Unit

WRZ Water Resource Zone

WwTW Wastewater Treatment Works

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1 INTRODUCTION

1.1 General Overview

1.1.1 - 1 In April 2010 Royal Haskoning was appointed by Babergh District Council (hereafter “the Council”) to produce a Stage 1/2 Water Cycle Study (WCS). This work follows on from the Haven Gateway Stage 2 WCS, which included the Eastern half of Babergh District and was completed by Royal Haskoning in November 2009. This WCS considers the District as a whole, updating the findings of the Haven Gateway study where appropriate. This report has been written to the specification of the Environment Agency’s WCS guidance (version 4), being equivalent to an Outline/Detailed level study, and the requirements of the Brief.

1.2 Scope

1.2.1 - 1 Babergh District Council is currently in the process of developing their Local Development Framework (LDF) and in particular their Core Strategy, as required by the Planning and Compulsory Purchase Act 2004. To inform and support the preparation of the LDF, the Council is required to present a portfolio of studies, forming an Evidence Base, of which this WCS will form a part. The study area is defined in Figure 1.

1.2.1 - 2 Following the abolition of the Regional Spatial Strategies (RSS) in June 2010, the Council is now required to determine appropriate and sustainable growth targets for the District in the absence of the RSS. This WCS will assist in this process through assessment of the constraints and requirements arising from growth on the water infrastructure of the study area and therefore which areas are the most suitable to accommodate growth. To assist the Council in determining the most appropriate growth target, this WCS considers the following five scenarios for growth:

1. The current situation with no future development; 2. The development trajectory in line with the former RSS targets; 3. The development trajectory in line with the draft RSS review to 2031; 4. Five alternative development options affecting the settlements of Brantham, Great Cornard, and Sproughton; and 5. The maximum capacity of the various elements of the water cycle.

1.2.1 - 3 It is intended that this study assists the Council with the development of investment programmes to ensure that:

• adequate water supply and waste water infrastructure are in place to support housing and employment growth; • any additional infrastructure is provided in accordance with a strategic rather than a piecemeal approach; • there is a strategic approach to the management and use of water; • the environment has sufficient capacity to receive increased waste water discharges; and • the potential for grey water reuse and implementation of Sustainable Drainage Systems (SUDS) is fully realised.

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1.3 Objectives of the Water Cycle Study

1.3.1 - 1 The WCS considers the following issues, addressing the constraints that they may pose to future development and discusses the improvements necessary to achieve the required level of development throughout the planning period, until 2031:

• Water Resources and Supply; • Wastewater Collection and Treatment; • Water Quality and Environmental Issues; • Flood Risk; and • Demand Management and SUDS.

1.3.1 - 2 The WCS process also provides a benefit to the water companies by providing them with a more detailed indication of the possible development within the area. This will reduce the number of assumptions that are necessary in making decisions in relation to future planning of resource and infrastructure requirements.

1.3.1 - 3 This WCS has been produced for the Council in consultation with the Environment Agency and Anglian Water Services (AWS).

1.4 Guidance on the use of this Study

1.4.1 - 1 This WCS report has been prepared over a period of one year. The methodologies and supporting data for such studies are constantly being developed and updated over time. This report, therefore, can only represent a snapshot in time and has to acknowledge that the supporting data and best practices are ever changing. The report will need to be periodically reviewed and updated to bring it in line with the latest data and best practices. As such, the Environment Agency guidance recommends reviewing this WCS every five years.

1.4.1 - 2 Much of the data used in the Haven Gateway WCS has been updated within the last 18 months and this report utilises the most recent data available, including AWS’ Final Water Resource Management Plan (FWRMP), 2010 Wastewater Treatment Work (WwTW) flow measurements and 2010 revised WwTW discharge consents. The development locations and trajectories for growth are also more defined within this study. As such many conclusions represented within this report differ from those shown in the Haven Gateway WCS.

1.4.1 - 3 To enable cross referencing between the two WCS reports, the scale of this WCS has been set to match the published Haven Gateway WCS. The scale of this study is such that it falls between the Outline and Detailed stage WCSs described in the Environment Agency’s guidance. The Council may consider it necessary to consult independently with AWS and/or the Environment Agency with regard to individual development sites or areas in order to obtain additional or more recent information if further detail is required to support the detailed planning process. They may also find it beneficial for further growth scenarios or locations to be reviewed at a later date.

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1.4.1 - 4 This report does not remove the need for planning authorities and developers to consult with AWS, the Environment Agency and other statutory bodies to confirm the validity of information and any other impacts that development may have on the water cycle, particularly in details at a local level that this study may not have identified.

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2 DATA COLLECTION AND METHODOLOGY

2.1 Overview

2.1.1 - 1 A sequential approach was adopted within the production of this WCS and followed the high level model shown:

State Pressure Impact Management (1) (2) (3) (4)

1. Firstly, the current status of the water management infrastructure was assessed in order to gain an insight into the current demands placed upon it as well as existing management strategies. 2. Secondly, using information available at the time of writing, the likely trends of future growth, environmental targets and possible external threats (e.g. climate change) were established. 3. Thirdly, the impact of the identified pressures on the existing water infrastructure and other environmental assets was assessed. 4. Finally, high level sustainable management strategies were proposed in order to manage the identified problems.

2.1.1 - 2 The following areas have been considered in evaluating the water infrastructure within the above model:

• Housing and employment growth (considering future trajectories and potential growth options); • Water resources and supply; • Wastewater treatment and collection; • Water quality and the environment; • Flood risk; and • Demand Management and SUDS.

2.1.1 - 3 The following sections broadly outline how each of these areas has been evaluated for this study, including the data and methodology used throughout the WCS. As such, this section does not include the analyses or any conclusions, which can be found in Sections 3 - 6.

2.2 Data Collection

2.2.1 - 1 Over the duration of the study much data has been requested, received and reviewed from the project consultees, in addition to extensive consultation with the Council, AWS and the Environment Agency. A record of the data collected is presented as a data register in Appendix B.

2.2.1 - 2 The data included within the study was correct as of the start of May 2011. Due to the nature of this data and study, some of this information will become superseded fairly rapidly. Any limitations of the data are discussed further in the relevant sections of the report.

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2.3 Housing and Employment Growth

2.3.1 Scenarios for Growth

2.3.1 - 1 As stated in Section 1.2, following the abolition of the RSS, the Council must determine an appropriate and sustainable development strategy and appropriate growth targets for the District. Although key potential broad locations for development are being considered by the Council as part of their Core Strategy, a preferred strategy for growth is yet to be determined. Many of the potential locations for growth, as identified by the Council in the Growth Options Core Strategy, have been used as a basis for analysis throughout this WCS. These locations consist of the following three development ‘groups’:

1. Towns and Urban Areas; 2. Key Service Centres; and 3. ‘Other Villages’

2.3.1 - 2 The locations identified as ‘Town and Urban Areas’ include potential broad locations for urban expansion around the towns of Sudbury, Hadleigh and Ipswich. The Key Service Centres are the fifteen larger villages within the District that have been identified as having a number of key services required to support additional growth. ‘Other Villages’ consist of a group of seventeen settlements identified as suitable for small scale infill development. The settlements within each of these groups are listed in Table 2.1 below and shown graphically in Figures 2a and 2b. The key employment locations have been identified around Sudbury, Hadleigh and the Ipswich Fringe (including Brantham, Sproughton and ). These are also listed in Table 2.1 and shown graphically in Figures 2a and 2b.

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Table 2.1 - Proposed Locations for Growth within Babergh District

Development Towns and Urban Key Service Centres Other Villages Type Areas Residential Hadleigh Acton Glemsford Assington (Growth Areas 1, 2 and Bildeston Great Bentley Monks Eleigh 3) Boxford Waldingfield Cockfield Brantham Holbrook and Sproughton Sudbury and Great Bures St Mary Stoke by Cornard Chapel St Long Elmsett Nayland (Growth Areas 5 & 6) Mary Melford Stratford St Chelmondiston Nayland Mary Ipswich Fringe East Bergholt Hitcham Stutton (Growth Area 8) Kersey Employment Hadleigh Brantham Sproughton (Growth Area 1 & Lady Lane)

Sudbury and Great Cornard (Growth Area 6 & Chilton Woods)

Ipswich Fringe (Growth Area 8, Wherstead Office Park & Sprites Lane)

2.3.1 - 3 To assist the Council in determining the capacity of the water cycle for sustainable growth, the following five growth options have been considered within this WCS:

Growth Option 1: The Current Situation

2.3.1 - 4 This scenario has assessed the current status of all elements of the water cycle, listed in Section 2.1, with no additional growth.

Growth Options 2 and 3: Trajectories for Growth

2.3.1 - 5 The Council is currently consulting the public about potential growth targets for the District. This study assesses the impacts of the former RSS targets and the Draft RSS Review up to 2031 targets to determine if these notional figures and distributions can be sustainably accommodated in the District. The reason for assessing these former targets in this study is that they are somewhere in the middle of the range of the growth options that are currently being considered as part of the Babergh Core Strategy Growth Options consultation and the outcome of this study will inform the Core Strategy preparation in terms of the impacts of potential growth on the Water Cycle in the District. These assessments include a consideration of the current commitments and potential windfalls across the planning period, as provided by the Council. Information regarding the timing and location of current commitments was obtained from Appendix 1 of the

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Council’s latest Annual Monitoring Report (AMR)1. Allowances for potential future growth were based on the distributions in Table 1 of the Babergh Draft Core Strategy (that was submitted to Babergh District Council on the 1st June 2010 and that was deferred following the commitment by the Coalition Government to revoke the RSS). To keep the development trajectories inline with those presented in the Haven Gateway WCS, the impact of holiday influx, based on a population equivalent figure (supplied by AWS) was included within the potential trajectories for growth.

2.3.1 - 6 Trajectories of employment growth have been provided by the Council and included within this assessment. The employment trajectory does not differ between Growth Options 2 and 3.

2.3.1 - 7 The final trajectories used in the analysis for Growth Options 2 and 3 is presented in Appendix C.

Growth Option 4: Alternative Development Options

2.3.1 - 8 To test the sensitivity of the water cycle to the proposed growth figures and to assist in the determination of the most suitable locations for growth, the Council requested the following additional development options were tested:

1) 250 residential properties in Brantham (increase on Growth Options 2 and 3); 2) 700 residential properties in Brantham (increase on Growth Options 2 and 3); 3) 500 residential properties in Sudbury, Area 6 (decrease from Growth Options 2 and 3); 4) 350 residential properties in Sudbury, Area 5 (decrease from Growth Options 2 and 3); and 5) 950 residential properties in Ipswich, Area 8 (increase on Growth Options 2 and 3).

2.3.1 - 9 These five options have been tested independently. However, where other settlements are located within the same water cycle catchment (e.g. WwTW catchment) as Brantham, Sudbury or Ipswich, the growth scenarios stated above have been combined with the Growth Option 2 and 3 figures and both with and without the proposed employment trajectories stated in Growth Options 2 and 3. In addition the existing commitments and windfalls have been included. Combining the scenarios in this manner enables a more accurate assessment of the impact of the five options within Growth Option 4 on the Water Cycle as a whole. The trajectories used in this Growth Option are also included in Appendix C.

For example, an assessment of the WwTW capacity for sub option 4 above, 350 residential properties in Sudbury Area 5 has been undertaken as follows. Sudbury Area 5 is located within the Long Melford WwtW catchment. This WwTW also serves the villages of Acton and Long Melford, which have both been identified for a base rate of residential development in Growth Options 2 and 3 (27 dwellings and 40 dwellings in each village respectively). In addition, Long Melford WwTW will serve the Chilton Woods employment development. As such the 350 dwellings in sub option 4 has been

1 Annual Monitoring Report, Babergh District Council, 2008-9

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tested alongside the Growth Option 2 growth within the catchment, in addition to any existing commitments and windfalls (350 dwellings + 27 dwellings + 27 dwellings + 12 dwellings + 320 dwellings), totalling the 736 dwellings shown in Appendix C. This residential total has been tested both with and without the proposed 8.32ha of employment development. The same scenario has also been run alongside Growth Option 3, where the potential residential development in Acton and Long Melford increases to 40 dwellings, both with and without employment development. Breakdowns of the development considered in each scenario can be found in Appendix E.

Growth Option 5: The Maximum Capacity

2.3.1 - 10 The maximum capacity of all elements of the water cycle has been assessed to determine the highest growth scenario that could be sustainably accommodated within the District with no additional, development specific, infrastructure improvements or adjustments.

2.4 Water Resources and Supply

2.4.1 Introduction

2.4.1 - 1 All potable water within Babergh District is provided by AWS. The assessment of water resources and water supply included in this WCS has therefore been primarily based on consultation with, and data provided by, AWS, together with any additional information provided by the Council and the Environment Agency.

2.4.2 Water Resources

2.4.2 - 2 Babergh District is served by one water company, AWS. The Environment Agency have published a document entitled ‘Areas of Water Stress: final classification’, available on their website2. This document included a map of England, identifying areas of relative water stress, as shown in Figure 3. The whole of AWS’ supply area (marked with the number ‘1’ on Figure 3) is shown as an area of ‘Serious’ water stress, based upon the amount of water available per person both now and in the future3. Please note this classification of relative water stress was designed to support decisions about metering in 2007 and on its own does not give a complete picture of water resource pressures. For example it does not take account of the impacts of climate change and cannot be used as an indicator for environmental water resource pressures.

2 http://publications.environment-agency.gov.uk/PDF/GEHO1207BNOC-E-E.pdf 3 Using data from the 2004 water company Water Resource Management Plans

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Figure 3 - Environment Agency ‘Areas of Water Stress’

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2.4.2 - 3 Water companies have a duty to maintain the security of their supplies. In order to help achieve this, the Water Resource Management Plan Regulations (2007) require all water companies to publish a Water Resources Management Plan (WRMP), which states how each company expects to supply water to its customers over the 25 year period from 2010 to 2035, whilst protecting the environment. They also form part of the five yearly business plans each company must submit to Defra, the latest of which was submitted in August 2008. The draft versions of the most recent plans were published in 2008, with most of the final versions being released in 2009-10.

2.4.2 - 4 An assessment of water availability has been made using AWS’ Final Water Resource Management Plan (FWRMP)4 (published in February 2010, following completion of the Haven Gateway WCS). Discussion has also taken place with AWS to compare the development trajectory used in their FWRMP with those provided by the Council and to identify any foreseeable site-specific limitations to the water supply resources and network. The responses provided by AWS to the Council’s Core Strategy consultations have also been included. In addition to the FWRMP, the Environment Agency’s relevant Catchment Abstraction Management Strategies (CAMS) reports have been reviewed to determine any likely restrictions on the abstraction of surface water over the planning period.

2.4.2 - 5 This section identifies the relevant parts of the FWRMP and CAMS reports which relate to the District. The current status of water resources are discussed in Section 3.

FWRMP

2.4.2 - 6 Within their WRMPs the water companies refer to their Water Resource Zones (WRZs). A WRZ is the largest possible zone in which all resources, including external transfers, can be shared and hence the zone in which all customers experience the same risk of supply failure from a resource failure. Within their twelve WRZs, AWS differentiate a number of smaller areas, referred to as Planning Zones (PZs), which are used in the planning and management of their assets.

2.4.2 - 7 Babergh District is served by the following two WRZs and 4 PZs, as illustrated in Figures 4a and 4b:

• WRZ09 and West , within which PZ62 (Sudbury) and PZ48 (Bury St Edmunds) serve the western half of the District; and • WRZ10 East Suffolk and , within which PZ61 (Semer) and PZ60 (Ipswich) serve the eastern half of the District.

2.4.2 - 8 Table 2.2 identifies the WRZ and PZ in which each of the key settlements within the District are located:

4 AWS FWRMP can be viewed online at http://www.anglianwater.co.uk/environment/water-resources/resource- management/

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Table 2.2 - Potential Growth Area WRZ and PZ

Site Potential Development Development Cambridgeshire and East Suffolk and Essex # Site Group (WRZ09) (WRZ10) RESIDENTIAL 1 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich 2 Hadleigh (west: area 2) Town/Urban Area PZ60 - Ipswich 3 Hadleigh (north area 3) Town/Urban Area PZ60 - Ipswich 4 Sudbury (north area 5) Town/Urban Area PZ62 - Sudbury 5 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury 6 Ipswich Fringe (western Town/Urban Area PZ60 - Ipswich area 8) 7 Acton Key Service Centre PZ62 - Sudbury 8 Bildeston Key Service Centre PZ61 - Semer 9 Boxford Key Service Centre PZ60 - Ipswich 10 Brantham Key Service Centre PZ60 - Ipswich 11 Bures St Mary Key Service Centre PZ62 - Sudbury 12 Chapel St Mary Key Service Centre PZ60 - Ipswich 13 Chelmondiston Key Service Centre PZ60 - Ipswich 14 East Bergholt Key Service Centre PZ60 - Ipswich 15 Glemsford Key Service Centre PZ48 - Bury St Edmunds 16 Key Service Centre PZ62 - Sudbury 17 Holbrook Key Service Centre PZ60 - Ipswich 18 Lavenham Key Service Centre PZ48 - Bury St Edmunds 19 Long Melford Key Service Centre PZ62 - Sudbury 20 Nayland Key Service Centre PZ60 - Ipswich 21 Shotley Key Service Centre PZ60 - Ipswich 22 Assington Other Villages PZ62 - Sudbury 23 Bentley Other Villages PZ60 - Ipswich 24 Cockfield Other Villages PZ48 - Bury St Edmunds 25 Other Villages PZ60 - Ipswich 26 Elmsett Other Villages PZ61 - Semer 27 Hartest Other Villages PZ48 - Bury St Edmunds 28 Hintlesham Other Villages PZ61 - Semer 29 Hitcham Other Villages PZ61 - Semer 30 Kersey Other Villages PZ61 - Semer 31 Lawshall Other Villages PZ48 - Bury St Edmunds 32 Monks Eleigh Other Villages PZ61 - Semer 33 Polstead Other Villages PZ60 - Ipswich 34 Sproughton Other Villages PZ60 - Ipswich 35 Stoke by Nayland Other Villages PZ60 - Ipswich 36 Stratford St Mary Other Villages PZ60 - Ipswich 37 Stutton Other Villages PZ60 - Ipswich 38 Tattingstone Other Villages PZ60 - Ipswich EMPLOYMENT 39 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich 40 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury

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Site Potential Development Development Cambridgeshire and West Suffolk East Suffolk and Essex # Site Group (WRZ09) (WRZ10)

41 Ipswich Fringe (western Town/Urban Area PZ60 - Ipswich area 8) 42 Chilton Woods, Sudbury Town/Urban Area PZ62 - Sudbury 43 Brantham Key Service Centre PZ60 - Ipswich 44 Sproughton Other Villages PZ60 - Ipswich 45 Lady Lane, Hadleigh Town/Urban Area PZ60 - Ipswich 46 Wherstead Office Park, Other PZ60 - Ipswich Wherstead 47 Sprites Lane, Ipswich Town/Urban Area PZ60 - Ipswich

2.4.2 - 9 Water supply within both the WRZs is predominantly abstracted from Chalk aquifer groundwater sources, although WRZ10 is also supported by surface water reservoirs at Alton and Ardleigh. Alton reservoir is located in the eastern end of the Babergh District, close to the village of Tattingstone. It is filled from the Gipping catchment and augmented from the Mill Stream at Bucklesham with water pumped under the . The Ardleigh reservoir is located outside Babergh District, to the northeast of . Rather than having a fluvial catchment inflow, Ardleigh reservoir is filled by treated wastewater from towns along the Colne valley, in addition to groundwater baseflow. Planning permission has been granted for the extension of Ardleigh reservoir through the restoration of adjacent gravel workings.

CAMS

2.4.2 - 10 The Environment Agency is in the process of writing a number of new Catchment Abstraction Management Strategies (CAMS), based on new Resource Assessments completed between 2008 and 20115. The Strategies will be produced in consultation with a range of key stakeholders and explain how they will manage the water resources. Babergh District Council’s area is mainly within the North Essex CAMS, with some parts in the East Suffolk CAMS. Although unlikely to impact on residential development, the Environment Agency’s policies regarding abstraction from the waterbodies within the District may impact upon the viability of smaller commercial developments or agriculture.

2.4.2 - 11 The following two CAMS studies are relevant to Babergh District:

• East Suffolk which covers the catchments of the Brook and the River Gipping; and • Combined Essex which covers the catchments of the Rivers Stour, Brett and Box, Sutton and Sixpenny Brooks.

5 Please note, the Resource Assessment on which CAMS is based is subject to review on an approximately annual basis, so these status’ will change from time to time. Updates will be published on the Environment Agency’s website. The Resource Assessment status does not form the whole of the Abstraction Management Strategy for each area. Other factors, such as the status of waterbodies downstream and/or the presence of locally sensitive receptors will be taken into account in licensing strategies and decisions.

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2.4.2 - 12 These strategies will soon be available through the Environment Agency’s website6, which includes maps of their catchment boundaries. Information from the underlying Resource Assessment is currently being used in determining licenses, in line with the requirements of the Water Framework Directive. They will outline where water is available for abstraction, where there is a need to reduce current rates of abstraction, the Environment Agency’s policy on time-limited licences and renewal of licences and provide an indication of the reliability of a potential abstraction licence. They highlight the status of the Water Framework Directive Waterbodies in the area, in addition to the water dependent SSSIs, Special Areas of Conservation (SAC) and Special Protection Areas (SPA) which are affected by changes in water availability (these are discussed in more detail in Section 2.6). The Strategies will use the three tier categorisation system of water resource availability, plus two categories for ‘special’ waterbodies, as shown in Table 2.3. The new CAMS will be published in late 2012/early 2013. In the meantime, all information relating to CAMS within this WCS has been provided by the Environment Agency.

Table 2.3 - New CAMS Categorisation System

Water Resource Implication for Licensing Availability Colour High hydrological There is more water than required to meet the needs of the environment. However, due to regime the need to maintain the near pristine nature of the water body, further abstraction is severely restricted. Water available for There is more water than required to meet the needs of the environment. licensing New licences can be considered depending on local and downstream impacts.

Restricted water Full Licensed flows fall below the Environmental Flow Indicator (EFI). available for No new consumptive licences would be granted. It may also be appropriate to investigate the licensing possibilities for reducing fully licensed risks. Water may be available if you can ‘buy’ (known as licence trading) the entitlement to abstract water from an existing licence holder. Water not Recent actual flows are below the EFI. available for This scenario highlights water bodies where flows are below the requirement to meet Good licensing Ecological Status (as required by the Water Framework Directive). No further consumptive licences will be granted. An economic appraisal of flow recovery and ecological benefit will be carried out. Water may be available if you can ‘buy’ (known as licence trading) the entitlement to abstract water from an existing licence holder. HMWBs These water bodies have a modified flow that are influenced by reservoir compensation releases or they have flows that are augmented. These and are often known as ‘regulated rivers’. They may be managed through an operating agreement, often held by a water company. The availability of water is dependent on these operating agreements.

6 http://www.environment-agency.gov.uk/research/planning/33518.aspx

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2.4.3 Water Supply

2.4.3 - 13 Due to heightened security around water supply resources, this study is not able to provide details about the location of water abstraction points or water networks from AWS. In addition, as no network models were run or constructed as part of this WCS, making an independent accurate assessment on the impact of growth on the water infrastructure is not possible. Some assessment has, however, been made based upon discussion held with AWS and the comments they have provided regarding the Council’s Core Strategy consultations. However water supply infrastructure is a critical part of the water cycle and should be evaluated on a site-specific basis at planning stage in the same way as wastewater or flooding.

2.5 Wastewater Treatment and Collection

2.5.1 - 1 AWS are responsible for most domestic and a small percentage of trade wastewater treatment within Babergh District. Information regarding the wastewater collection and treatment infrastructure serving the study area has been provided by AWS, in the form of data spreadsheets, discussions and the comments they have provided on the Council’s Core Strategy consultations.

2.5.2 Wastewater Treatment

2.5.2 - 2 All wastewater transmitted in the combined or foul sewer networks, either by gravity systems or pumps, is taken to a WwTW to be cleansed and subsequently released back into the river network. The number of WwTWs is decreasing due to a preference for the utilisation of fewer larger works, although the Environment Agency is now trying to reduce the trend in amalgamating smaller works as it is not always the most viable option environmentally.

2.5.2 - 3 The capacity of the wastewater treatment systems is an important consideration when planning new development. This is judged in terms of the ability of the WwTW to receive more flow and the quality of the watercourse into which it discharges. For a WwTW to increase its capacity, it has the potential to request an increase in Consented Dry Weather Flow (CDWF), i.e. the volume of treated effluent it is permitted to discharge. If the quality of the river in question is already marginal or poor, it may prove to be a barrier to the increase in CDWF due to the enhanced influence an increase in treated effluent will have upon the aquatic ecosystem. However, should consent be granted, the conditions will undoubtedly be stringent and require additional capital investment by AWS in order to meet the higher effluent standard, particularly with regards to the level of phosphates discharged as there must be no deterioration in standard (under the Water Framework Directive, WFD).

2.5.2 - 4 The Urban Wastewater Treatment Directive (UWWTD) is designed to make sure all wastewater in the EU is treated to the appropriate standard. An essential element of the Directive is that quality standards for effluent fall into categories depending on the size of the treatment works and the sensitivity of the receiving watercourse. As populations grow, some WwTW may exceed the UWWTD threshold that requires nutrient removal. In locations where households cannot be connected to existing sewers, particularly of concern in the rural areas of the Study Area, this may result in additional septic tank

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discharges to waterbodies in which levels of phosphates and nitrates are already very high.

2.5.2 - 5 Under the Water Resources Act a ‘consent to discharge’ must be obtained from the Environment Agency before any polluting material is legally discharged into a watercourse. The consents are based upon the quality and volume of the wastewater and the quality and capacity of the receiving watercourse. If a WwTW needs to expand due to the impact of new development, it may be necessary for a new consent for increased flow to be applied for. Where this is granted by the Environment Agency, it is likely that tighter limits will be set on the pollutant concentrations to ensure overall loading is unaltered. When consent limits are reviewed, the ammonia and phosphate levels in the receiving watercourses must be considered, as will the requirements of the WFD and the findings of the River Basin Management Plans (RBMP), published in 2009. These issues are discussed further in Section 2.6.

2.5.2 - 6 The latest data (April 2011) has been provided by AWS including CDWF, the last seven years flow data records (2004 - 2010), catchment areas, population equivalent figures and receiving watercourses. The impact of potential development on the WwTWs has been determined by considering the potential growth areas and trajectories and determining the wastewater treatment works catchment area in which they are located (see Figures 5a and 5b). Using this data the capacity of the wastewater treatment infrastructure has been determined for each growth option as follows:

2.5.2 - 7 The current situation (Growth Option 1) has been determined through comparison of the current flow data7 with the CDWF, in addition to statements provided by AWS. This simply determines whether a WwTWs is currently operating below, or close to, its consent.

2.5.2 - 8 For Growth Options 2, 3 and 4 the capacity of each WwTW has been calculated through utilisation of the potential growth trajectories shown in Appendix C. The increase in calculated DWF figure in each year is based upon the following assumed design flows (shown within Table 2.4). Please note, these have been updated following publication of the Haven Gateway WCS. The base was taken as the current DWF (see footnote 6). The impact of the holiday influx, based on a population equivalent figure (supplied by AWS) was included in the wastewater collection assessment, and the demands included in the evaluation.

7 Generally calculated as an average of the measured flow records between 2004 - 2010 (following the removal of any anomalies) unless stated otherwise by AWS.

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Table 2.4 - Water Usage Design Flows

Flow Element Design Flows Litres Cubic Metres Residential Development 145 litres/capita/day 0.145 m³/capita/day Industrial Development B1 (office) 750 litres/day/100m³ 75 m³/ha developable land/day B2 (industrial) 550 litres/day/100m³ 55 B8 (warehousing) 150 litres/day/100m³ 15 m³/ha developable land/day Infiltration 45 litres/capita/day 0.045 m³/capita/day Dwelling Population Density 2.1 people/dwelling

2.5.2 - 9 These standard figures, particularly for the non-residential development, will give rise to unusual results in some areas where the development is not “standard”. For certain developments the design flow rates for the industrial development may be a higher estimate than expected, although this impact is thought to be minimal within Babergh District. Any future update of the study should reconsider the flows used to assess the impacts on receiving watercourses and treatment works.

2.5.2 - 10 The ‘base’ DWFs were then compared with the current CDWFs for each WwTW to establish the “headroom” at the works for each year of the study period. As the consented discharge is the key limiting factor for the capacity of the WwTWs, the headroom evaluations have been based on the CDWF rather than the actual process capacity of the works, which may be significantly different. The resulting headroom information has been presented in the form of traffic light colour coded charts indicating whether a WwTWs is predicted to be operating within it’s current consent (green), whether it is predicted to be operating within 20% of its current consent (amber) or whether it is predicted to require an increase in CDWF (red). In addition, to provide a safety factor to highlight a risk of breach, the sites predicted to discharge within 10% of their CDWF have been highlighted.

2.5.2 - 11 The maximum capacity (Growth Option 5) of each WwTW has been calculated through conversion of the current available headroom into dwelling numbers for each WwTW, using the water usage design flow values provided in Table 2.4. It has also accounted for headroom restrictions identified by AWS.

2.5.3 Wastewater Collection

2.5.3 - 12 The main network of sewers between developed areas and WwTWs are considered ‘public’ sewers and are the responsibility of AWS. However, for houses built after 1 October 1937 all pipework serving more than one property are currently ‘private’ sewers until they join the public sewer, normally under the road. Maintenance of private sewers is the responsibility of all the house owners using it. It is the capacity and location of the main public sewers that will be discussed within this report.

2.5.3 - 13 There are two types of public sewer: foul and surface. The foul sewers remove dirty wastewater that cannot be discharged into the environment and carry it to sewage

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treatment works. Surface water sewers transmit runoff from housing (i.e. roofs, driveways etc.) and discharge it into ditches and rivers. Although new developments generally connect road gullies to housing estate mains, highway drainage is usually owned and operated by highways authorities, especially on main routes and water companies have no legal requirement to take highway drainage. However, there will also be locations within the study area where there is only one combined sewer, which is a much older system and transmits both foul and surface water. Although the proportion of ‘dirty’ water containing sewage is much less in these systems, the inclusion of foul water results in the need to treat all the discharge from these sewers at the WwTWs.

2.5.3 - 14 As mentioned in Section 2.5.1 above, wastewater is collected within ‘catchments’, under the power of gravity or artificially pumped. At the ‘downstream’ end of the catchments the wastewater is then either treated at a WwTW and the treated effluent released into a watercourse or it is pumped to another catchment which does contain a WwTW. Outside of the catchments, in the more rural areas of the Study Area, some of the wastewater is collected in septic tanks. Where potential development sites fall outside the current WwTW catchments they may be able to connect to the existing network, although, depending upon the topography, some parts of the sites may require pumps to connect to the gravity network. Alternatively they will require the inclusion of septic tanks on site. Further investigation regarding these sites will be required with AWS to establish whether they can be connected into the existing sewer network or whether new infrastructure will need to be installed.

2.5.3 - 15 Additional features of the sewerage network are Combined Sewer Overflows (CSOs). CSOs are located on the older combined sewer systems, mentioned above. As the combined sewers transmit both foul sewage and surface water they rapidly reach capacity and are at risk flooding during rainstorm events. Therefore at times of high flow CSOs operate at overflows to discharge some of the sewage out of the sewer system and into a nearby watercourse. However, this discharge contains surface water and foul effluent and thus poses health and ecological risks as well as aesthetic pollution.

2.5.3 - 16 One of the key aspects that could generally improve the network and the associated risks of flooding (and excessive flows into works) is the separation of surface water from sewage (i.e. combined systems) and the reduction in such systems is expected to help the long term flood risk and capacity issues in a number of locations. Increases in flow through these combined systems are unlikely to be acceptable due to the increase in pollutants that this would generate in the receiving watercourses.

2.5.3 - 17 As no network models were run or constructed as part of this WCS, limited comment can be made regarding the capacity of the wastewater collection network. Some assessment has, however, been made based upon discussion held with AWS and the comments they have provided regarding the Council’s Core Strategy consultations. In addition limited analysis has also been provided regarding the location of the wastewater network relating to the potential development locations. Similarly to the water supply network, discussed in Section 2.5 above, the locations of the wastewater network cannot be displayed for security reasons. Additional evaluation of the wastewater collection network should be carried out on a site specific basis once individual locations are identified.

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2.6 Water Quality and the Environment

2.6.1 Introduction

2.6.1 - 1 As mentioned above water quality is an important consideration when planning new development and a central concern in the principle of sustainable development. Any deterioration in quality will result in a negative impact on the biodiversity of the watercourse itself, the availability of water for abstraction and environmental sites located downstream. There are many ways in which pollution can enter a watercourse but the two main sources relevant to this study are from unsustainable development or agricultural practices within the catchment. This can either enter the watercourse directly (most commonly from insufficiently treated sewage effluent) or in the form of diffuse pollution from contaminated surface runoff.

2.6.1 - 2 The ‘capacity’ of the environment, in terms of the level of development it can sustainably accommodate, can be hard to define since it involves a level of subjectivity; the level of change that can be accommodated often depends on the level of impact, or decline in quality or services, that is felt to be acceptable. Within this WCS we are limited to considering those effects of development that affect the water environment. Within this environment no decrease in quality is considered acceptable, in line with the ‘no deterioration’ objective under the implementation of the Water Framework Directive.

2.6.2 Effect of Development upon Water Quality

2.6.2 - 3 In general there are three main ways in which new development might impact on the water environment:

1. Increased abstraction due to development can have a direct negative impact on the condition of surrounding surface watercourses or on the underlying groundwater resource. 2. Increased development can result in changes in water quality where watercourses receive discharges from WwTWs. 3. Lastly the impacts can have a knock-on effect on the environmentally significant sites. This is of most relevant for sites which are highly dependent on water resources and quality, such as grazing meadows or marshes.

2.6.2 - 4 It is therefore important that these risks are assessed and mitigation delivered before development commences.

Abstraction

2.6.2 - 5 The limits and issues surrounding abstraction relevant for the study area are reviewed within the sections relating to water resources.

WwTW Discharge

2.6.2 - 6 Untreated sewage discharges can have a significant impact on the environment. The inappropriate collection and treatment of sewage, and disposal of the sewage sludge (generated as a by-product of sewage treatment), have detrimental effects on river

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quality, mainly due to overloading of phosphates and nitrates resulting in eutrophication. Defra has identified nitrate and eutrophic sensitive areas in the UK which are being adversely affected by sewage discharges. However, for the worst affected watercourses the WwTW have been identified as Eutrophic Tertiary Treatment Works which have to provide a final treatment stage to raise the effluent quality before its release into the stream.

2.6.2 - 7 The impact of development upon the WwTW discharge consents forms the central part of this WCS water quality methodology. The assessment is based primarily on the location of WwTWs which will be potentially impacted by the new developments, and the connectivity between these WwTWs and key sites designated for their conservation value.

2.6.2 - 8 This WCS reviews the current quality of the watercourses within the Study Area and the potential impact that the potential development may have upon the watercourses and environmentally designated sites. The Environment Agency regularly assesses the quality of the watercourses in the UK. Until 2006 this was in the form of River Quality Objectives (RQO), but is now provided in the form of a River Basin Management Plan (RBMP), published in 2009. The Anglian RBMP is reviewed within this WCS and provides an assessment of the current status of waterbodies within the study area in addition to targets, which are based upon the requirement for all inland and coastal waters to achieve ‘good ecological status’ by 2015, as required under the Water Framework Directive (WFD).

2.6.2 - 9 To help assess the impact of the proposed development, the Environment Agency has calculated the required WwTW Indicative Consent Limits (limiting the volume or concentration of various elements permitted in the discharge) required to maintain water quality objectives whilst accommodating the proposed growth within the planning period. The required limits to ensure a) no deterioration in the current status of the watercourses and b) to meet the ‘good status’ required under the WFD have been provided and assessment made as to whether they are achievable using current economically viable technology.

Environmentally Designated Sites

2.6.2 - 10 The assessment of environmentally designated sites is strongly linked to the abstraction and WwTW discharge discussions above. Sites designated at a European8 or International9 level which have the potential to be affected are identified and described in Sections 3 to 6. The location of these sites within the District is shown on Figures 6a and 6b.

2.6.2 - 11 At a development site level SUDS can be implemented as part of new developments with the resulting effect of improving water quality and reducing additional rate and volume of surface water run off. This is discussed further in Section 2.8.

8 Special Protection Areas and Special Areas of Conservation are established under the EC Birds Directive and Habitats Directive respectively, and together form the Natura 2000 network 9 Additionally, this review has taken account of sites designated as wetlands of international importance under the Ramsar Convention.

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2.6.3 Directives

2.6.3 - 12 There are several European Union Directives that influence water quality and therefore sewage treatment levels, including the Urban Waste Water Treatment Directive (UWWTD)10, Water Framework Directive (WFD) and Freshwater Fish Directive. Summaries of the key points addressed within each of these Directives are summarised in Boxes 2.1 to 2.3 below. Additional Directives relating to agricultural runoff are discussed in Section 2.6.4 below.

Box 2.1 - Water Framework Directive

The European Water Framework Directive (WFD) became part of UK law in December 2003. The aim of the Directive is to protect and enhance the quality of all the waterbodies with an objective of achieving ‘no deterioration’. As such all waterbodies must meet the class limits for the status class declared in the final RBMPs with the aim to achieve good ecological status. It is the responsibility of the Environment Agency as the ‘competent authority’ to ensure the Directive is carried out, although it is also a requirement of Regulation 17 that all public bodies have regard to the RBMPs and their objectives. This Directive affects any discharges to designated waters, including industry and sewage treatment plants, and the standards set within it are taken into account when the Environment Agency sets discharge consent limits. It is therefore advised that, without appropriate mitigation, no development takes place within the catchments of WwTWs that are identified as having no, or limited, headroom available. It is the responsibility of AWS to implement the appropriate mitigation and ensure that their WwTWs discharge within the consented limits.

Box 2.2 - Urban Waste Water Treatment Directive

The aim of this Directive is to ensure all the wastewater in the EU is treated to the appropriate standard. Quality standards for effluent fall into categories depending upon the size of the WwTWs and the sensitivity of the receiving water body. Where populations exceed the threshold of the Directive the watercourses are given special designations, such as ‘Sensitive Areas (Eutrophic)’, which require the WwTWs to adhere to tighter limits on the quality of the effluent being discharged. As the populations increase, so the limits tighten. As such development which requires the utilisation of works identified in the UWWTD may be restricted by the environmental constraints on the discharge. Within Babergh the River Stour is designated ‘sensitive’ and, as their population catchments are greater than the 10,000 population equivalent limit, Sudbury and Great Cornard WwTWs have phosphate removal.

10 See the Defra web page http://www.defra.gov.uk/environment/quality/water/waterquality/sewage/uwwtd/index.htm

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Box 2.3 - Freshwater Fish Directive

The aim of the Freshwater Fish Directive is to protect and improve the quality of rivers and lakes to encourage healthy fish populations. Water quality standards are set for ‘designated’ areas which are significant bodies of water capable of supporting fish populations. In 2013 the waters currently designated as Fish Directive waters will become protected areas under the WFD.

2.6.4 Effect of Agricultural Practices on Water Quality

2.6.4 - 13 Agriculture is a major source of diffuse pollution. Diffuse pollution cannot be attributed to a precise point or incident, but is the cumulative effect of day to day activities over a large area, including agriculture, forestry, mining, construction and urban life. The main agricultural sources of diffuse pollution include silt from soil erosion, nutrients from the application of fertiliser or spreading of manure and pesticides from the handling and application of the chemicals. In addition to this pollution entering surface water sources, it can be carried within infiltrating rain water and pollute groundwater sources. On their website, Defra states the following statistics11:

• around 60% of nitrate and 25% of phosphates in English waters originate from agricultural land; • Agricultural practices contribute between 25-50% of pathogen loadings which affect England’s bathing waters; • Up to 75% of the sediment input into rivers can be attributed to agriculture, reducing water clarity and causing serious problems for fish, plants and insects; and • Pesticides are contaminating drinking water sources, requiring expensive treatment at water works.

2.6.4 - 14 Defra considers that the improved control of the application of manures and fertilisers to land is essential to improve the diffuse water pollution from agriculture. Studies to achieve this are ongoing, but the three currently recommended methods are:

• Promoting the Codes of Good Agricultural Practice • Encouraging Catchment Sensitive Farming • Implementing the EC Nitrates Directive

11 http://www.defra.gov.uk/Environment/water/quality/nitrate/intro.htm

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Box 2.4 - Codes of Good Agricultural Practice

These codes, until recently, consisted of Water, Air and Soil codes, which were introduced in the early 1990s and outline practical steps for preventing environmental pollution from farming activities. However, these have recently been reviewed and now consolidated into one document entitled ‘Protecting our Water, Soil and Air: A Code of Good Agricultural Practice for farmers, land growers and land managers’.

One of the aims of the code is to help farmers achieve the standards which will be required by the integrated approach to managing water quality and quantity across whole river catchments by 2015 as part of the Water Framework Directive. It does this by explaining the environmental impacts of farming practices and suggests methods of minimising these impacts with regards to management plans, use of farm buildings and structures, field work, specialised horticulture, wastes and water supplies to the farm. The full document can be found at on the Defra website12.

Box 2.5 - Catchment Sensitive Farming

Catchment Sensitive Farming is land management that keeps diffuse emissions of pollutants to levels consistent with the ecological sensitivity and uses of rivers, groundwater and other aquatic habitats, both in the immediate catchment and further downstream. It includes managing appropriately the use of fertilisers, manures and pesticides; promoting good soil structure and rain infiltration to avoid run-off and erosion; protecting watercourses from faecal contamination, sedimentation and pesticides; reducing stocking density; managing stock on farms to avoid compaction and poaching of land; and separating clean and dirty water on farms.

At present the advice element of the programme is being delivered through the England Catchment Sensitive Farming Delivery Initiative (ECSFDI) across 50 Priority Catchments in England alongside some limited capital grants. The ECSFDI was rolled out across 40 catchments in England in 2006 with another 10 catchments added, along with 7 extensions in October 2008. These were jointly identified by Natural England and the Environment Agency from data gathered for the Water Framework Directive (WFD) and cover approximately 40% of the agricultural area of England, including the whole of Babergh District, which is located within the Rivers Stour and Colne catchment.

12 http://www.defra.gov.uk/foodfarm/landmanage/cogap/response.htm

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Box 2.6 - EC Nitrates Directive This is an environmental measure designed to reduce water pollution by nitrate from agricultural sources to prevent such pollution from occurring in the future. The Directive requires Member States to:

• designate as Nitrate Vulnerable Zones (NVZs) all land draining to waters that are affected by nitrate pollution;

• establish a voluntary code of good agricultural practice to be followed by all farmers throughout the country (outlined above);

• establish an Action Programme of measures for the purposes of tackling nitrate loss from agriculture. The Action Programme should be applied either within NVZs or throughout the whole country; and

• review the extent of their NVZs and the effectiveness of their Action Programmes at least every four years and to make amendments if necessary. 66 Nitrate Vulnerable Zones (NVZs), 8% England, were designated in 1996 to protect drinking waters from nitrate pollution. A further 47% of England was designated as an NVZ in October 2002 to include all surface and groundwaters. On 1st January 2009 the NVZs were expanded again to cover 70% of England. Almost all of Study Area is now included within this zone. The boundary can be viewed in more detail on the Magic website13. Further information on this Directive can be found on the Defra website14.

Within these areas farmers will have to comply with a number of rules to promote best practice in the use and storage of fertiliser and manure (building upon the Code for Agricultural Practice for the Protection of Water), for example by following restrictions on the time of year that fertiliser can be spread on land and through storing excess manure.

2.6.5 Assessment Methodology

2.6.5 - 15 The impact of development upon Water Quality and the Environment has been assessed for the four growth options as follows:

2.6.5 - 16 The current situation has been identified from a review of the Anglian RBMP. The information provided assesses the current ecological, phosphorous and ammonia classifications for the various water bodies across the District and the potential cause of any ‘poor’ classifications. It also summarises the principal rivers within the District that are effected by WwTW discharge, their current status (with regards to Ammonia, Biological Oxygen Demand, BOD, and Soluble Reactive Phosphorous, SRP) and the required concentration of these elements for the watercourse to meet the objectives of ‘Good Status’ under the WFD15. A review is also provided of the environmentally

13 http://www.magic.gov.uk/website/magic/viewer.htm?startTopic=magicall&box=- 100000:0:800000:700000&chosenLayers=nvzIndex 14 http://www.defra.gov.uk/environment/quality/water/waterquality/diffuse/nitrate/directive.htm 15 This information was provided by the Environment Agency for use in this WCS.

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designated sites within the District, including their current condition and whether any ‘unfavourable’ status classifications are linked to any elements of the water cycle.

2.6.5 - 17 The growth scenarios (Growth Options 2, 3 and 4) were assessed through consideration of the increases in WwTW discharge flow that would be required by the proposed development. Where the proposed development was identified to require the WwTW to apply for an increase in flow consent the resulting Indicative Consent Limits, required to accommodate the maximum proposed growth within the catchment, were calculated by the Environment Agency. Two scenarios have been considered - the consent limits required to meet ‘no deterioration’ and the limits required to achieve ‘good status’ under the WFD. In both cases the limits required to accommodate the proposed development have been compared the tightened consent limits required to meet the WFD objectives if no development took place. As any tightening of consents will require an increase in treatment processes within the WwTW the Indicative Consent Limits have been compared to the ‘economic limit for conventional treatment’. Any that are considered beyond this limit, detailed below, are not considered viable, economically. Discussion is also provided regarding the potential impact of the proposed growth upon the environmentally designated sites identified as being linked to elements of the water cycle. The environmental assessments carried out during this study are not intended to act as an assessment under the Habitats Regulations. Instead, they identify potential significant effects for future consideration.

Economic Limit for Conventional Treatment:

• 1mg/l (90%ile) for Ammonia; • 5mg/l (90%ile) for BOD; and • 1mg/l (annual average mean) for Phosphate.

2.6.5 - 18 The maximum capacity has been identified through a review of the Indicative Consent Limits provided by the Environment Agency. Where potential discharge limits are identified due to the economic limit for conventional treatment being reached, the resulting maximum development that can be accommodated within that catchment is calculated.

2.6.6 Environmental Assessment Considerations and Assumptions

2.6.6 - 19 This study identifies the WwTWs which represent ‘pinch points’, and which may represent environmental constraints on expansion (e.g. increased discharge). The assessment of possible impacts on the environment, and constraints on development that these may impose, has been based on the modelled future flows used elsewhere in the WCS. It is therefore subject to the same constraints and caveats. Due to the potential issues with the data provided it is possible that further pinch points will be identified in subsequent studies.

2.6.6 - 20 Through consultation with AWS, a number of WwTWs have been identified as having no or limited capacity for growth, namely Bildeston, Chelmondiston, Elmsett, Capel St Mary, Hadleigh, Holbrook, Nayland, Sproughton and Sudbury. For the works predicted to require an increase in discharge consent as a result of proposed development within

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the planning period, the tightened consent limits have been calculated. For the works not identified as requiring an increase in CDWF or that are not impacted by the proposed growth, it is anticipated, following AWS advice, that some if not all of these sites will require some sort of additional technology to reduce the nutrient loads of their discharges. If additional development is proposed for any of these works advice regarding the feasibility must be sought from AWS and the Environment Agency.

2.7 Flood Risk

2.7.1 Introduction

2.7.1 - 1 Babergh District lies within the catchments of two river systems - the River Stour, forming the southern boundary of the District, and the River Orwell, forming the northeastern boundary. The two estuaries meet at the end of the Shotley peninsular, where they discharge into the North Sea.

2.7.1 - 2 The majority of watercourses within the District flow south, into the River Stour. The Main Rivers within this catchment consist of the River Glem, the Chad Brook, the Cornard Black Brook, the Assington Brook, the River Box, the , the Dodnash Brook, the Holbrook Stream and the Beaumont Creek. The northern edge of the District is drained by the catchment of the River Orwell, consisting of the River Gipping, the Belstead Brook and the Spring Brook. With the exception of the River Gipping, the River Stour and the River Glem, all the Main Rivers draining the District start within the District boundaries.

2.7.1 - 3 Due to the number of watercourses and its location at the downstream extent of the catchments of the River Stour and River Orwell, fluvial flooding poses a significant risk to a number of settlements within the District. This is illustrated by the extent of the Environment Agency fluvial Flood Zones 2 and 3, as shown in Figures 7a and 7b. Flood Zones 2 and 3 indicate the extent of the floodplain (the area that would naturally be affected by flooding if a river rises above its banks, or high tides and stormy seas cause flooding in coastal areas). Flood Zone 3 shows the area that could be affected by flooding, either from rivers or the sea, if there were no flood defences for the following flood events:

• from the sea by a flood that has a 0.5 per cent (1 in 200) or greater chance of happening each year; or • from a river by a flood that has a 1 per cent (1 in 100) or greater chance of happening each year.

2.7.1 - 4 Flood Zone 3b is the ‘Functional Floodplain’, which comprises land where water has to flow or be stored in times of flood. As stated in PPS25, the suggested approximation for the designation of this zone is land which would flood with an annual probability of 1 in 20 (5%) or greater in any year, or is designed to flood in an extreme (0.1%) flood.

2.7.1 - 5 Flood Zone 2 shows the additional extent of an extreme flood from rivers or the sea. These outlying areas are likely to be affected by a major flood, with up to a 0.1 per cent (1 in 1000) chance of occurring each year.

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2.7.1 - 6 Tidal flooding is also a risk to the District. The tidal boundary of the River Stour is located at Cattawade, just south of the village of Brantham and the tidal boundary of the River Orwell is located in the town of Ipswich and marks the downstream extent of the River Gipping. This places the entire coastline of the Shotley peninsular at risk of tidal flooding.

2.7.1 - 7 This WCS considers the following sources of information to assess the risk of all forms of flooding, including fluvial, tidal, surface water, sewers and groundwater (N.B. No hydraulic modelling was carried out for the purposes of this WCS):

• Environment Agency Flood Maps (fluvial and surface water); • Babergh District Level 1 and 2 Strategic Flood Risk Assessment (SFRA); • Regional Flood Risk Appraisal; • Catchment Flood Management Plans; and • Shoreline Management Plans.

2.7.2 Environment Agency Flood Maps

2.7.2 - 8 In accordance with PPS25, the location of new development should initially be based on the fluvial Flood Zones 2 and 3, defined in the Environment Agency’s Flood Map, which refer to the probability of sea and river flooding, ignoring the presence of any defences. Figure 7a and 7b show the location of the Environment Agency’s Flood Zones (Flood Zones 2 and 3) across the Study Area - these can be viewed in more detail on the Environment Agency’s website16 - in addition to Flood Zone 3a with climate change and Flood Zone 3b, which have been taken from the Babergh Strategic Flood Risk Assessment (SFRA). PPS25 limits the type of development that can take place within each Flood Zone. Further reference to the limits placed on development is provided in Section 7.

2.7.2 - 9 The Environment Agency have recently released two editions of surface water flood maps, identifying low lying areas of land which may be susceptible to surface water flooding. The currently methodology used to produce these maps is fairly crude, consisting of low resolution topographic data and no consideration of buildings or surface water drainage systems.

2.7.2 - 10 Both the Environment Agency fluvial and first edition surface water maps have been reviewed to determine the current flood risk for each key settlement.

2.7.2 - 11 The Flood Zone maps currently do not consider groundwater flooding or flooding from sewers. In addition, watercourses where the upstream catchment is less than 3km2 have not been mapped. The identification of these other types of flooding is considered within the SFRA, mainly through consideration of recorded flooding, and comments are made on individual sites or areas within the District.

2.7.3 Strategic Flood Risk Assessments

2.7.3 - 12 The Council has undertaken a Level 1 and 2 SFRA to support their evidence base. This document follows the requirements of “PPS25 - Development and Flood Risk” and is

16 http://www.environment-agency.gov.uk/homeandleisure/floods/31650.aspx

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designed to assist in the planning process by providing information to enable the “Sequential” and “Exception” Tests to be applied. The aim is to ensure that only appropriate development takes place within the floodplain, as mentioned above.

2.7.3 - 13 The SFRA provides a strategic assessment of flood risk at the District scale for all forms of flooding. It also assesses the location of flood defences and therefore the residual flood risk and associated impact upon development. This information has been used alongside the Environment Agency’s flood maps to determine the current risk of flooding to the District. In addition, the SFRA considers the impact of climate change upon the District and this information has been used to predict the future impact of flooding.

2.7.4 Catchment Flood Management Plan (CFMP)

2.7.4 - 14 Babergh district is covered by the North Essex CFMP in the south and the East Suffolk CFMP in the north. The CFMPs outline policies planned to reduce flood risk within the District. These have been reviewed to consider the impacts upon future developments.

2.7.5 Regional Flood Risk Appraisal (RFRA)

2.7.5 - 15 The RFRA for the was commissioned by the East of England Regional Assembly and finalised in March 2009. This publication takes into account the results of the most recently available (at the time of its development) SFRA and Catchment Flood Management Plans (CFMPs).

2.7.6 Shoreline Management Plan (SMP)

2.7.6 - 16 An SMP is a plan for managing flood and erosion risk for a particular stretch of shoreline over the short, medium and long term. SMPs identify best ways to manage coastal flood and erosion risk to people and the developed, historic and natural environment. They also identify opportunities where shoreline management can work with others to make improvements. Outcomes from the studies identify the 'intent of management' for the shoreline that achieves the best possible balance of all values and features and policies to deliver this management intent.

2.7.6 - 17 The second Essex and South Suffolk SMP has been developed by Royal Haskoning and was finalised in draft form October 2010. It builds upon findings and policies from the first Essex and South Suffolk SMP. The broad findings of the second plan are therefore used here along with the initial policies.

2.7.7 Impact of WwTW Flows on Flood Risk

2.7.7 - 18 For the WwTWs which are predicted to require an increased CDWF within the planning period, the increase in flow required to accommodate the growth proposed by the end of the planning period has been calculated. This has been compared with the Q95 flow at the closest gauging station to the WwTWs to determine a percentage increase in flow and therefore the potential impact of the increased flow upon flood risk. This has only been carried out for the Growth Options 2, 3 and 4.

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2.8 Demand Management and SUDS

2.8.1 Demand Management

2.8.1 - 1 National government policy for sustainable development includes efficient resource use and PPS12 emphasise the need for water efficiency as part of sustainable development. In addition the Department of Communities and Local Government (DCLG) requirements for the sustainable communities’ plan include higher standards of water efficiency and 25% savings. Government has stated a greater need for higher regional standards of water efficiency in response to the regional water resources position and the Water Act 2003 requirements place a duty on undertakers to achieve further water conservation and on public authorities to take into account the desirability of conserving water supplied to premises.

2.8.1 - 2 Development will increase the water requirement within the Study Area, but through managed water usage, wastage can be reduced and the developments made more sustainable in the long term to meet the Government requirements outlined above.

2.8.1 - 3 The three main methods used to promote sustainable water usage are:

1) Metering (to encourage conservative usage in the home); 2) Leakage control (to reduce loss through the pipelines); and 3) Sustainable housing (to increase the efficiency of water usage).

2.8.1 - 4 This is referred to as the Twin Track Approach whereby water resources are managed through investment in demand management alongside water resources development and all three methods have been referred to within AWS’ FWRMP and water resource strategies, discussed with regards to the current situation (Growth Option 1) in Section 3. An overall aim for new development using these measures is recommended to be for ‘water neutrality’, whereby the total water use after development does not exceed the total water use before development.

2.8.1 - 5 As demand management techniques are applicable to all new development without a negative impact on the environment, it is not necessary to assess their impact in terms of growth options.

2.8.2 Sustainable Drainage Systems

2.8.2 - 6 Within new developments, the incorporation of a suitably designed drainage system will be necessary and, as stated in the Floods and Water Management Act 2010 (FWMA), soon be mandatory, in order to mitigate the risk of surface water and overland flooding as well as the risk posed by the overloading of local sewers and watercourses. It is therefore essential that Sustainable Drainage policies are included in the Council’s LDF documents.

2.8.2 - 7 SUDS schemes must be designed at the planning stage based upon a number of site specific characteristics. Such a system should ideally be based upon Sustainable Drainage principles aimed at simulating natural processes and mitigating the impact of polluted surface water runoff upon the environment.

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2.8.2 - 8 Similarly to demand management, the implementation of SUDS techniques is not limited by the scale of development, but by site characteristics. A full review of the applicable SUDS dependent upon these characteristics is provided in Section 7. It is not possible to consider them for all the main settlements, but a general assessment has been made as to the potential restrictions placed upon the types of SUDS that can be implemented at each location in terms of soil permeability and groundwater sources. Within Section 3 the GWV17, proximity to SPZ and soil drainage has been identified for each of the main settlements using the methodology discussed below. As these definitions do not alter dependent upon development these assessments have not been repeated within Growth Options 2, 3, 4 and 5.

Soil Type

2.8.2 - 9 The most significant feature of the soil type with regards to SUDS is the permeability and therefore the soil infiltration rate (loosely extending from ‘sandy’, highly permeable soil types in one extreme to ‘clay’ based, impermeable soil types in the other). Whereas permeable soils can enhance the operation of some practices, enabling collected water to drain away from the surface much more rapidly, other practices are adversely affected, for example those intended to be permanent wetlands or ponds.

2.8.2 - 10 In addition highly permeable soils may create a negative impact where the development site is located close to contaminated land or has the potential to produce surface runoff with a high pollutant load, which should not be allowed to connect to the groundwater flows. Where contaminated land is present, the drainage of surface or roof water could mobilise the contaminants and therefore pose a risk to ‘Controlled Waters’ receptors. Therefore, proposals for the drainage of surface or roof water into the ground will need to take into account the outcome of a site investigation and any subsequent risk assessments and remedial options appraisals required for the site. Conversely, the requirement for surface or roof water drainage into the ground will need to be accounted for by any risk assessment or remedial options appraisal.

2.8.2 - 11 Impermeable soils however will result in a very slow infiltration rate of surface water which is not compatible with SUDS techniques relying upon the passage of water through the soil profile, such as porous pavement or infiltration devices. SUDS in these areas would therefore need to utilise storage rather than infiltration.

2.8.2 - 12 Maps of soil type for the Study Area are available from the National Soil Resources Institute website18. By zooming into the required area, an OS map of the area of interest will be displayed underneath the coloured soil classifications. When selected with the ‘identify’ tool, the characteristics of the soil type in question will be displayed to the left of the screen, including the drainage and texture. Alternatively a ‘Permeability Dataset’ is available upon request from the British Geological Survey, details of which can be found on the BGS website19.

17 Please note the GWV information has been recently superseded and developers should approach the Environment Agency for site specific information. 18 http://www.landis.org.uk/soilscapes/. 19 http://www.bgs.ac.uk/discoverymetadata/13603036.html

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2.8.2 - 13 Information detailing the appropriate types of SUDS dependent upon soil type is given in Section 7 (Table 7.2 provides information regarding soil type and Table 7.3 for restrictions relating to groundwater sources).

Groundwater

2.8.2 - 14 As many SUDS methods utilise the infiltration of surface water into the underlying soil, they interact with the groundwater systems. It is therefore important to consider whether a groundwater supply exists beneath the site (i.e. in the form of a principle or secondary aquifer), whether the supply is susceptible to pollutants due to the permeability of the overlying substrata, and also the depth of the groundwater table and its susceptibility to flooding.

2.8.2 - 15 Depending upon the proposed catchment and estimated surface water runoff pollutant load, the application of SUDS, especially those based upon infiltration, must be done so with care within areas designated by the Environment Agency as Source Protection Zones (SPZ) or highly vulnerable aquifers. The locations of the principle and secondary aquifers and their susceptibility to diffuse pollutants are shown on the Environment Agency’s Groundwater Vulnerability (GWV) dataset, shown in Figure 820. The SPZs, illustrated in Figure 9, define the locations of groundwater sources, such as wells, boreholes and springs used for public drinking water supply. These zones (defined in Box 2.7) indicate the risk of contamination from any activities that might cause pollution in the area -the closer the activity, the greater the risk. The shape and size of the zones depends upon the condition of the ground, how the groundwater is removed and other environmental factors.

20 Please note the GWV information has been recently superseded and developers should approach the Environment Agency for site specific information.

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Box 2.7 - Source Protection Zones Zone 1 (Inner protection zone)

Defined as the 50 day travel time from any point below the water table to the source. This zone has a minimum radius of 50 metres.

Zone 2 (Outer protection zone)

Defined by a 400 day travel time from a point below the water table. The previous methodology gave an option to define SPZ2 as the minimum recharge area required to support 25 per cent of the protected yield. This option is no longer available in defining new SPZs and instead this zone has a minimum radius of 250 or 500 metres around the source, depending on the size of the abstraction.

Zone 3 (Total catchment)

Defined as the area around a source within which all groundwater recharge is presumed to be discharged at the source. In confined aquifers, the source catchment may be displaced some distance from the source. For heavily exploited aquifers, the final Source Catchment Protection Zone can be defined as the whole aquifer recharge area where the ratio of groundwater abstraction to aquifer recharge (average recharge multiplied by outcrop area) is >0.75. There is still the need to define individual source protection areas to assist operators in catchment management. (Environment Agency website)

N.B. Although the location of these SPZs are valid as of January 2010, the Environment Agency periodically reviews and updates the maps. The location of these zones may therefore change in the future.

2.9 Data Limitations

2.9.1 - 1 As with all studies of this nature, the analysis relies heavily on data and information supplied by third parties. This is augmented by work carried out directly for the study. This WCS has pulled together much data from many parties to enable this report to be prepared. However there are some limitations with the process which should be noted, and some points for future projects relating to the data. Firstly, following abolition of the RSS, there is uncertainty surrounding the growth targets for the District. The locations assessed are broad in scale with individual sites as yet unknown. Further assessment may therefore be required on a site specific basis, once identified.

2.9.1 - 2 Furthermore, much of this data is not static and is regularly being updated and revised as new information is collected or trends in development change. This study reflects a point in time and may need to be reconsidered at a later point. This study is based on data available at the start of May 2011 and does not include changes to data such as revised development scenarios introduced since then. Future revisions of the study to accommodate any changes will be required on a regular basis.

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3 GROWTH OPTION 1: CURRENT SITUATION

3.1 Introduction

3.1.1 - 1 The current situation has been assessed for each of the elements of the water cycle using the data discussed in Section 2 above. This provides a baseline scenario for the District as it stands at present with no new development.

3.2 Water Resources and Supply

3.2.1 Water Resources

3.2.1 - 1 The relevant WRZ and PZ for each development area have been identified in Table 2.2. Both WRZ09 and WRZ10 are identified in the FWRMP as having a small surplus of available water against target headroom at the start of the planning period.

3.2.1 - 2 With regards to the CAMS, as all abstraction licenses are now issued with a Hands Off Flow (a level of flow below which no water may be taken) for environmental protection, all areas experience some restriction on water availability. Within Babergh District Council area, the Resource Assessment indicates that water availability is generally poor. Only one or two very small waterbodies, plus the Belstead Brook, have water available at lower flows. All the other watercourses either have no water available for further licensing at low flows or are over-licensed, indicating a shortage of water at low flows, if all licences were utilised at one time. The groundwater in the area is currently over-abstracted, causing unacceptable damage to the environment.

3.2.1 - 3 For the existing residential and commercial developments which obtain their water supply from AWS there are sufficient water resources at present across the entire District. However, any development or industry which relies upon direct surface or groundwater abstraction may experience a lack of available water .

3.2.2 Water Supply

3.2.2 - 4 AWS have identified that there are currently no problems or low pressure areas within the water supply network anywhere in the District.

3.3 Wastewater Treatment and Collection

3.3.1 Wastewater Treatment

3.3.1 - 1 Babergh District is served by 45 WwTWs, listed in Table 3.1, which vary in catchment size and capacity. Of these, four of the WwTWs have catchments that extend beyond the District boundaries and therefore serve settlements in neighbouring Local Authority areas in addition to those located within Babergh District, as shown in Figures 5a and 5b.

3.3.1 - 2 The available headroom of the WwTWs has been assessed through comparison of their CDWF with the 2010 measured DWF. This information is shown in Table 3.1 below, with the WwTWs identified as having no available headroom highlighted in red.

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Table 3.1 - WwTW Current Capacity WwTW Name WwTW Settlements Measured CDWF Available Headroom? 4 Code DWF (m³/d) (Average 2004 - 2010) (m³/d) Capel St Mary; Bentley BENTST Yes Bentley 641 83 Bildeston BILDST Bildeston; Hitcham 2502 3103 Minimal (Limited) 5 Boxford BOXFST Boxford; Polstead 3431 420 Minimal Brantham; Sutton; Brantham BRANST Yes Tattingstone 552 910 BRENST Brent Eleigh N/A - Small Package Plant N/A 0 Brettenham BRETST Brettenham N/A 0 N/A - Small Package Plant Bures-Wissington Bures BUREST Minimal Road 207 250 Ipswich Fringe; Yes Chantry CHANST Copdock; Washbrook 34021 5200 Chelmondiston CHEMST Chelmondiston 1292 1913 Yes (but Limited) 5 Cliff Quay CLQYST Ipswich Fringe 23370 34213 Yes Cockfield-Green Cockfield COCGST N/A - Small Package Plant Lane Great Green N/A 0 Cockfield- Cockfield COCMST N/A - Small Package Plant McKenzie Place Smithwood Green N/A 0 Cockfield-Windsor COCWST N/A - Small Package Plant Green N/A 0 Dedham DEDHST Stratford St Mary 7571 610 No East Bergholt EBERST East Bergholt 3971 560 Yes Elmsett ELMSST Hadleigh; Elmsett 3342 334 No ERWAST Shotley N/A 0 N/A - Small Package Plant Glemsford GLEMST Glemsford; Hartest 1426 1032 No Sudbury; Great Yes Great Cornard GCORST Cornard 1524 2450 Great Yes GWLDST Great Waldingfield Waldingfield;

Acton 315 470 Great Wenham GWENST Capel St Mary 3452 6173 Yes (but Limited) 5 Groton-Castlings Groton GROCST N/A - Small Package Plant Heath N/A 0 Groton-Park Groton GROPST N/A - Small Package Plant Corner N/A 0 Hadleigh HADLST Hadleigh 14862 17003 Minimal (Limited) 5 Hintlesham- Hintlesham Yes HINTST Wilderness Hill 60 136 Holbrook HOLKST Holbrook 5002 500 No Kersey KERSST Kersey N/A 0 N/A - Small Package Plant Lavenham LAVHST Lavenham 232 480 Yes

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WwTW Name WwTW Settlements Measured CDWF Available Headroom? 4 Code DWF (m³/d) (Average 2004 - 2010) (m³/d) Lindsey-Church Lindsey LINCST N/A - Small Package Plant Road N/A 0 Lindsey-Frogs Lindsey LINFST N/A - Small Package Plant Hall N/A 0 Long Melford; Long Melford LMELST Acton; Sudbury; Yes Great Waldingfield 798 1571

Milden-Powney MILPST N/A - Small Package Plant Street N/A 4 Monks Eleigh MONEST Monks Eleigh 1001 111 Minimal Nayland, Nayland NAYLST Polstead; Stoke by No Nayland 10382 1038 NEDGST N/A - Small Package Plant Crowcroft Road N/A 0 Nedging-Tye NEDTST N/A 0 N/A - Small Package Plant PRESST N/A 0 N/A - Small Package Plant SHIMST Lawshall 132 260 Yes Shotley-Overhall Shotley Yes SHOTST Fm 3391 662 Sproughton- Ipswich Fringe; SPRCST No Church Lane Sproughton 4182 418 Sudbury SUDBST Sudbury 49022 4902 No THOSST N/A 0 N/A - Small Package Plant THMBST N/A - Small Package Plant Blacksmith N/A 0 Thorpe Morieux THMPST N/A - Small Package Plant Post Office N/A 0 WHATST 441 95 Yes NOTES 1 Anomalies removed from the 2004 - 2010 average calculations 2 WwTW stated to be at capacity by AWS, therefore DWF = CDWF 3 CDWF manually lowered by AWS to provide a ‘safety factor’ in calculations 4 ‘Minimal’ represents <20% headroom remaining 5 Limited status identified by AWS

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3.3.1 - 3 The data provided by AWS indicates that the following seven WwTWs currently have no available capacity and a further seven have minimal or limited headroom:

• Dedham • Elmsett • Glemsford • Holbrook • Nayland • Sproughton • Sudbury

3.3.1 - 4 It is recommended that further discussion is held between AWS and the Environment Agency before any development is progressed within the catchments of these WwTWs, once the development sites and trajectories have been finalised.

3.3.2 Wastewater Collection

3.3.2 - 5 AWS have stated that, although capacity is limited, there are no problems with the current wastewater network. This is reiterated within the SFRA which states that sewer flooding is not a significant issue within Babergh District. However, the SFRA does state that there is a history of occurrences of sewer flooding problems in the town of Sudbury and within the Stratford St Mary and East Bergholt areas. All occurrences have affected a small number of properties and typically occur due to an influx of surface water into the sewer network. As the SFRA was completed over a year ago, most of these issues are likely to have been resolved by AWS (if there was a significant risk of repeat flooding or if funding was available within the AMP programme to remove risk). As such, they are unlikely to represent a current lack of capacity within the network.

3.4 Water Quality and the Environment

3.4.1 Water Quality

3.4.1 - 1 Maps of current ecological, phosphorous and ammonia classifications across the District have been provided by the Environment Agency. The current ecological and physico- chemical quality status’ shown on these maps and within the Anglian RBMP for all the waterbodies within Babergh District are summarised in Appendix E. For the surface water bodies (rivers, brooks and lakes) this is shown in terms of Ecological status and Ammonia and Phosphorus classifications. For groundwater bodies it is shown in the form of Quantitative status and Overall status, scored on a scale of ‘Good’, ‘Moderate’ or ‘Poor’21. These classifications are the baseline from which improvements and the ‘no deterioration status’ of the WFD is measured.

3.4.1 - 2 Most of the surface water bodies within Babergh District have been recorded as having a ‘moderate’ ecological status with a target to improve to ‘good’ within the planning period. The tidal River Orwell is the only watercourse that has already been given a ‘good’ overall status. Three watercourses - the Belstead Brook, the Bildeston Brook and the River Gipping - have been classified as having ‘poor’ ecological status. Both groundwater sources have also been assigned an overall status of ‘poor’.

21 NB Ammonia and Phosphorous classifications also have a status of ‘High’, which is a level above ‘Good’

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3.4.1 - 3 Within the catchment of the River Stour, phosphorous levels have been classified as moderate to poor in the main river channel, in addition to the River Box and River Brett. Phosphorous levels have, however, been classified as moderate to good in all the tributaries. The Chad Brook, the Dodnash Brook and the Holbrook Stream are all classified as ‘good’ with regards to phosphorous. The catchment of the River Orwell and its tributaries have been identified as having ‘moderate’ phosphate levels within Babergh District. Ammonia has been classified as ‘high’ (denoting undisturbed conditions within the watercourses) across the District and the Environment Agency have emphasised that this level must be maintained. The tidal River Stour and River Orwell, however, have been classified as ‘moderate’ with regards to nitrogen.

3.4.1 - 4 The relatively high levels of phosphorous within some of the watercourses and nitrogen within the tidal areas can, most likely, be attributed to the high level of agriculture within the District. The Catchment Sensitive Farming initiative and Nitrate Vulnerable classifications, as outlined in Section 2.6 have been identified as being applicable across the entire District. It is therefore important that improvements to the nitrate and phosphate levels are made through the following initiatives by the Council (although initiatives are set by Defra they will require implementation and promotion by the Council):

• promotion of the Codes of Good Agricultural Practice, especially now the updated version has been released; • Participation in the Catchment Sensitive Farming Initiative, if the study area is included within the Priority Catchments list either now or in the future; and • Recognition of their location within a NVZ and application of the updated EC Nitrates Directive Action Programme.

3.4.2 WwTW Discharge

3.4.2 - 5 It is paramount that the WwTWs operate within their biological discharge consents and therefore do not contribute to the degradation of the nitrate and phosphorous levels noted above. The consented discharge limits (CDWF), outlined in Table 3.1, account for the required limits of Ammonia, BOD and Phosphorous under the WFD. It is therefore essential that no development takes place in the catchments of the WwTWs noted in Table 3.1 as having no or limited capacity until the development trajectories and sites are confirmed and the required adjustment in the consented flows are calculated, reviewed and agreed with the Environment Agency. Such a review will ensure that the following key objectives of the WFD are met through any revision in consented discharge:

1) Avoid deterioration in the current water quality status (as set out in the Anglian RBMP and summarised in Appendix E); and 2) To achieve (by 2027 at the latest) ‘Good’ status water quality.

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3.4.2 - 6 Table 3.2 presents the current WFD status of the principal22 rivers within Babergh District, as provided by the Environment Agency. There should be no deterioration beyond any of the class boundaries. It also shows the indicative levels required to meet the WFD ‘Good Status’ objective.

Table 3.2 - Current WFD Objectives for Principle Rivers within Babergh District (as reported in the Anglian RBMP, December 2009)

Current Status Good Status Objectives (‘no deterioration’ objective) WwTW Waterbody Downstream Ammonia BOD1 SRP2 Ammonia BOD1 SRP2 Sample (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) Point 90%ile 90%ile AA 90%ile 90%ile AA Glem Moderate Good Poor Glemsford GL0110 0.6 n/a 0.12 GB105036040970 (1.1) (5) (1) Long Stour High High Poor ST08 n/a n/a 0.12 Melford GB105036040940 (0.3) (4) (1) Stour US High High Poor Sudbury Lamarsh ST07 n/a n/a 0.12 (0.3) (4) (1) GB105036040940 Stour High High Moderate Nayland ST03 n/a n/a 0.12 GB105036040940 (0.3) (4) (0.25) Black Brook High Good Poor Dedham ST0120 n/a n/a 0.12 GB105036041000 (0.3) (5) (1) Brett High High Poor Hadleigh BT01 n/a n/a 0.12 GB105036040930 (0.3) (4) (1) Belstead Brook High High Poor Elmsett BEL010 n/a n/a 0.12 GB105035040440 (0.3) (4) (1) Gipping High Good Moderate Sproughton GIP200 n/a n/a 0.12 GB105035046280 (0.3) (5) (0.25) Transitional waterbody – the above WFD elements do not apply. Clarity is Brantham GB205036041090 awaited on what parameters to consider for discharges to transitional and coastal waters. Values provided by the Environment Agency NOTES: 1 Biological Oxygen Demand 2 Soluble Reactive Phosphorous

3.4.3 Environmentally Designated Sites

3.4.3 - 7 There are a number of environmentally designated sites within Babergh District, as shown on Figures 6a and 6b. Two multi-designation (Ramsar, SPA and SSSI) sites are located within the District, namely the Stour and Orwell Estuaries. Other designated sites consist of SSSIs, a number of which are water dependent and therefore linked to the water resources required within the District. Where they are located close to watercourses, they are also linked to the WwTWs located within the District and the discharge which they emit, most notably the Stour and Orwell estuaries.

22 WwTWs most likely to be influenced by the proposed development outlined in Growth Options 2, 3 and 4.

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3.4.3 - 8 Their current condition, obtained from Natural England’s website, is summarised in Table 3.3. A number are currently in unfavourable or recovering condition and, as such, effort should be made to assist Natural England in improving their condition. It is also paramount that new development does not negatively impact any of these sites (e.g. from water use, wastewater effluent or surface pollution). Further information about these sites can be obtained from Natural England’s website23:

Table 3.3 - Current Condition of Environmentally Designated Sites

Environmentally Designation Current Reason for Unfavourable Potential Link to Designated Site Condition Status Development SSSI Mixed Grazing Bobbitshole, SSSI Favourable Belstead Brent Eleigh Woods SSSI Unfavourable Process/structure recovering / Favourable Cattawade Marshes SSSI Unfavourable Water level management Wastewater recovering Discharge; Water Use, Flood Risk Cornard Mere, Little SSSI Unfavourable Drainage; Inappropriate Wastewater Cornard declining water levels; Siltation; Discharge; Water Water abstraction Use, Flood Risk Woods SSSI Unfavourable Deer grazing/browsing recovering / Unfavourable declining Elmsett Park Wood SSSI Unfavourable Woodland management recovering Freston & Cutler's SSSI Mixed Deer grazing/browsing; Woods Drainage; Forestry and woodland management; Inappropriate weed control Frithy & Chadacre SSSI Unfavourable Deer grazing/browsing; Wood recovering / Forestry and woodland Unfavourable management declining SSSI Unfavourable Structure recovering SSSI Favourable SSSI Mixed Deer grazing/browsing; Forestry and Woodland Management

Kentwell Woods SSSI Mixed Deer grazing/browsing; Forestry and Woodland

23 http://www.sssi.naturalengland.org.uk

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Environmentally Designation Current Reason for Unfavourable Potential Link to Designated Site Condition Status Development Management; Structure Lineage Wood & SSSI Mixed Inappropriate Railway Track, Long cutting/mowing; Melford Inappropriate scrub control; Forestry and woodland management Milden Thicks SSSI Unfavourable Regeneration Recovering / Favourable Thorpe Morieux SSSI Unfavourable Deer Woods Recovering / Favourable River Ramsar/SPA/SSSI Unfavourable Coastal squeeze Downstream of declining / WwTWs Favourable River Orwell Estuary Ramsar/SPA/SSSI Mixed Coastal squeeze Downstream of WwTWs

3.4.3 - 9 The following paragraphs detail the main features of the four sites identified above as at risk from the potential impacts of development upon the water cycle.

Cattawade Marshes SSSI

3.4.3 - 10 The Cattawade Marshes lie at the head of the Stour Estuary, between freshwater and tidal channels of the River Stour. These grazing marshes with associated open water and fen habitats are of major importance for the diversity of their breeding bird community, which includes species that have become uncommon throughout lowland Britain as a result of habitat loss. The site has benefited from a sympathetic management regime aimed at enhancing the ornithological interest. The marshes are also of value as a complement to the adjacent Stour Estuary SSSI where breeding habitats for birds are relatively scarce.

3.4.3 - 11 The undisturbed nesting habitats are particularly favourable to waders and wildfowl. Redshank, Lapwing and Oystercatcher breed within the cattle-grazed pasture, while Ringed Plover and Shelduck nest on the relict seawalls. Marshy pools and a system of dykes within the grassland, together with dense riverside vegetation, provide further nesting habitats, most notably for Shoveler, Teal, Tufted Duck and Water Rail.

3.4.3 - 12 The main factor affecting this site is water level management, with a requirement for increased winter water levels. However, recent works have been undertaken at this site which should enable improved water level management.

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Cornard Mere SSSI

3.4.3 - 13 Cornard Mere comprises a seasonally flooded area of fen, species-rich ruderal herb vegetation, woodland, scrub and neutral grassland occupying a shallow basin on a mixture of peat and glacial sands. Traditional management with regular cutting maintains a varied flora with many species typical of wetland communities. The Mere attracts considerable numbers of over-wintering snipe and provides a habitat for a variety of insects, including an uncommon sawfly.

3.4.3 - 14 This site suffers from inappropriate water levels, drainage and siltation, linked to water abstraction. This has caused major changes in the way water arrives and moves off the site, altering the vegetation and, most notably, the swamp community.

Stour and Orwell Estuaries

3.4.3 - 15 The Stour and Orwell estuaries straddle the eastern part of the Essex/Suffolk border. They are wetlands of international importance, comprising extensive mudflats, low cliffs, saltmarsh and areas of vegetated shingle. The estuaries provide habitat for an important assemblage of wetland birds in the non-breeding season and also support internationally important numbers of wintering and passage waterbirds. The Orwell is a relatively long, narrow estuary with extensive mudflats that support large areas of eelgrass. Saltmarsh tends to be sandy and fairly calcareous with a wide range of communities, while grazing marshes adjoin the estuary at Shotley. The Stour Estuary is a relatively simple estuary with areas of higher saltmarsh, a sandy outer area and a muddier inner section, rich in invertebrates. The shoreline vegetation varies from wooded cliffs, to coarse grasses. The site also holds several nationally scarce plants and British Red Data Book invertebrates. The site is primarily designated due to the large number of bird species it receives including important numbers of breeding avocet. Surrounding areas of agricultural land, outside the SPA, are also used by feeding geese and waders to roost.

3.4.3 - 16 The main factors currently affecting the Stour and Orwell Estuaries SPA and Ramsar site are coastal squeeze, port development, maintenance dredging and sea level rise, causing the erosion of saltmarsh. This indicates that coastal processes dominate the site. However the upstream sections of the site will be more influenced by fluvial processes and impacts upon the riverine environment.

3.4.3 - 17 The current discharge consents assigned to each WwTW have been set by the Environment Agency. In order to ensure that such activities are compatible with the requirements of the Habitats Regulations, specifically to ensure that these can be determined as having ‘no adverse effect on site integrity’, the Environment Agency has reviewed all the activities it consents through the Regulation 50 Review of Consents (RoC) Project (Regulation 50 under the 1994 Habitats Regulations, addressed by regulations 63 and 67 of the 2010 regulations (as amended)). The Review of Consents found that the current consented discharges have no adverse effect on the integrity of the Stour and Orwell SPA and Ramsar site.

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3.5 Flood Risk

3.5.1 Fluvial and Tidal

3.5.1 - 1 The watercourses within Babergh District, outlined in Section 2.7.1, pose a significant fluvial flood risk to the District, including many of the main settlements, a number of which partially fall within Flood Zone 2 (the 0.1% annual probability, 1000year average return period) and Flood Zone 3 (the 1%, 100 year average return period).

3.5.1 - 2 The areas of Babergh District which are within tidal Flood Zones 2 and 3 include those adjacent to the River Stour downstream of Dedham Bridge, parts of the Stour estuary (including along Dodnash Brook), along parts of the Orwell estuary, and the River Gipping through the Sproughton area.

3.5.1 - 3 To mitigate the risk, a number of flood defences are located along the Main Rivers and tidal estuaries, in the form of raised defences (e.g. Sudbury), sea walls (e.g. Brantham) and bypass channels (e.g. Nayland) and the level of protection provided by these defences varies across the District. The Environment Agency maintains the majority of these defences, although some are privately owned (most notably along the north bank of the River Stour estuary). Tidal sluice gates operate at the tidal boundary of the River Stour and River Gipping/Orwell to protect the upstream settlements from high tides and surges. As a result of these defences, the Environment Agency Flood Zones 2 and 3 represent the ‘worst case’ unmitigated scenario. More detail regarding the risk of fluvial flooding across the District is provided in the SFRA, available on the Council’s website24.

3.5.1 - 4 In addition to the flood defences, the Environment Agency provides a flood warning service for fluvial and tidal flooding in Babergh District using its Floodline Warnings Direct Service (FWD). The following seven flood warning areas serve Babergh District:

• 051FWFEF2 – River Stour from downstream of Kedington to Sudbury (fluvial); • 051FWFEF3A – River Stour from Sudbury to, and including, Boxted (fluvial); • 054FWFSF5A – River Box from Boxford to, and including, Thorington Street (fluvial); • 051FWFEF3B - River Stour from Boxted to (fluvial); • 054FWFSF5B – River Brett from, and including Lavenham to Higham (fluvial); • 054FWCDV4A - Coast from Shingle Street to Clacton, including Felixstowe and Ipswich; and • 054FWFSF4G – River Gipping at Ipswich, upstream of London Road Bridge. 3.5.2 Surface Water

3.5.2 - 5 An assessment of surface water flood risk to the potential development areas has been undertaken and obtained from the SFRA. This has accounted for historic flooding occurrences, the potential for future surface water flooding and flood risk from the sewer network. In addition, although briefly considered within the SFRA, the Environment Agency’s ‘Areas Susceptible to Surface Water Flooding’ maps have also been reviewed

24 http://www.babergh-south- suffolk.gov.uk/Babergh/Home/Planning+and+Building+Control/Local+Development+Framework/Strategic+Flood+Ri sk+Assessment.htm

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to provide a growth area specific assessment. Please note, however, that this is a starting point for consideration of surface water flood risk and is not a definitive analysis. Further assessment should be made on a site specific basis.

3.5.3 Groundwater

3.5.3 - 6 In general the Babergh drift geology, which overlies the chalk, is impermeable so the processes which promote groundwater flooding are restricted. This is assisted by the constantly high levels of groundwater abstraction in the region. Although there have been some isolated historical incidents of groundwater flooding across the Babergh District this is not a major flood risk issue and was not considered further within the SFRA.

3.5.4 Canals

3.5.4 - 7 No canal networks are present in the Babergh District and therefore flood risk from this source has not been considered as part of this WCS.

3.5.5 Reservoirs

3.5.5 - 8 Alton Water is the only major reservoir within the Babergh District. It is owned by AWS and the safety of the dam is maintained through regular inspection by specialised independent engineers under the strict remit of the Reservoirs Act 1975, which is overseen by the Environment Agency. There is thus an extremely low chance of dam failure. Furthermore, the dam is close to the coast and there are no settlements downstream. Therefore the effect of a failure would be limited and has not been included within this WCS, although the Council may wish to review this if any additional information regarding particular waterbodies is obtained at a later date.

3.5.6 Current Flood Risk

3.5.6 - 9 The current flood risk and mitigation measures proposed or provided to the key settlements within the District are summarised in Table 3.4 below:

Table 3.4 - Current Flood Risk to Babergh Key Settlements

Fluvial & Tidal Surface Water Residual Risk Flood to Current Warning FZ21 FZ31, 2 FZ3b1 Historic Surface Housing2 Area Settlement Surface Water - Flood

Water Map (More 1000 100yr/ 100yr/ 1000 20yr Flood susceptible) 3 yr 200yr Sewer Flooding Defence Flood 200yr yr Hadleigh F F F Partial Yes Sudbury F F F Highways Yes Yes Ipswich Fringe F/T F/T F/T Yes Partial Yes Low Low Partial Acton Bildeston F F F Yes No Boxford F F F Yes Yes Brantham

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Fluvial & Tidal Surface Water Residual Risk Flood to Current Warning FZ21 FZ31, 2 FZ3b1 Historic Surface Housing2 Area Settlement Surface Water - Flood

Water Map (More 1000 100yr/ 100yr/ 1000 20yr Flood susceptible) 3 yr 200yr Sewer Flooding Defence Flood 200yr yr Bures St Mary F F F Highways Yes Yes Not Modelled Yes Chapel St F F F Partial Mary Chelmondiston T T T Partial East Bergholt Partial Yes Glemsford

Great

Waldingfield

Holbrook Partial Lavenham F F F Highways Partial Yes Long Melford F F F Highways Yes Yes Not Modelled Yes Nayland F F F Highways Yes Yes Not Modelled Yes Shotley T T T Yes Not Modelled Yes Assington Bentley Cockfield F F F Yes Copdock and F F F Yes Washbrook Elmsett Hartest F F F Yes Hintlesham Hitcham F F F Yes Kersey F F F Yes Lawshall Monks Eleigh F F F Highways Yes Yes Polstead Highways Partial Yes Sproughton T T T Yes Yes Not Modelled Yes Stoke by

Nayland Stratford St F F F Yes Yes Yes Low High Yes Mary Stutton Partial Tattingstone F F F Yes NOTES 1 F - Fluvial Flooding ; T - Tidal Flooding 2 100yr denotes fluvial and 200yr denotes tidal 3 This information has been obtained from the Environment Agency’s ‘Areas Susceptible to Surface Water Flooding’ maps. Please note a second edition surface water flood map has now been produced entitled ‘Flood Map for Surface Water’. Neither map is suitable for identifying whether an individual property will flood and should not be relied on alone to show expected areas at risk from surface water flooding

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3.6 Demand Management and SUDS

3.6.1 Water Usage

3.6.1 - 1 AWS’ FWRMP states that meter penetration with AWS’ supply area is already high (65%), leakage is low and water consumption is favourable. The following demand management proposals are included with significant investment allocated in their business plan for these aspects after 2010-15:

• Further targeted leakage control (maintaining the current 210Ml/d); • Enhanced metering (aiming for 90% by 2035 through new home installation and pro-active customer campaigns); • Pressure reduction schemes; • Installation of water efficiency devices; and • Water audits.

3.6.1 - 2 The Council can assist AWS in meeting these targets by promoting the implementation of sustainable housing across the District. The Code for Sustainable Homes was published by the Department of Communities and Local Government in December 2006. From May 1st 2008 the assessment of new developments against Level 3 of this Code became mandatory, although there is now an aim towards the adoption of Level 4. In terms of water use, the code states that for Levels 3 and 4 the home should be designed to use no more than 105 litres of water per person per day.

3.6.1 - 3 The Council may benefit from a review of the Level 4 requirements against how the present housing stock compares (for example using Ofwat data). The code uses a points system to identify the most efficient homes, with higher points being awarded for the most efficient. Points are awarded for internal potable water consumption (i.e. reduced toilet cistern sizes), external potable water consumption (i.e. water butts, grey water recycling and rainwater harvesting discussed below), surface water run off (specifically the use of SUDS) and flood risk, which is generally based on development location. There are similar measures against which commercial development can be assessed, dependent upon its intended use. These are set by the Building Research Establishment (BRE) and are known as BREEAM standards (BRE Environmental Assessment Method), upon which there is increasing pressure for commercial buildings to adhere. These can be viewed in detail on the BREEAM website25.

3.6.1 - 4 Further information regarding the key aspects of sustainable housing and the Code for Sustainable Homes is provided in Section 7.

3.6.2 SUDS

3.6.2 - 5 SUDS should be incorporated as far as possible in all new developments and in the retrofitting of existing sites. This section reviews particular restrictions to infiltration SUDS. However, this should not deter the use of sustainable drainage as numerous alternatives, such as rainwater harvesting will be feasible. Opportunities for strategic SUDS schemes for larger developments, or groups of developments should also be

25 http://www.breeam.org.

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investigated (this may require the Council to take a lead in providing funding and recover the costs via Section 106, for example).

3.6.2 - 6 Most of the District is underlain by aquifers, as shown on Figure 8, although only a small proportion, in the western side of the District is classified as a principal aquifer. In terms of vulnerability, most of the aquifers are classified as being intermediate to low with only the River Stour Valley corridor and an area around the River Gipping being classified as high. However, these more vulnerable areas include the larger settlements of Sudbury, Hadleigh and the Ipswich Fringe.

3.6.2 - 7 The location of the SPZs are shown in Figure 9. There are a large number of SPZs located within the District boundaries and the entire western half of the District is classified as being within the catchment of a SPZ. The SPZ centres are located along the valleys of the River Stour and River Brett and just south of Ipswich. All the larger settlements, including Sudbury, Hadleigh and the Ipswich Fringe are located within the Inner and Outer zones.

3.6.2 - 8 A large portion of the District is underlain by freely draining soils26, although a large area of the central part of the District suffers from impeded or slightly impeded drainage.

3.6.2 - 9 All these factors will present restrictions upon the suitable types of SUDS for use in the District, with land above vulnerable groundwater sources, the inner zone of SPZs and impeded drainage suffering from the greatest restrictions. However, suitable SUDS for each location are available (please see Section 7 for a description of a range of schemes). As stated within the new Floods and Water Management Act developers are now required to submit appropriate SUDS proposals with their planning applications for review and adoption by the SUDS Approval Board (SAB), the responsibility of which will rest with the Lead Local Flood Authority (i.e. Suffolk County Council).

3.6.2 - 10 Table 3.5 summarises the SUDS restrictions applicable to each of the main settlements within the District. As many of the settlements are located above split geology, site specific assessments will be required for an accurate assessment. The right hand column provides an overall comparative assessment of the restrictions upon the use of SUDS in each location. As some form of SUDS is available for all site characteristics none of the areas have been given an overall classification of ‘red’. Please note this assessment is indicative and the suitability of a proposed site for the use of different SUDS techniques will need to be determined on a site by site basis. Particular consideration needs to be given to groundwater vulnerability, contaminated land and pollution control.

3.6.2 - 11 As the restrictions placed on the type of SUDS do not vary with different levels of growth and there is not a ‘maximum capacity’ for their implementation, this table has not been repeated within Sections 4, 5 and 6.

26 Reference Soilscapes http://www.landis.org.uk/soilscapes/

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Table 3.5 - Settlement Specific SUDS Restrictions

GWV* SPZ Drainage Overall Potential Zone 1 Zone 2 Site Zone 3 Development Inner Outer # Aquifer Vulnerability Total Site Protection Protection Catchment Zone Zone RESIDENTIAL 1 Hadleigh (east: Secondary Intermediate Slightly Impeded G area 1) 2 Hadleigh (west: Feely Draining/ Secondary Intermediate Yes G area 2) Slightly Impeded 3 Hadleigh (north Principle Intermediate Yes Yes Freely Draining A area 3) 4 Sudbury Principle Intermediate Yes Yes Yes Freely Draining A (north area 5) 5 Sudbury Secondary Intermediate Yes Yes Freely Draining G (east area 6) 6 Ipswich Fringe Secondary Intermediate Yes Yes Freely Draining G (western area 8) 7 Acton Principle Slightly Impeded / Intermediate Yes Yes A Freely Draining 8 Bildeston Principle Slightly Impeded / Intermediate Yes Yes A Freely Draining 9 Boxford Secondary Slightly Impeded / Intermediate Yes Yes G Freely Draining 10 Brantham Secondary Slightly Impeded / High A Freely Draining 11 Bures St Mary Secondary Slightly Impeded / Intermediate Yes Yes G Freely Draining 12 Capel St Mary Secondary Impeded / Intermediate Yes Slightly Impeded / A Freely Draining 13 Chelmondiston Secondary Slightly Impeded / Intermediate G Freely Draining 14 East Bergholt Secondary Slightly Impeded / Intermediate G Freely Draining 15 Glemsford Slightly Impeded / Principle Intermediate Yes Yes A Freely Draining 16 Great Secondary Slightly Impeded / Intermediate Yes G Waldingfield Freely Draining 17 Holbrook Secondary Intermediate Freely Draining G 18 Lavenham Secondary Intermediate Yes Slightly Impeded G 19 Long Melford Slightly Impeded / Principle High Yes Yes A Freely Draining 20 Nayland Secondary Slightly Impeded / High Yes Yes Yes A Freely Draining 21 Shotley Secondary Intermediate Freely Draining G

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GWV* SPZ Drainage Overall Potential Zone 1 Zone 2 Site Zone 3 Development Inner Outer # Aquifer Vulnerability Total Site Protection Protection Catchment Zone Zone 22 Secondary Slightly Impeded Assington Intermediate Yes G Drainage 23 Secondary Slightly Impeded / Bentley Intermediate G Freely Draining 24 Cockfield Principle Intermediate Yes Slightly Impeded A 25 Copdock and Secondary Slightly Impeded / Intermediate Yes Yes G Washbrook Freely Draining 26 Secondary Slightly Impeded/ Elmsett Intermediate G Impeded 27 Hartest Principle Intermediate Yes Slightly Impeded A 28 Secondary Freely Draining / Hintlesham Intermediate A Impeded 29 Hitcham Secondary Intermediate Yes Slightly Impeded G 30 Secondary Slightly Impeded / Kersey Intermediate Yes Yes G Freely Draining 31 Lawshall Principle Intermediate Yes Slightly Impeded A 32 Principle Feely Draining/ Monks Eleigh Intermediate Yes A Slightly Impeded 33 Polstead Principle Intermediate Yes Freely Draining A 34 Sproughton Principle High Yes Yes Freely Draining A 35 Stoke by Principle Intermediate Yes Freely Draining A Nayland 36 Stratford St Secondary Slightly Impeded / High Yes Yes Yes A Mary Freely Draining 37 Secondary Slightly Impeded / Stutton Intermediate G Freely Draining 38 Secondary Slightly Impeded / Tattingstone Intermediate G Freely Draining EMPLOYMENT 39 Hadleigh (east: Secondary Intermediate Slightly Impeded G area 1) 40 Sudbury (east Secondary Intermediate Yes Yes Freely Draining G area 6) 41 Ipswich Fringe Secondary Intermediate Yes Yes Freely Draining G (western area 8) 42 Chilton Woods, Principle Intermediate Yes Yes Yes Freely Draining A Sudbury 43 Brantham Slightly Impeded / Secondary High A Freely Draining 44 Sproughton Principle High Yes Yes Freely Draining A 45 Lady Lane, Secondary Intermediate Yes Yes Freely Draining A Hadleigh 46 Wherstead Secondary Intermediate Yes Yes Freely Draining / A

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GWV* SPZ Drainage Overall Potential Zone 1 Zone 2 Site Zone 3 Development Inner Outer # Aquifer Vulnerability Total Site Protection Protection Catchment Zone Zone Office Park, Impeded Drainage Wherstead 47 Sprites Lane, Secondary Intermediate Yes Yes Freely Draining G Ipswich NOTES * Please note that this GWV information has recently been superseded. Developers should approach the Environment Agency for site specific information regarding groundwater vulnerability.

3.7 Summary

3.7.1 - 1 The key points raised within this section are listed within Table 3.6 below. A colour- coded constraints matrix is provided in Appendix H which summarises the current situation for each element of the water cycle for all the main development sites. Although some issues have been identified with regards to wastewater treatment, water quality, flood risk and SUDS, these are all relatively minor and, for the current situation, are not a cause for concern.

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Table 3.6 - Summary of Current Situation

Water Cycle Element Current Situation Water Resources • Currently a small surplus in AWS’ supply across the District. • Very little water available for abstraction at low flows across the District. Water Supply • No issues. Wastewater Treatment • Seven WwTWs have been identified as currently being at capacity with no available headroom: Dedham, Elmsett, Glemsford, Holbrook, Nayland, Sproughton and Sudbury. Developers and the Council should approach AWS directly for development within these catchments. • Seven WwTWs have been identified as having minimal headroom capacity, or limited capacity (by AWS): Bildeston, Boxford, Bures, Chelmondiston, Great Wenham, Hadleigh and Monks Eleigh. Wastewater Collection • No issues • Minor historical exceedence of sewer capacity in and around Sudbury, Stratford St Mary and East Bergholt due to surface water in storm events Water Quality and • Phosphorous levels are fairly high across the District, which is also classified as a Environment Nitrate Sensitive Area. As such farming practices should mitigate pollution through compliance with the Catchment Sensitive Farming and Nitrate Vulnerable Area initiatives. • Ammonia levels are very low and should be maintained. • The RBMP classifies most watercourses as having a ‘moderate’ ecological status with a target to improve to ‘good’ by 2027. • Two Environmentally Designated sites - Cattawade Marshes and Cornard Mere - have been identified as having a currently unfavourable condition due to water cycle processes (water level management, drainage and/or abstraction). Partnership working between the Council, Natural England, the Environment Agency and AWS should be undertaken to seek resolution to these issues. • To Ramsar/SPA/SSSI sites - the Stour and Orwell Estuaries - are directly downstream of multiple WwTWs, although WwTW discharge has not been identified as a cause of their current unfavourable/mixed status’. Flood Risk • Flood risk is posed mainly from fluvial and tidal sources, although some occurrences of historic surface water flooding have been recorded across the District. A substantial area of the District is located within the current surface water flood map outlines. • Fluvial and tidal flood defences protect a number of settlements and residual risk has been calculated in some areas within the SFRA. • Flood warning areas are in operation for a number of settlements. • Historic occurrence of sewer flooding in Sudbury, Stratford St Mary and East Bergholt. Demand Management • Metering, Leakage and Water Efficiency targets have been set out in AWS’ and SUDS FWRMP. Promotion of sustainable housing by the Council will assist AWS in meeting these targets. • Some restriction to infiltration SUDS techniques have been identified due to location of GWV, SPZ and permeability. Alternative measures, such as rainwater harvesting, are available and should be progressed alongside retrofitting of existing developments and investigations into strategic SUDS where possible. See Section 7 for further details regarding SUDS.

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4 OPTIONS FOR GROWTH

4.1 Introduction

4.1.1 - 1 To enable cross comparison between the various increased growth options considered within this WCS, they have been analysed in parallel within this section. Table 4.1 below summarises Growth Options 2, 3 and 4:

Table 4.1 - Summary of Growth Options

Growth Option Residential (Dwellings) Employment (ha) B1 B2 B8 Growth Option 2 (Former RSS) 5,9781 5.7 8.7 18.3 Growth Option 3 (Draft RSS Review) 7,1351 5.7 8.7 18.3 Growth Option 4 a 250 (Brantham) 2 0.3 1.7 1.8 b 700 (Brantham) 2 0.3 1.7 1.8 c 500 (Sudbury Area 6) 2 0.5 1.5 1.0 d 350 (Sudbury Area 5) 2 1.3 2.5 4.5 e 950 (Ipswich Area 8) 2 2.3 2.0 9.2 NOTES 1 Includes windfalls, trajectories and holiday population 2 Tested alongside relevant Growth Option 2 and Growth Option 3 values for neighbouring settlements

4.2 Water Resources and Supply

4.2.1 Water Resources

4.2.1 - 1 AWS’ FWRMP has been based upon the former RSS targets, accounting for a population increase over their supply area of 20% between 2010 and 2035. The proposed Growth Option 2 and Growth Option 3 trajectories of 5,978 dwellings and 7,135 dwellings, respectively, between 2009 and 2031 fall within AWS’ predicted increase. On a District-wide scale there is little variance between the ‘worst case’ alternative development trajectories presented in Growth Option 4 for the specified sites and those considered in Growth Options 3 (a decrease of just 68 dwellings - the decrease in dwellings in the Sudbury area offsets the increases in Ipswich and Brantham). As such, Growth Option 4 also falls within AWS’ predicted population increases for the area.

4.2.1 - 2 Overall AWS are confident that sufficient water resources are available to supply the Growth Options listed above. However, both WRZs are predicted to experience a deficit within the planning period covered by the FWRMP. Although both WRZs currently have a small surplus of water, the Cambridgeshire and West Suffolk WRZ (WRZ09) is forecast to have a deficit in the last five years of the planning period (2030-2035) and the East Suffolk and Essex WRZ (WRZ10) is forecast to have a deficit by the end of AMP5 (2015). Within each WRZ only the PZs shown in Table 4.2 are forecast to have a negative supply-demand balance.

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Table 4.2 - Planning Zone Water Supply Deficits

Planning Zone WRZ Affected Potential Growth Locations Forecast Deficit in 2036/7 Residential Employment Average (Ml/d) Peak (Ml/d) Glemsford Lavenham PZ48 - Bury St 9 Cockfield -3.64 -3.47 Edmunds Hartest Lawshall Boxford Hadleigh Brantham Ipswich Fringe Capel St Mary Brantham Chelmondiston Sproughton East Bergholt Wherstead Holbrook Nayland Shotley Ipswich PZ60 - Ipswich 10 Hadleigh -20.18 -3.69 Bentley Copdock and Washbrook Polstead Sproughton Stoke by Nayland Stratford St Mary Stutton Tattingstone

4.2.1 - 3 To overcome these deficits a number of mitigation measures are planned by AWS across the planning period, listed in Table 4.3 below. Without the installation of these measures, the PZs, and therefore the settlements identified above, may experience a shortage of water resources. In addition to these measures, AWS have factored general improved demand management across their supply area into their FWRMP, including increased installation of water meters, promotion of water efficiency and stability of leakage volumes at the current level. These activities will be required in all new development and have been included in Table 4.3 covering the planning period for all planning zones, unless otherwise stated in the FWRMP.

4.2.1 - 4 Mitigation measures will therefore be required within all new development and larger scale infrastructure mitigation will be required within Planning Zones 48 and 60, as shown in Table 4.3 below. Additional mitigation may be required for large scale commercial or industrial use (not identified at present) and alterative water sources or storage capabilities may be required to supply agricultural practices.

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Table 4.3 - Planned Mitigation Measures

WRZ Planning Affected Potential Growth Mitigation Planned Zone Locations* Measure Installation Dates Residential Employment AMP Dates Period Active Leakage 2010 - AMP5-7 Control 2025 Water 2010 - Efficiency AMP5 2015 Measures PZ48 - Bury Glemsford Enhanced 2010 - St Edmunds Lavenham AMP5 Metering 2015 Barnham Cross 2010 - AMP5 9 - Cambridgeshire Transfer1 2015 and West Suffolk 2025 - GOGS South2 AMP8 2030

Sudbury Enhanced 2010 - AMP5-8 Great Cornard Metering 2030 PZ62 - Acton Water 2010 - Sudbury AMP5-8 Sudbury Bures St Mary Efficiency 2030 Gt Waldingfield Active Leakage 2010 - AMP5-8 Long Melford Control 2030 Active Leakage 2010 - AMP5 Control 2015 Ipswich Fringe Water 2010 - Hadleigh Efficiency AMP5-8 2030 Boxford Measures Hadleigh Brantham Enhanced 2010 - Ipswich Fringe AMP5-8 PZ60 - Chapel St Mary Metering 2030 Brantham Ipswich Chelmondiston Pressure 2010 - Sproughton AMP5 East Bergholt Reduction 2015 Wherstead 10 - East Suffolk Holbrook Bucklesham 2010 - AMP5 and Essex Nayland ASR Scheme3 2015 Shotley Ipswich 2015 - Discharge Re- AMP6 2020 Use4 Enhanced 2010 - AMP5-8 Metering 2030 Bildeston Water 2010 - PZ61 - Semer Elmsett AMP5-8 Efficiency 2030

Active Leakage 2010 - AMP5-8 Control 2030 Notes * Towns/Urban Areas and Key Service Centres only 1 Barnham Cross is a new sourceworks that will create a surplus in the Thetford PZ 2 Great Ouse Groundwater South involves the reallocations of licences within the Environment Agency, following a review of consents.

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3 Bucklesham Aquifer Storage Recovery scheme uses a current licence to abstract water from the Mill River to the east of Ipswich. The Mill River used to supply Ipswich before the development of Alton Reservoir. The surface water would be treated for direct supply. Surplus water will be stored in the underlying Chalk aquifer for abstraction in times of low river flow. 4 The Ipswich Discharges Re-Use returns current discharges to the River Orwell to the River Gipping after additional treatment. This enables more water to be abstracted and therefore enable filling of the Alton Water reservoir.

4.2.1 - 5 The FWRMP states the growth scenarios used for the WRZs as a whole. As they cover an area much larger than Babergh District the figures stated are not directly applicable to the study area. However, for both WRZs, commercial demand is predicted by AWS to ‘remain steady’. No allowance has therefore been made within the FWRMP and water supply scenarios to account for any commercial development within the District. Discussion with AWS has identified that small scale mixed use office and retail based development is not considered to be a problem for water resource planning. However, if an opportunity does arise for an industrial or larger commercial development, discussion should be held with AWS as early in the planning process as possible.

4.2.1 - 6 The CAMS Resource Assessments imply that over the planning period very little additional water will be available for abstraction from the current ground or surface water sources. Therefore, for almost all waterbodies no new consumptive licences are likely to be granted and little or no water is available for abstraction from groundwater. Only the Belstead Brook catchment has some resource potentially available for abstraction at present. As agricultural practices have a high demand for water supply, they can have a major impact on water resources, mainly to fulfil irrigation requirements, but also due to the potential impacts from the use of fertilisers and general land management. Due to the increased licence restrictions within the Study Area and increasing pressures on water resources due to climate change, intensification or expansion of agriculture industry within Babergh District may not be viable.

4.2.1 - 7 Overall, AWS are confident that water is available to supply the residential and commercial development within Growth Options 2, 3 and 4, although mitigation measures will be required within all new development and larger scale infrastructure mitigation for particular planning zones. Additional mitigation may be required for large scale commercial or industrial use and alterative water sources or storage capabilities may be required to supply agricultural practices.

4.2.2 Water Supply

4.2.2 - 8 AWS have reviewed the water supply network for the former RSS targets and draft RSS review to 2031 as part of their response to the Council’s Core Strategy consultations. No issues have been identified for the network for any of the potential growth areas. This will therefore also cover the locations specified in Growth Option 4. The only identified requirement is for the connection of on site water supply connection. Additional correspondence will be required with AWS by either the Council or developers once specific site locations are identified.

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4.3 Wastewater Treatment and Collection

4.3.1 Wastewater Treatment

4.3.1 - 1 Only the WwTWs which serve the potential development locations (Towns and Urban, Key Service Centres and Other Villages) have been assessed. Each growth area has been routed to one WwTW to avoid ‘double counting’ in the figures. As residential development forms the most significant element of proposed growth it has been tested separately and in combination with the employment growth. Table 4.4 below summarises the settlements located within each WwTW catchment.

4.3.1 - 2 Tables 4.5 and 4.6 illustrate the predicted capacity of the WwTWs for Growth Options 2 and 3, accounting for residential development only. Tables 4.7 and Table 4.8 illustrate the predicted capacity of the WwTWs for Growth Options 2 and 3, accounting for both residential and employment development (please note only the WwTWs affected by the employment development are listed within these tables. Tables 4.9 and 4.10 illustrate the predicted capacity of the affected WwTWs for Growth Option 4 (residential only and residential combined with employment respectively). As the results for Growth Option 4 combined with Growth Options 2 and 3 for neighbouring settlements did not show noticeable differences they have not been shown separately. The capacity of each WwTW has been calculated, assuming that the maximum potential development occurs in each catchment (the full trajectories used in these calculations are included in Appendix C). The full list of resulting DWF flows is included in Appendix F.

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Table 4.4 - Summary of Settlements within each WwTW catchment

WwTW WwTW Name Settlement Residential Employment Code Development Development BENTST Bentley Bentley  BILDST Bildeston Bildeston; Hitcham; Commitments and Windfalls  BOXFST Boxford Boxford; Commitments and Windfalls  BRANST Brantham Brantham ; Stutton; Tattingstone; Commitments   and Windfalls BUREST Bures Bures; Commitments and Windfalls  CHANST Chantry Copdock and Washbrook; Commitments   CHEMST Chelmondiston Chelmondiston; Commitments and Windfalls  COCGST Cockfield Cockfield  DEDHST Dedham Stratford St Mary  EBERST East Bergholt East Bergholt; Windfalls  ELMSST Elmsett Elmsett  GLEMST Glemsford Glemsford; Hartest; Commitments and Windfalls  GCORST Great Cornard Sudbury Area 6; Commitments and Windfalls   GWLDST Great Great Waldingfield; Commitments and Windfalls  Waldingfield GWENST Great Wenham Capel St Mary; Commitments and Windfalls  HADLST Hadleigh Hadleigh All; Commitments and Windfalls   HINTST Hintlesham Hintlesham  HOLKST Holbrook Holbrook; Windfalls  KERSST Kersey Kersey  LAVHST Lavenham Lavenham; Commitments and Windfalls  LMELST Long Melford Sudbury Area 5; Acton; Long Melford;   Commitments and Windfalls MONEST Monks Eleigh Monks Eleigh  NAYLST Nayland Nayland; Polstead; Stoke by Nayland; Windfalls  NEDGST Nedging-Tye Commitments  SHIMST Shimpley Lawshall  SHOTST Shotley Shotley and Shotley Gate; Commitments and  Windfalls SPRCST Sproughton Ipswich Area 8; Sproughton; Commitments and   Windfalls SUDBST Sudbury Commitments 

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Table 4.5 - Growth Option 2, Residential Development WwTW Capacity (inc. commitments & windfalls)

1Should these works be allocated growth, consideration should be given to the permitting implications. A significant growth estimate of 10% of the current (2010) Total PE has been provided as a guide. AWS will require consultation in all cases, but, as a guide, growth above these values is unlikely to be accommodated under the current processing system.

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Table 4.6 - Growth Option 3, Residential Development WwTW Capacity (including commitments & windfalls)

1Should these works be allocated growth, consideration should be given to the permitting implications. A significant growth estimate of 10% of the current (2010) Total PE has been provided as a guide. AWS will require consultation in all cases, but, as a guide, growth above these values is unlikely to be accommodated under the current processing system.

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Table 4.7 - Growth Option 2, Residential and Employment Development WwTW Capacity (inc. commitments & windfalls)

Table 4.8 - Growth Option 3, Residential and Employment Development WwTW Capacity (including commitments & windfalls)

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Table 4.9 - Growth Option 4, Residential Development WwTW Capacity (inc. commitments & windfalls)

NOTES: 1250 dwellings in Brantham 2700 dwellings in Brantham 3 500 dwellings in Sudbury Area 6 4 350 dwellings in Sudbury Area 5 5 950 dwellings in Ipswich Area 8

Table 4.10 - Growth Option 4, Residential and Employment Development WwTW Capacity (inc. commitments & windfalls

NOTES: 1250 dwellings in Brantham 2700 dwellings in Brantham 3 500 dwellings in Sudbury Area 6 4 350 dwellings in Sudbury Area 5 5 950 dwellings in Ipswich Area 8

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4.3.1 - 3 A number of WwTW capacity restrictions have been identified with regards to the accommodation of all three Growth Options. In addition to the seven WwTWs already identified within Growth Option 1 as being currently at capacity (Dedham, Elmsett, Glemsford, Holbrook, Nayland, Sproughton and Sudbury) and the four identified as limited capacity (Bildeston, Chelmondiston, Great Wenham and Hadleigh), Hadleigh and Brantham are also identified as requiring an increased CDWF within the planning period. Hadleigh is identified as requiring an increased consent by 2018 for Growth Option 2 and 2016 for Growth Option 3 (considering employment plus residential growth). Brantham requires an increased CDWF in 2022 if the higher development scenario in Growth Option 4 is progressed. AWS request that developers and the Council approach them directly for development within these catchments, which should also be discussed with the Environment Agency. An additional eight WwTWs have been identified as being at risk of falling within 20% of their CDWF at some point within the planning period for Growth Options 2 and 3 and three WwTWs within Growth Option 4. A significant limit for growth has been provided for the small package plants affected by the proposed development. The only one of concern is Nedging as the limit (20% of the current PE) is predicted to be 4 dwellings, whereas the trajectories provided by the Council indicate a 12 dwelling commitment within that catchment. It is assumed this issue has already been discussed with AWS, but urge the Council to notify AWS of the current situation with regards to these additional dwellings as soon as possible.

4.3.1 - 4 The WwTWs that may pose a constraint to the proposed development for each Growth Option are summarised below. As the 10% margin is deemed sensible as a ‘safety factor’ to highlight a risk of breach all the WwTWs identified as falling within 10% of their CDWF or as having limited or no capacity will require review by AWS and possibly have their consents reviewed and tighter water quality discharge limits applied before the proposed development can take place. The WwTWs identified as being at requiring an increased CDWF within the planning period have been highlighted in bold in Table 4.11.

4.3.1 - 5 Certain areas around the Ipswich Fringe and Sudbury (affecting parts of growth location areas 5 and 6) and the village of Assington are currently not located within any WwTW catchments. It is assumed that the non serviced areas surrounding Sudbury and the Ipswich Fringe will be connected to the neighbouring networks and this assumption has been incorporated into the assessment of WwTW flows above. Assington has been identified for infill development, which will require the use of septic tanks. The suitability of these has not been assessed as part of this WCS, but should be considered on a site by site basis and planning applications are received.

4.3.1 - 6 Table 4.11 below summarises the year in which each WwTW becomes limited in its capacity or by which it requires an increase in its CDWF as a result of the proposed development for each growth option. The maximum CDWF required for each of these works to accommodate the full growth quota (2010 - 2031) is listed in the final column of the table.

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Table 4.11 - WwTWs Requiring an Increased CDWF or Experiencing Limited Headroom Within the Planning Period

GROWTH OPTION 2 WwTWs with Capacity Affected Potential Growth Issue Year Max Constraints in Planning Locations CDWF Period Required (m³/day) Residential Only Bildeston (BILDST) Bildeston; Hitcham; Limited Capacity stated by AWS 2010 266.8 Commitments and Windfalls Boxford (BOXST) Boxford; Commitments and <20% Flow Consent Headroom 2010 365.3 Windfalls Bures (BUREST) Bures; Commitments and <20% Flow Consent Headroom 2010 233.3 Windfalls <10% Flow Consent Headroom 2018 Chelmondiston (CHEMST) Chelmondiston; Commitments Limited Capacity stated by AWS 2010 148.2 and Windfalls Dedham (DEDHST) Stratford St Mary No Headroom 2010 757 Elmsett (ELMSST) Elmsett No Headroom 2010 334 Glemsford (GLEMST) Glemsford; Hartest; No Headroom 2010 1468.3 Commitments and Windfalls Great Cornard (GCORST) Sudbury Area 6; Commitments <20% Flow Consent Headroom 2023 2167.9 and Windfalls Great Wenham (GWENST) Capel St Mary; Commitments Limited Capacity stated by AWS 2010 372.1 and Windfalls Hadleigh (HADLST) Hadleigh All; Commitments Limited Capacity stated by AWS 2010 1737.4 and Windfalls <10% Flow Consent Headroom 2012 No Headroom 2026 Holbrook (HOLST) Holbrook; Windfalls No Headroom 2010 514 Monks Eleigh (MONEST) Monks Eleigh <10% Flow Consent Headroom 2010 100 Nayland (NAYLST) Nayland; Polstead; Stoke by No Headroom 2010 1052 Nayland; Windfalls Nedging (NEDGST) Commitments Development > 20% Total PE 2011 Unknown Shotley (SHOTST) Shotley and Shotley Gate; <20% Flow Consent Headroom 2016 553.3 Commitments and Windfalls Sproughton (SPRCST) Ipswich Area 8; Sproughton; No Headroom 2010 601.5 Commitments and Windfalls Sudbury (SUDBST) Commitments No Headroom 2010 5274.3 WwTWs Affected by Residential and Employment Great Cornard (GCORST) Sudbury Area 6; Commitments <20% Flow Consent Headroom 2023 2297.6 and Windfalls <10% Flow Consent Headroom 2027 Hadleigh (HADLST) Hadleigh All; Commitments Limited Capacity stated by AWS 2010 1906.4 and Windfalls <10% Flow Consent Headroom 2012 No Headroom 2018 Long Melford (LMELST) Sudbury Area 5; Acton; Long <20% Flow Consent Headroom 2020 1557.3 Melford; Commitments and <10% Flow Consent Headroom 2025 Windfalls Sproughton (SPRCST) Ipswich Area 8; Sproughton; No Headroom 2010 1019.7 Commitments and Windfalls

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GROWTH OPTION 3 WwTWs with Capacity Affected Potential Growth Issue Year Max CDWF Constraints in Planning Locations Required Period (m³ and day) Residential Only Bildeston (BILDST) Bildeston; Hitcham; Limited Capacity stated by AWS 2010 273.1 Commitments and Windfalls Boxford (BOXST) Boxford; Commitments and <20% Flow Consent Headroom 2010 371.7 Windfalls Bures (BUREST) Bures; Commitments and <20% Flow Consent Headroom 2010 239.7 Windfalls <10% Flow Consent Headroom 2018 Chelmondiston (CHEMST) Chelmondiston; Commitments Limited Capacity stated by AWS 2010 154.5 and Windfalls Dedham (DEDHST) Stratford St Mary No Headroom 2010 757 Elmsett (ELMSST) Elmsett No Headroom 2010 334 Glemsford (GLEMST) Glemsford; Hartest; No Headroom 2010 1474.7 Commitments and Windfalls Great Cornard (GCORST) Sudbury Area 6; Commitments <20% Flow Consent Headroom 2020 2306.4 and Windfalls <10% Flow Consent Headroom 2028 Great Wenham (GWENST) Capel St Mary; Commitments Limited Capacity stated by AWS 2010 378.5 and Windfalls Hadleigh (HADLST) Hadleigh All; Commitments and Limited Capacity stated by AWS 2010 1792.8 Windfalls <10% Flow Consent Headroom 2012 No Capacity 2023 Holbrook (HOLST) Holbrook; Windfalls No Headroom 2010 520.3 Long Melford (LMELST) Sudbury Area 5; Acton; Long <20% Flow Consent Headroom 2026 1400.5 Melford; Commitments and Windfalls Monks Eleigh (MONEST) Monks Eleigh <10% Flow Consent Headroom 2010 100 Nayland (NAYLST) Nayland; Polstead; Stoke by No Headroom 2010 1058.3 Nayland; Windfalls Nedging (NEDGST) Commitments Development > 20% Total PE 2011 Unknown Shotley (SHOTST) Shotley and Shotley Gate; <20% Flow Consent Headroom 2016 559.6 Commitments and Windfalls Sproughton (SPRCST) Ipswich Area 8; Sproughton; No Headroom 2010 657.8 Commitments and Windfalls Sudbury (SUDBST) Commitments No Headroom 2010 5274.3 WwTWs Affected by Residential and Employment Great Cornard (GCORST) Sudbury Area 6; Commitments <20% Flow Consent Headroom 2020 2436.4 and Windfalls <10% Flow Consent Headroom 2025 Hadleigh (HADLST) Hadleigh All; Commitments Limited Capacity stated by AWS 2010 1961.8 and Windfalls <10% Flow Consent Headroom 2011 No Headroom 2016 Long Melford (LMELST) Sudbury Area 5; Acton; Long <20% Flow Consent Headroom 2028 1704.5 Melford; Commitments and <10% Flow Consent Headroom 2022 Windfalls No Headroom 2027 Sproughton (SPRCST) Ipswich Area 8; Sproughton; No Headroom 2010 1075.4 Commitments and Windfalls

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GROWTH OPTION 4 WwTWs with Capacity Affected Potential Growth Issue Year Max Constraints in Planning Locations CDWF Period Required (m³ and day) Residential Only Brantham (BRANST) Brantham ; Stutton; <20% Flow Consent Headroom 2025 844.5 (700 dwellings) Tattingstone; Commitments and <10% Flow Consent Headroom 2029 Windfalls Great Cornard (GCORST) Sudbury Area 6; Commitments <20% Flow Consent Headroom 2026 2073 and Windfalls Sproughton (SPRCST) Ipswich Area 8; Sproughton; No Headroom 2010 914.4 Commitments and Windfalls WwTWs Affected by Residential and Employment Brantham (BRANST) Brantham ; Stutton; <20% Flow Consent Headroom 2018 890.9 (250 dwellings) Tattingstone; Commitments and <10% Flow Consent Headroom 2021 Windfalls Brantham (BRANST) Brantham ; Stutton; <20% Flow Consent Headroom 2018 1076 (700 dwellings) Tattingstone; Commitments <10% Flow Consent Headroom 2019 and Windfalls No Headroom 2022 Great Cornard (GCORST) Sudbury Area 6; Commitments <20% Flow Consent Headroom 2024 2251.3 and Windfalls <10% Flow Consent Headroom 2029 Long Melford (LMELST) Sudbury Area 5; Acton; Long <20% Flow Consent Headroom 2018 1542.6 Melford; Commitments and <10% Flow Consent Headroom 2025 Windfalls Sproughton (SPRCST) Ipswich Area 8; Sproughton; No Headroom 2010 1588.9 Commitments and Windfalls

4.3.2 Wastewater Collection

4.3.2 - 7 AWS have reviewed the wastewater collection network for the Growth Options 2 and 3 as part of their response to the Council’s Core Strategy consultations. Limited capacity has been identified in both the foul and surface water network and significant upgrades will be required to accommodate the full potential growth targets. In particular the towns of Great Cornard and Sudbury have been identified as having severe network capacity restrictions. Combined with the potential growth targets for the area identified in the Growth Options, infrastructure upgrades will be required for those growth locations. It is recommended that additional correspondence is undertaken with AWS by either the Council or developers once specific site locations and capacities are identified.

4.3.2 - 8 An assessment of the impact of the proposed development upon Combined Sewer Overflow (CSO) discharge has not been possible within this assessment due to the required information not being available from AWS’ current models. Without detailed information regarding specific development sites there is no benefit to undertaking an assessment on the impact of a catchment upstream of a CSO. However, once exact site specific allocation numbers and locations are identified, this assessment should be undertaken to ensure development does not result in an increase in frequency of CSO spills.

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4.4 Water Quality and the Environment

4.4.1 Impact of WwTW Discharge on Water Quality

4.4.1 - 1 Discharge consent limits are placed on WwTWs to ensure that their discharge is within appropriate biological and chemical limits. Where a volumetric permit is to be increased to accommodate growth, the quality permit limits would be accordingly tightened to ensure ‘no deterioration’ in the current (2009) WFD class. To provide an assessment of the feasibility of accommodating the proposed growth within the WFD limits, the Environment Agency have provided the Indicative Consent Limits required to meet the WFD objectives for the WwTWs identified as requiring an increase to their CDWF within the planning period. These limits have been derived using the Environment Agency River Quality Planning tool (a simple water quality consent modelling tool), or using simple mass balance calculations to determine load constant values. Please note the permit limits calculated for the existing volumetric permit (2010) may be different to existing permit limits as they reflect the newly introduced WFD targets. The results of this modelling are summarised for the key WFD parameters (Ammonia, BOD and phosphorous) in Appendix G, which compares the current permit limits with the future limits required by the end of the planning scenario for the ‘worst case’ growth option.

4.4.1 - 2 As a tightening of the quality permit limits will be required to meet the ‘no deterioration’ and ‘good status’ objectives of the WFD regardless of whether growth takes place in the catchment, a comparison is made between the consent limits required to meet these objectives if no additional growth takes place in the catchment (top line for each WwTW in Appendix G) and the consent limits required if the maximum potential level of growth takes place (bottom line).

4.4.1 - 3 The indicative consent limits for the three key WFD parameters to ensure ‘no deterioration’ in the current WFD status are shaded blue in Appendix G. As all of these indicative consent limits are within the current economic limit of conventional treatment, the proposed growth in the catchment of these works is therefore not currently constrained by the WFD ‘no deterioration’ objective. Please note, however, that the phosphate limits for the Nayland WwTW and the ammonia limit for the Dedham WwTW are very close to the limit of economic treatment (the ‘marginal’ values are marked in amber within Appendix G) and it is unlikely these WwTWs will be able to accommodate any additional development above the modelled ‘worst case’ growth scenario (40 new dwellings, plus 11 windfalls within the Nayland WwTW catchment and infill development within the Dedham catchment). In addition, as extra treatment processes will be required at these sites to meet the tighter quality limits, AWS will have to review the deliverability of such processes on a site by site basis as some of the tighter limits may not be deliverable at some of the works. As part of this WCS a review has been made as to the availability of additional physical space around the WwTWs. In all cases the WwTWs are not constrained by neighbouring buildings or infrastructure, although the availability of the surrounding land for purchase by AWS may be a limiting factor.

4.4.1 - 4 An assessment of whether the proposed growth would make meeting the ‘Good Status’ objective of the WFD more difficult to achieve has also been undertaken through comparison of the ‘current’ and ‘predicted’ values shown in the three columns on the far right of the table in Appendix G (again, a comparison can be made between the discharge requirements if no growth took place in the catchment, top line, and if the

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maximum proposed growth took place, bottom line). In all cases, the upstream water quality is assumed to already be at ‘good status’, to represent a situation where all upstream sources of pollution have been addressed. This is to ensure the onus of delivering the good status objective is not placed on any particular discharge or operator. The midpoint of the good status class is used and for phosphorous this is 0.086mg/l. However, even with this assumption of good upstream phosphorous water quality, almost all the WwTWs assessed have been assigned an indicative permit limit required to meet the WFD ‘Good Status’ for phosphorous which is beyond the current economic limit of conventional treatment, without any additional growth (the values beyond the economic limit for conventional treatment are marked in red and those considered ‘marginal’ marked in amber). The discharge points can be viewed on Figures 5a and 5b. It is therefore important that policies within the Core Strategy and accompanying documents are suitably flexible to deal with this issue (for example the proposed growth may require redistribution between the WwTW catchments if the required phosphorous limits are deemed unattainable).

4.4.1 - 5 Despite this, it is important to note that, with the exception of Sproughton WwTW, the 2030/31 permit limits required to accommodate the proposed growth are no more onerous to achieve than those required for the existing 2010 permit, with no additional growth. As such the proposed growth in the catchments of the assessed WwTWs, with the exception of Sproughton, are not currently constrained by the WFD ‘Good Status’ objective. However, the requirement for the WwTWs, regardless of the growth proposals, to achieve the required phosphorus limits may pose future deliverability issues as the extra costs associated with the treatment beyond the current economic limit may impact the sustainability and thus deliverability of the proposed growth in the future. Actions required to achieve the ‘Good Status’ objectives of the WFD will be considered as part of the next review of water company prices (Periodic Review 2014). It is recommended that the required growth figures remaining for the District are reassessed following that review.

4.4.1 - 6 The indicative consent limits for Sproughton, without any growth, are within the current economic limit of conventional treatment, whereas they fall beyond the economic limit of treatment for phosphorous when the full quota for growth is considered. As such, it is recommended that the full quota for growth within that catchment should not be pursued. The maximum quota for growth which can be accommodated at this WwTW within the current economic limit of treatment is discussed in Section 5 of this WCS. It is greater than the maximum discharge predicted for Growth Options 2 and 3.

4.4.1 - 7 Please note that there are some limitations in the methodology used to calculate the indicative consent limits identified above and in Appendix G and work is currently ongoing to develop a more sophisticated water quality model of the Stour catchment. Once developed, the model will enable review of the indicative permit limits presented above and will enable a catchment approach to permitting to be considered. This model will be available by December 2012.

4.4.1 - 8 For the WwTW where sufficient volumetric headroom is available within the current discharge permits, there has not been a need to calculate indicative consent limits. However, the current permits may be reviewed under the Periodic Review 2014 and, if necessary, the quality permit limits may be tightened. This review and any permit

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changes will be driven by the requirement to meet the ‘no deterioration’ of ‘Good status’ objectives of the WFD. Any permit modifications could be made as early as 2015 and, due to the potentially large costs involved, could have implications for the long term sustainability and deliverability of the proposed growth. As a result, policies in the Core Strategy and accompanying documents need to be flexible enough to deal with this potential deliverability issue (e.g. the redistribution of the required growth between the WwTW catchments).

4.4.2 Impact of Development on Environmentally Designated Sites

4.4.2 - 9 As stated in Table 3.3, the only environmentally designated sites which may be affected by the impacts of proposed development on the water cycle are the Cattawade Marshes, Cornard Mere, and the Stour and Orwell Estuaries. Inappropriate water levels and water level management are the key reasons for the unfavourable status of the Cattawade Marshes and Cornard Mere, whereas the main factors impacting the Stour and Orwell Estuaries are coastal squeeze, port development, maintenance dredging and sea level rise. For the latter there is therefore an indication that coastal processes dominate the site, although upstream sections will be more influenced by tidal processes and impacts upon the riverine environment. 4.4.2 - 10 As illustrated in Appendix G and discussed in Section 4.4 above, the only WwTW for which the impact of the proposed development results in the indicative consent limits crossing the threshold of the current economic limit of treatment, and therefore potentially having a negative impact on water quality, is Sproughton. The only designated site (from the four listed above) that is located downstream of Sproughton is the Orwell Estuary, however, due to its distance upstream, it is not anticipated that this WwTW will have a significant impact on the site.

4.4.2 - 11 The Cattawade Marshes and the Stour Estuary are located at the downstream extent of the River Stour. As a result most of the WwTWs and development sites are located upstream. Due to their distance upstream of the sites and, as the indicative consent limits for all these WwTWs are not significantly affected by the proposed growth, it is not anticipated that the proposed development will have a negative impact on water quality at the site. However, as mentioned above, the phosphorous discharge required to achieve ‘Good Status’ under the WFD, regardless of the proposed development, is, for many of the WwTWs, beyond the current economic limit of treatment. As the actions required to achieve ‘Good Status’ will be considered in the next water company Periodic Review in 2014, it is recommended that the policies in the Core Strategy remain suitably flexible to accommodate any potential issues arising from this.

4.4.2 - 12 As discussed in Section 4.5 below, the impact of the proposed development on water levels within Babergh should be minimal All surface water runoff should be attenuated on site and the impact of increased WwTW flows is marginal in all cases. As such, it is not anticipated that the proposed development will impact upon water level management at the designated sites. Potential issues surrounding abstraction and water availability in the District have been discussed above and the Council should seek to maximise water efficiency within all new development and promote the Environment Agency’s abstraction consenting policy throughout the District.

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4.4.2 - 13 Cornard Mere is located on a tributary of the River Stour. It is not located downstream of any development sites or WwTWs and, as such, the proposed development will not have a direct impact on the recovery of the site.

4.4.2 - 14 Overall, therefore, it is not anticipated that the proposed development will have a significant effect on internationally designated sites, but, depending on the recommendations in this study and their adoption into the Core Strategy, this should be confirmed through consultation with Natural England as part of the Habitats Regulations assessment of the Core Strategy.

4.5 Flood Risk

4.5.1 - 1 As individual development sites have not been identified at this stage, it is difficult to make a quantitative assessment of the capacity of the water cycle for each development area in terms of flood risk. However, it is important to consider any potential changes to the risk posed by flood risk to the development areas. The key drivers for change are:

• Climate change, predicted to increase the risk of fluvial, tidal and surface water flooding due to sea level rise and increased intensity and duration of rainfall; • Improved levels of flood defence; • Implementation of flood policies and mitigation measures for all forms of flooding; and • Impact of new development increasing flood risk downstream.

4.5.2 Climate Change

4.5.2 - 2 PPS25 provides current guidance regarding contingency allowances for the impacts of climate change on both fluvial and tidal flooding. The allowances for sea level, rainfall intensity and peak river flow, as presented in PPS25 are shown below, with the time scale relevant to the planning period in this study highlighted in blue:

Table 4.12 - PPS25 Climate Change Allowances27

1990 - 2025 2025 - 2055 2055 - 2085 2085 - 2115 Net Sea Level Rise relative to 1990 4.0 mm/yr 8.5 mm/yr 12.0 mm/yr 15.0 mm/yr (East of England) Peak Rainfall +5% +10% +20% +30% Intensity Peak River Flow +10% +20% +20% Offshore Wind +5% +10% Speed Extreme Wave +5% +10% Height

27 PPS25: Development and Flood Risk, 2010: pp16

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4.5.2 - 3 Climate change has been considered in the SFRA and an outline for Flood Zone 3b with climate change has been provided. The SFRA concluded that the impact of climate change on the fluvial flood zone extent in Babergh District was minimal. As such, it recommends that Flood Zone 2 is used as a conservative estimate of the impacts of climate change on Flood Zone 3 for planning purposes. With regards to tidal flood risk, the SFRA concluded that the increase in sea level will not adversely impact the current tidal barriers. However, climate change will increase the frequency with which the current tidal defences will be overtopped if they are not raised.

4.5.2 - 4 The impact of sea level rise on sewer outfalls should be investigated as part of a further modelling study, such as an updated SFRA or within AWS sewer modelling scenarios.

4.5.3 Flood Defences

4.5.3 - 5 The Environment Agency are promoting a project to construct a new tidal barrier on the Orwell estuary. This will be located at New Cut (in the administrative area of Ipswich Borough Council). This will provide protection up to a 0.33% annual probability event taking into account the effect of climate change and will restrict the tidal flows along the lower River Gipping during extreme floods. The only part of Babergh district which this will impact is the Sproughton area which is shown by the Flood Zone maps as being at flood risk. It would be anticipated that the installation of the new barrier would reduce the fluvial and tidal flood risk in this location particularly in the future climate allowing for climate change.

4.5.4 Policies

SMP

4.5.4 - 6 The coastline of the Babergh District is covered by the Stour and Orwell Policy Unit in the draft Essex and South Suffolk SMP2. The overall intent of management for the Stour and Orwell is to support and enhance the natural evolution of the estuaries, while continuing to defend all existing dwellings and infrastructure, and facilitating adaptation or limited local intervention where needed. For most of the shoreline, the current management approach will be continued: holding the current alignment where there are defences, and continuing a No Active Intervention approach for high ground frontages.

4.5.4 - 7 However, at Shotley Marshes the flood defences are under pressure from erosion and tidal wave action. A landward realignment at some point within the timescale of the SMP will create a more sustainable situation by reducing the pressure on the flood defences and will support the estuary to move towards a more natural system.

CFMP

4.5.4 - 8 The following adopted policies will affect flood risk across Babergh, and should be considered for future developments:

4.5.4 - 9 Policy 2 - To reduce existing flood risk management actions, accepting that flood risk will increase with time. Policy 2 has been adopted for the Upper Reaches and Coastal Streams policy units, in the North Essex CFMP, as well as for the Suffolk Coast and Heaths, and the East Anglian Plain policy units in the East Suffolk CFMP. This covers

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the southeastern area of Babergh District, located within the catchment of the River Stour. Adopting this policy means that the Environment Agency accepts that flood risk will increase with time in these areas.

4.5.4 - 10 Policy 3 - To continue with existing or alternative actions to manage flood risk at the current level (accepting that flood risk will increase in time from this baseline). Policy 3 has been adopted for the Upper and mid Tributaries, and the Mid Colne and Stour policy units in the North Essex CFMP. It covers the major fluvial catchments in the western area of Babergh district, including the Rivers Stour, Box and Brett. The area over which Policy 3 is to be adopted covers the areas of Hadleigh and Sudbury and this would include some of the broad locations for future development that are being considered.

4.5.4 - 11 Policy 5 - To take further action to reduce flood risk (now and/or in the future). This has been applied to the Ipswich policy unit of the East Suffolk CFMP, and covers the northeastern area of Babergh district. The watercourses covered by Policy 5 are the River Gipping (between Sproughton and the downstream end of the Chantry Washland) and the downstream end of the Belstead Brook (from the A14).

4.5.5 Impact of new development

4.5.5 - 12 All new development should follow the guidance provided in PPS25, including the Sequential and Exception tests, where relevant (see Section 7). Where a site is located within Flood Zones 2 or 3, or is located in Flood Zone 1 and greater than 1ha, a site specific Flood Risk Assessment (FRA) will be required to determine the flood risk to the development site and the impact of the development site on flood risk downstream. Although policy states that where possible all development should be located outside of Flood Zones 2 and 3, it is occasionally acceptable for certain types of development to go ahead, providing the flood risk is mitigated, including the potential downstream impact. An FRA should also assess the potential runoff from individual sites and suggest suitable mitigation measures to accommodate such runoff. Inline with the emerging Floods and Water Management Act, all new developments should seek to attenuate all surface runoff on site through the use of SUDS.

4.5.5 - 13 With regards to the increased volumetric discharge occurring as a result of the development, Table 4.13 below summarises the maximum increase in flow expected at each of the WwTWs, the current Q95 of the receiving watercourse and the percentage increase in flow expected as a result of the increased discharge. It identifies that three of the WwTWs are expected to have a sufficiently elevated discharge volume which may be noticeable, although, at under 10% of the Q95 flow it is unlikely the impact will be significant. Table 4.14 summarises the key settlements and structures located downstream of the WwTWs. Due to their rural locations, few notable receptors are located in proximity to the Glemsford and Hadleigh WwTWs. As such the impact of the elevated river flows as a result of the increased WwTW discharges is not considered to be significant. The town of Ipswich is located immediately downstream of the Sproughton WwTWs, however, due to the proximity of the tidal estuary it is unlikely the potential increase in flow will pose a significant flood risk to the town. The current predicted increase in peak river flow due to climate change is +20% which is significantly greater than the impact of the WwTW. However, any mitigation measures implemented to account for climate change should also consider the potential increases in flow due to development over the planning period, as stated in Table 4.13. It is

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recommended that further modelling is undertaken for these watercourses to asses the impact of the proposed development on river flow, once specific site allocations and locations are confirmed.

Table 4.13 - Potential Increase in River Flow as a Result of WwTW Discharge

WwTW Increase in Flow Receiving Nearest Q95 Impact of Significant Above Consent Watercourse Gauge (m³/s) Additional Flow Increase? (m³/d) on Q95 (%) Growth 2 3 4 2 3 4 Option: No Gauge Tributary of Brantham N/A N/A 166 (36001-Stour 0.566 N/A N/A 0.3 No River Stour @ Stratford) 36001 - Stour Dedham 147 147 N/A Black Brook 0.566 0.3 0.3 N/A No @ Stratford No Gauge (350001- Belstead Elmsett 0 0 N/A Gipping @ 0.125 0.0 0.0 N/A No Brook Constantine Weir) 36002 - Glem Glemsford 436 443 N/A River Glem 0.072 7.0 7.1 N/A Yes @ Glemsford 36005 - River Hadleigh 206 262 N/A River Brett Brett @ 0.091 2.6 3.3 N/A Yes Hadleigh No Gauge Holbrook Holbrook 14 20 N/A (36001-Stour 0.566 0.0 0.0 N/A No Creek @ Stratford) Long 36015 - Stour N/A 133 N/A River Stour 0.599 N/A 0.3 N/A No Melford @ Lamarsh 36006 - Stour Nayland 14 20 N/A River Stour 0.573 0.0 0.0 N/A No @ Langham 35010 - Sproughton 602 658 1171 River Gipping Gipping @ 0.186 3.7 4.1 7.3 Yes Bramford 36015 - Stour Sudbury 372 372 N/A River Stour 0.599 0.7 0.7 N/A No @ Lamarsh

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Table 4.14 - Key Settlements and Structures Located Downstream of WwTWs WwTW Downstream Settlement Downstream Structure Brantham None (estuary) Culvert under Railway Line Mill; Cattawade Industrial Estate; Cattawade; Footbridges Dedham Manningtree Elmsett Burstall; Washbrook Culvert under B1065 Glemsford Culvert under B1065 Hadleigh Southern edge of Hadleigh; ; Shelley; Higham Culvert under B1068 Holbrook Holbrook Culvert under B1080 Long Melford; Sudbury Culvert under B1064 Long Melford Culvert under A131 Stratford St Mary; Dedham Culvert under A12 Nayland Culvert under B1029 Ipswich Culvert under Railway Line Sproughton Orwell Bridge Sudbury; Great Cornard; ; Henny Street; Culvert under A131 Sudbury Lamarsh; Bures Culvert under Railway Line Culvert under B1508

4.5.6 Flood Risk to Potential development Locations

4.5.6 - 14 Table 4.15 summarises the current and future extent of Flood Zone 3 (1%, 100 year), the current and proposed defence situation, the implication of proposed management policies, downstream settlements that may be affected by upstream development, area needed for the proposed number of dwelling and the most suitable directions for growth with reference to the flood zones. Please note that the required development area is based upon Growth Option 2 and 3 trajectories, exclusive of commitments and potential future development and an average density of 40 dwellings per hectare. The conclusions carried forward into Appendix H only account for whether the settlement is at risk from tidal or fluvial flooding - it does not account for the impact of defences or the policies included within the CFMP or draft SMP.

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Table 4.15 - Impact of Flood Risk on Potential Development Locations

Proposed Number of Flood Zone 3 Defences Dwellings/ ha Equivalent

Potential Development Site # # Site Location

28 Current? Current? With Change? Climate Now Future Policies Downstream Settlements Growth 2 Option Growth 3 Option Growth 4 Option growth) (additional Direction Suitable Growth

RESIDENTIAL Hadleigh 1 Any (east: area 1) Hadleigh Layham, 290 / 427 / 2 Yes Yes Maintain West (west: area 2) Higham, 72.5ha 106.75ha Hadleigh Stratford St 3 Yes Yes Maintain East and West (north area 3) Mary Sudbury 500 / 4 Any (north area 5) 1,450 / 2,136 / 125ha Sudbury 362.5ha 534ha 350 / 5 Any (east area 6) 87.5ha Ipswich Fringe 265 / 392 / 950 / 6 (western area Yes Yes Yes Yes Reduce Ipswich South 66.25ha 98ha 237.5ha 8) 27 / 40 / 7 Acton Any 0.68ha 1.0ha 27 / 40 / North, South and 8 Bildeston Yes Yes Maintain Hadleigh 0.68ha 1.0ha West Thorington Street, 27 / 40 / North, Southwest, 9 Boxford Yes Yes Maintain Stratford St 0.68ha 1.0ha Southeast Mary 250 / 27 / 40 / 62.5ha 10 Brantham Any 0.68ha 1.0ha 700 / 175ha Wissington, 27 / 40 / 11 Bures St Mary Yes Yes Yes Maintain East Nayland 0.68ha 1.0ha Small 27 / 40 / 12 Capel St Mary Partial Partial Maintain North, South, East Hamlets 0.68ha 1.0ha 27 / 40 / 13 Chelmondiston Partial Partial Hold South 0.68ha 1.0ha 27 / 40 / 14 East Bergholt Any 0.68ha 1.0ha

28 This information has been obtained from the East Suffolk and North Essex CFMPs. Please see http://www.environment-agency.gov.uk/research/planning/114303.aspx for more details.

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Proposed Number of Flood Zone 3 Defences Dwellings/ ha Equivalent

Potential Development Site # # Site Location

28 Current? Current? With Change? Climate Now Future Policies Downstream Settlements Growth 2 Option Growth 3 Option Growth 4 Option (additional growth) Direction Growth Suitable

27 / 40 / 15 Glemsford Any 0.68ha 1.0ha Great 27 / 40 / 16 Any Waldingfield 0.68ha 1.0ha 27 / 40 / 17 Holbrook Any 0.68ha 1.0ha Brent Eleigh, 27 / 40 / 18 Lavenham Yes Yes Maintain West, East Monks 0.68ha 1.0ha Eleigh Sudbury, 27 / 40 / 19 Long Melford Yes Yes Yes Maintain North, Southeast Bures 0.68ha 1.0ha Stratford St 27 / 40 / 20 Nayland Yes Yes Yes Maintain North Mary 0.68ha 1.0ha 27 / 40 / 21 Shotley Yes Yes Yes Hold Northwest 0.68ha 1.0ha EMPLOYMENT Hadleigh 22 2ha 2ha Any (east: area 1) Sudbury (east 23 2.88ha 2.88ha Any area 6) Ipswich Fringe 24 (western area Yes Yes Yes Yes Reduce Ipswich 1.92ha 1.92ha South 8) Chilton 25 Woods, 8.32ha 8.32ha Any Sudbury 26 Brantham 3.85ha 3.85ha Any Sproughton Southwest, 27 Yes Yes Yes Yes Reduce Ipswich 11.52ha 11.52ha Northeast Lady Lane, 28 2ha 2ha Any Hadleigh Wherstead 29 Office Park, 0.1ha 0.1ha Any Wherstead Sprites Lane, 30 0.08ha 0.08ha Any Ipswich

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4.6 Demand Management and SUDS

4.6.1 - 1 Please refer to Section 2.8 - growth targets do not have a direct impact on demand management or the use of SUDS. However, the suitability of various SUDS for individual sites will need analysing with each development proposal.

4.7 Summary

4.7.1 - 1 A summary of the ability of each element of the WCS to accommodate potential development is summarised in Table 4.16 below. A colour-coded constraints matrix is provided in Appendix H which summarises the capacity of the WCS to accommodate the potential development for each growth location. Although generally the District can accommodate the potential growth, some mitigation measures are required.

Table 4.16 - Ability of WCS to Accommodate Growth Options 2 and 3

Water Cycle Growth Option 2 Growth Option 3 Growth Option 4 Element • Water AWS are confident sufficient water resources are available to support Growth Options 2 and 3. Due to its similarity in development scale, this is also valid for Growth Option 4. Resources • PZ48 will incur a negative supply demand balance by 2025 unless the Barnham Cross Transfer is implemented • PZ60 will incur a negative supply demand balance by 2015 unless a pressure reduction scheme and the Bucklesham ASR are implemented. • Leakage control, water efficiency and metering are required across the entire District to avoid water deficiency. • Very little water available for abstraction at low flows across the District and any new consumptive licences will be issued with a Hands Off Flow. Alternative sources of water, such as winter storage reservoirs should be sought for agriculture.

Funding • AWS factor the required mitigation strategies into their Business Plans on a 5 yearly basis. The large schemes listed above have been factored into their current Business Plan for AMP5. Any additional requirements will be reviewed in future Business Plan submissions. • Water No issues foreseen by AWS • New development will require on site connection - assessment will be made by AWS at planning Supply permission stage. Funding • Developer contributions and AWS (see Joint Position Statement in Section 7.5) • Wastewater Three areas of the District are located outside the catchments of WwTWs. It is assumed that any development within the unserviced areas of the Ipswich Fringe and Sudbury will be routed Treatment to neighbouring WwTWs. For infill development within the village of Assington the suitability of septic tanks should be assessed when planning applications are received. • Developers and the Council should approach AWS and the Environment Agency directly regarding any proposed development in catchments identified as not having any available headroom. • Sufficient information was not available to assess the impact of development upon CSOs. This should be undertaken once specific site allocations and locations are determined. • Eight WwTW requiring an • Nine WwTW requiring an • Two WwTW requiring an increased CDWF within increased CDWF within increased CDWF within planning period by the planning period by the planning period by the following volumes: following volumes: following volumes: Dedham: 147m³/d Dedham: 147m³/d Brantham: 166m³/d Elmsett: 0 m³/d (no Elmsett: 0 m³/d (no (higher growth scenario) headroom but no headroom but no Sproughton: 1,171m³/d development proposed) development proposed) Glemsford: 436³/d Glemsford: 443³/d • Brantham WwTW falls Hadleigh: 206m³/d Hadleigh: 262m³/d within 10% of its CDWF in

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Water Cycle Growth Option 2 Growth Option 3 Growth Option 4 Element Holbrook: 14m³/d Holbrook: 20m³/d 2021 (lower growth Nayland: 14m³/d Long Melford: 133m³/d scenario). • Sproughton: 602m³/d Nayland: 20m³/d Brantham WwTW falls within 10% of its CDWF in Sudbury: 372m³/d Sproughton: 658m³/d 2019 and requires an • Bures WwTW falls within Sudbury: 372m³/d increased consent by 2022 10% of its CDWF in 2018. (higher growth scenario). • Hadleigh WwTW falls within • • Sproughton has no spare 10% of its CDWF in 2012, Bures WwTW falls within headroom from 2010. and requires an increased 10% of its CDWF in 2018. consent by 2018. • Great Cornard WwTW • Monks Eleigh WwTW falls falls within 10% of its within 10% of its CDWF in CDWF in 2025. 2010. • Hadleigh WwTW falls • Great Cornard WwTW falls within 10% of its CDWF in within 10% of its CDWF in 2011 and requires an 2027 increased consent by • Long Melford WwTW falls 2016 within 10% of its CDWF in • Long Melford WwTW falls 2025 within 10% of its CDWF in • Dedham, Elmsett, 2022 and requires an Glemsford, Holbrook, increased consent by Nayland, Sproughton and 2027 Sudbury have no spare • Monks Eleigh WwTW falls headroom from 2010. within 10% of its CDWF in • Commitments in Nedging > 2010. 20% of Total PE in 2011. • Dedham, Elmsett, Requires discussion with Glemsford, Holbrook, AWS. Nayland, Sproughton and Sudbury have no spare headroom from 2010. • Commitments in Nedging > 20% of Total PE in 2011. Requires discussion with AWS. Funding • Additional improvements will be sought from Developer contributions and AWS (see Joint Position Statement in Section 7.5). Planning is required in advance. • Wastewater Foul and surface water sewer upgrades required. • Significant upgrades required in certain locations - Sudbury and Great Cornard require Collection immediate upgrade to the sewer networks before development can take place. Funding • Developer contributions (see Joint Position Statement in Section 7.5). Planning is required in advance. • Water The maximum proposed growth is not currently constrained by the WFD ‘no deterioration’ objective. Quality and • As their phosphate limits are borderline with the current economic limit of conventional treatment Environment under the WFD ‘no deterioration’ objective, Nayland cannot accommodate growth above 51 dwellings and Dedham cannot accommodate more than ‘infill’ development. • Physical expansion area is not a constraint at any of the WwTWs requiring an increase to their CDWF within the planning period as a result of the proposed development. • AWS required to review the deliverability of additional treatment processes on a site by site basis once development trajectories and sites are finalised. • The proposed growth in the catchments of the assessed WwTWs, with the exception of Sproughton, are not currently constrained by the WFD ‘Good Status’. The full quota of growth should not be pursued for Sproughton. • Policies in the Core Strategy and accompanying documents need to be flexible enough to deal with potential deliverability issues surrounding any revisions in discharge consents. • Development must not negatively impact the current status of the watercourses and, where possible, assist in improving the quality of all watercourses to ‘good’ by 2015. • It is not anticipated that the proposed development will have a significant effect on internationally designated sites, but this should be confirmed through the Habitats Regulations assessment of the Core Strategy. • The full quota of growth should not be pursued for

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Water Cycle Growth Option 2 Growth Option 3 Growth Option 4 Element Sproughton.

Funding • Consents to be reviewed by the Environment Agency and AWS to review and upgrade its WwTW processes. Funding may be sought through Business Plan submissions. • • Flood Risk Site specific FRAs are required for all development sites located in fluvial/tidal and where a site is greater than 1 hectare (Flood Zones 1, 2 and 3) or where a site falls within a critical drainage area. • FRAs must assess the impacts of runoff from development sites and propose appropriate mitigation strategies. • Surface water flooding information should be considered when assessing the surface water management for the site. • Development should be located in fluvial Flood Zone 1 as far as possible. • The increase in discharge predicted from the Glemsford, Hadleigh and Sproughton WwTWs may result in a minor increase of river flow. As the increase is <10% of the current Q95 it is unlikely the impact will be significant. Modelling is required to determine the severity or extent of any impacts. • Hadleigh and Sproughton both have large settlements located downstream of their discharge points. • River flows are expected to increase by another 20% as a result of climate change and mitigation measures should account for climate change and increased discharge flows. • Larger potential development locations would benefit from hazard mapping. • Due to historic occurrences and surface water flood extents, Sudbury would benefit from a Surface Water Management Plan. • Further modelling should be undertaken for the following watercourses to determine the impact of increased flow as a result of the proposed development: • Glemsford WwTW increase • Glemsford WwTW • Sproughton WwTW in Q95 river flow of 7% increase in Q95 river flow increase in Q95 river flow • Hadleigh WwTW increase in of 7.1% of 7.3.% Q95 river flow of 2.6% • Hadleigh WwTW increase • Sproughton WwTW in Q95 river flow of 3.3% increase in Q95 river flow of • Sproughton WwTW 3.7% increase in Q95 river flow of 4.1% Funding • FRAs to be undertaken by developers. • Hazard Maps to be funded by Council • SWMP to be undertaken by Council. • Demand Promotion of sustainable housing for water efficiency and metering. • As per FWMA all development applications should include a SUDS scheme. Management • Retrofitting of SUDS wherever possible. and SUDS • Some restriction to SUDS techniques have been identified due to location of GWV, SPZ and permeability. Funding • Sustainable housing requirements to be implemented by developers • Potential for Strategic SUDS to be investigated (potential to be implemented by Council and recovered via Section 106, for example) • Design of SUDS schemes to be undertaken by developers • SUDS to be reviewed, adopted and maintained by Suffolk County Council (re FWMA)

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5 GROWTH OPTION 5: MAXIMUM CAPACITY

5.1 Water Resources and Supply

5.1.1 Water Resources

5.1.1 - 1 AWS have based their FWRMP on the former and draft RSS targets and through discussion with AWS, it has been determined that there is some flexibility within the figures used in the FWRMP. As such, the maximum scenario for water resources can be estimated to be slightly higher than Growth Option 3, although it is impossible to quantify the exact capacity of system. As water resources are managed at a WRZ scale, the boundaries of which extend beyond the District, it is also not possible to determine the maximum capacity at a District scale. Within the FWRMP the following growth scenarios were assessed for each WRZ:

WRZ09: • Development of 700 dwellings per year; • Increase in domestic demand of 46-52Ml/d; • Commercial demand to remain steady at 14Ml/d; • Leakage to remain at 17Ml/d; and • Final planning scenario to utilise maintenance of demand management through leakage control, household metering and promotion of water efficiency.

WRZ10: • Development of 2,600 dwellings per year; • Increase in domestic demand of 76-85Ml/d; • Commercial demand to remain steady at 25Ml/d; • Leakage to remain at 23Ml/d; and • Final planning scenario to utilise maintenance of demand management through leakage control, household metering and promotion of water efficiency.

5.1.1 - 2 The maximum scenario for Babergh District is therefore dependent upon the scale of development undertaken in the surrounding Local Authority areas which share these WRZs. At a WRZ level the maximum capacity of water resources, utilising the mitigation measures planned by AWS and identified in Sections 4 and 5, are as stated above.

5.1.1 - 3 The maximum capacity for direct abstraction has almost already been met, and in some cases exceeded, as shown in the CAMS Resource Assessment. Only the Belstead Brook has some remaining capacity, but a Hands Off Flow will still apply.

5.1.2 Water Supply

5.1.2 - 4 As no network modelling has been undertaken as part of this WCS, it is difficult to quantify the maximum capacity of the water supply network. However, as AWS have identified that there is sufficient capacity to supply Growth Option 3, it can be inferred that there is spare capacity within the system to accommodate growth scenarios greater than the Growth Options 2 and 3. As Growth Option 4 refers mainly to redistribution of growth rather than increased growth above Growth Option 3, it is also assumed that there is sufficient capacity within the system to accommodate the alternative growth scenarios. This will depend on the density and location of development and any

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development projections greater than the total proposed in Growth Option 3 should be discussed with AWS at the earliest possible opportunity by the Council.

5.2 Wastewater Treatment and Collection

5.2.1 Wastewater Treatment

5.2.1 - 1 Using the available headroom volume, the maximum number of dwellings that can be accommodated within the current CDWF for each WwTW has been calculated:

Table 5.1 - Maximum WwTW Capacity, Flow and Dwelling Numbers

WwTW Settlements Measured CDWF Available Headroom? 4 Dwelling Equivalent DWF (m³/d) Headroom6 (Average 2004 - 2010) (m³/d) Capel St Mary; BENTST Yes 48 Bentley 641 83 BILDST Bildeston; Hitcham 2502 3103 Minimal (Limited) 5 (150) BOXFST Boxford; Polstead 3431 420 Minimal 193 Brantham; Sutton; BRANST Yes 895 Tattingstone 552 910 BRENST Brent Eleigh N/A - Small Package Plant 5 N/A 0 BRETST Brettenham N/A 0 N/A - Small Package Plant 3 BUREST Bures 207 250 Minimal 108 Ipswich Fringe; Yes CHANST Copdock; 4,495 Washbrook 34021 5200 CHEMST Chelmondiston 1292 1913 Yes (but Limited) 5 (155) CLQYST Ipswich Fringe 23370 34213 Yes 27,108 COCGST Cockfield N/A 0 N/A - Small Package Plant 18 COCMST Cockfield N/A 0 N/A - Small Package Plant 5 COCWST Windsor Green N/A 0 N/A - Small Package Plant 4 DEDHST Stratford St Mary 7571 610 No 0 EBERST East Bergholt 3971 560 Yes 408 ELMSST Hadleigh; Elmsett 3342 334 No 0 ERWAST Shotley N/A 0 N/A - Small Package Plant GLEMST Glemsford; Hartest 1426 1032 No 0 Sudbury; Great Yes GCORST 2,315 Cornard 1524 2450 Great Yes GWLDST Waldingfield; 388

Acton 315 470 GWENST Capel St Mary 3452 6173 Yes (but Limited) 5 (680) GROCST Groton N/A 0 N/A - Small Package Plant 2 GROPST Groton N/A 0 N/A - Small Package Plant 2 HADLST Hadleigh 14862 17003 Minimal (Limited) 5 (535)

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WwTW Settlements Measured CDWF Available Headroom? 4 Dwelling Equivalent DWF (m³/d) Headroom6 (Average 2004 - 2010) (m³/d) HINTST Hintlesham 60 136 Yes 190 HOLKST Holbrook 5002 500 No 0 KERSST Kersey N/A 0 N/A - Small Package Plant 20 LAVHST Lavenham 232 480 Yes 620 Lindsey - Church LINCST N/A - Small Package Plant 2 Road N/A 0 Lindsey - Frogs LINFST N/A - Small Package Plant 2 Hall N/A 0 Long Melford; LMELST Acton; Sudbury; Yes 1,933 Great Waldingfield 798 1571

MILPST N/A - Small Package Plant 3 N/A 4 MONEST Monks Eleigh 1001 111 Minimal 28 Nayland, NAYLST Polstead; Stoke by No 0 Nayland 10382 1038 NEDGST N/A 0 N/A - Small Package Plant 2 NEDTST N/A 0 N/A - Small Package Plant 11 PRESST N/A 0 N/A - Small Package Plant 7 SHIMST Lawshall 132 260 Yes 320 SHOTST Shotley 3391 662 Yes 808 Ipswich Fringe; SPRCST No 0 Sproughton 4182 418 SUDBST Sudbury 49022 4902 No 0 THOSST N/A 0 N/A - Small Package Plant 8 THMBST N/A 0 N/A - Small Package Plant 2 THMPST N/A 0 N/A - Small Package Plant 2 WHATST 441 95 Yes 128

NOTES 1 Anomalies removed from the 2004 - 2010 average calculations 2 WwTW stated to be at capacity by AWS, therefore DWF = CDWF 3 CDWF manually lowered by AWS to provide a ‘safety factor’ in calculations 4 ‘Minimal’ represents <20% headroom remaining 5 Limited status identified by AWS - remaining headroom in dwellings calculated but requires confirmation by AWS as sites are proposed for development. 6 For the small package plants, a conservative value of 10% of the current Total Population Equivalent (PE) has been used as a guide. In reality the maximum remaining headroom in dwelling numbers may be slightly higher or lower than the quoted value. A site specific review will be required by AWS as and when planning applications are submitted.

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5.2.1 - 2 For a number of the WwTWs a significant number of dwellings can be accommodated within the remaining flow headroom (please note these calculations refer to residential development only). The exceptions to this are the works identified as already operating at capacity or with minimal or limited headroom. The smaller package plants do not have a consented flow and, as such an estimate of remaining headroom has been made based on 10% of the current total population equivalent. For these works, AWS will review the availability of WwTW headroom and permitting implications as sites are put forward for planning permission.

5.2.2 Wastewater Collection

As no network modelling has been undertaken as part of this WCS, it is difficult to quantify the maximum capacity of the wastewater network. However, as AWS have identified that there is generally sufficient capacity to supply Growth Option 3, although some upgrades will be required, it can be inferred that there is spare capacity within the system to accommodate higher growth scenarios (including Growth Option 4). This will depend on the density and location of development, especially in the Great Cornard and Sudbury areas and any development projections greater the Growth Option 3 in these locations should be discussed with AWS at the earliest possible opportunity by the Council.

5.3 Water Quality and the Environment

5.3.1 - 1 From the calculation of indicative consent limits conducted by the Environment Agency it can be seen that, for most of the WwTWs the maximum capacity (with the aim for ‘no deterioration’) is higher than all the proposed growth scenarios, dependent upon AWS’ opinion as to the deliverability of the processes required to meet the tighter treatment limits. The two exceptions to this are Dedham and Nayland WwTWs, for which the required ammonia and phosphate limits are close to the current limit of economic treatment. For these two works, the maximum capacity should therefore be considered equivalent to Growth Option 3 - 40 dwellings plus 11 windfalls within the Nayland catchment and infill development only within the Dedham catchment.

5.3.1 - 2 When the maximum capacity of the WwTWs with respect to achieving ‘Good Status’ under the WFD is considered, discussion in Section 3.4 indicates that although the proposed development has not increased the level of improvements required at the works without any growth, for almost all works the required phosphorous levels are beyond the current economic limits of treatment. It is therefore not recommended that additional growth beyond the maximum levels proposed in Growth Options 2 - 4 is proposed without confirmation from AWS that the stricter discharge limits are achievable. An exception to this is Sproughton WwTW, for which the proposed level of growth is not considered achievable under the requirements of the WFD to meet ‘Good Status’ (showing a significant tightening of the phosphorous limit beyond the economic limit of treatment as a direct result of the proposed growth). According to their indicative consent limit calculations the Environment Agency have identified the maximum dry weather flow that could be accommodated, using conventional technology, to achieve the good status is 1,080m³/day. If the required level of employment growth is kept the same, then the maximum number of houses that can be accommodated within the catchment is 890 dwellings, rather than the 950 proposed in Growth Option 4.

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Alternatively, the 950 dwellings can be accommodated, but the category B8 employment allocation must be reduced by 1.7ha. The proposed growth for this WwTW catchment for Growth Options 2 and 3 are well below this maximum limit.

5.4 Flood Risk

5.4.1 - 1 A rough calculation has been carried out to estimate the area of the District located outside the fluvial, tidal and surface water Flood Zones 2 and 3. A similar calculation has been carried out for each of the potential growth locations (Towns/Urban areas and Key Service Centres). The area considered in each case is bounded by the circular outlines shown on Figures 2a and 2b. To provide a conservative estimate of the remaining land available for development, the current developed area within each growth location (as shown on OS mapping) has also been roughly calculated and subtracted. The calculated area in each case has been converted to dwelling numbers (highlighted in yellow within Table 5.3) using a density of 40 dwellings per hectare. The resulting capacity is far in excess of all the Growth Options considered and it can be concluded that as long as a sequential approach is applied, flood risk, by itself, is unlikely to be a major constraint to development in the District, although the appropriate site specific FRAs, surface water drainage schemes and mitigation measures will be required for each development, as recommended within the SFRA.

5.4.1 - 2 As the SFRA has not identified sewer or groundwater flooding as a major issue within the District, those sources of flooding have not been taken into account within this assessment.

Table 5.2 - Maximum Capacity of District for Development outside Fluvial, Tidal and Surface Water Flood Zones

Potential Area in Site Development Area in Surface Water Current # Location Floods 'Less Than' Settlement Remaining Area Zone 2 & 3 Outline Area (OS Map) Developable Area ha ha ha ha ha Dwellings RESIDENTIAL 1 Hadleigh 101.6 0.0 4.4 7.0 90.2 3,609 (east: area 1) 2 Hadleigh 118.6 9.9 19.2 8.0 81.5 3,260 (west: area 2) 3 Hadleigh 72.3 12.3 19.8 38.0 2.2 89 (north area 3) 4 Sudbury 155.1 0.0 4.0 0.0 151.1 6,044 (north area 5) 5 Sudbury 218.3 0.0 15.5 23.0 179.9 7,194 (east area 6) 6 Ipswich Fringe 158.0 14.1 22.0 33.0 88.8 6,452 (western area 8) 7 Acton 148.3 0.0 11.9 50.0 86.3 3,452 8 Bildeston 132.9 7.7 20.5 30.0 74.7 2,987 9 Boxford 186.0 15.3 29.5 33.0 108.2 4,328

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Potential Area in Site Development Area in Surface Water Current # Location Floods 'Less Than' Settlement Remaining Area Zone 2 & 3 Outline Area (OS Map) Developable Area ha ha ha ha ha Dwellings 10 Brantham 253.1 37.1 36.7 67.0 112.4 4,495 11 Bures St Mary 208.8 32.5 19.1 50.0 107.2 4,287 12 Capel St Mary 313.1 0.0 44.3 77.0 191.8 7,672 13 Chelmondiston 168.7 1.8 13.8 30.0 123.1 4,926 14 East Bergholt 186.0 0.0 13.4 54.0 118.6 4,745 15 Glemsford 218.3 0.0 7.9 67.0 143.4 5,736 16 Great Waldingfield 152.2 0.0 33.9 40.0 78.3 3,132 17 Holbrook 275.0 10.5 30.2 40.0 194.2 7,769 18 Lavenham 190.4 9.8 26.7 44.0 110.0 4,399 19 Long Melford 318.9 48.5 81.5 71.0 117.9 4,715 20 Nayland 168.7 51.7 44.7 30.0 42.3 1,692 21 Shotley 649.7 113.2 150.7 66.0 319.7 12,789 TOTAL 110,888 EMPLOYMENT 22 Hadleigh (east: 101.6 0.0 4.4 7.0 90.2 N/A area 1) 23 Sudbury (east area 218.3 0.0 15.5 23.0 179.9 N/A 6) 24 Ipswich Fringe 158.0 14.1 22.0 33.0 88.8 N/A (western area 8) 25 Chilton Woods, 80.6 0.0 5.9 10.0 64.7 N/A Sudbury 26 Brantham 253.1 37.1 36.7 67.0 112.4 N/A 27 Sproughton 77.6 0.0 14.7 24.0 38.9 N/A 28 Lady Lane, 62.4 0.0 2.9 41.5 18 N/A Hadleigh 29 Wherstead Office 43.5 0.0 2.4 6.0 35.1 N/A Park, Wherstead 30 Sprites Lane, 38.1 0.0 2.1 34.6 1.4 N/A Ipswich TOTAL 629.4

5.5 Demand Management and SUDS

5.5.1 - 1 Please refer to Section 2.8. As development trajectories and growth targets do not have a direct impact on demand management or the use of SUDS, it is not possible to calculate a ‘maximum’ capacity. However, the suitability of various SUDS for individual sites will need analysing with each development proposal to ensure that the development does not negatively impact the environment, either in terms of flood risk or pollution.

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5.6 Summary

5.6.1 - 1 A summary of the maximum capacity of each element of the WCS is summarised in Table 5.4 below. The constraints matrix in Appendix H summarises the maximum capacity for each of the main settlements within the District.

Table 5.3 - Maximum Capacity of WCS

Water Cycle Element Maximum Capacity Water Resources • With mitigation measures proposed by AWS, maximum capacity assumed to be marginally greater than Growth Option 3 (and therefore 4), but dependent upon development in neighbouring Local Authority areas within the shared WRZs and PZs. • Without mitigation measures, maximum capacity of PZ48 will be reached in 2025 and the maximum capacity of PZ60 will be reached in 2015. • Maximum abstraction capacity already reached. Water Supply • Capacity of current network, with no upgrade, has already been reached. • With upgrade stated by AWS, assumed to be greater than Growth Options 3 and 4. but dependent upon location and density. Wastewater Treatment • A number of WwTWs have spare flow capacity for a significant number of dwellings, however with the exception of the seven WwTWs currently at capacity. None of these WwTWs have spare capacity for growth without upgrades. • A maximum capacity for the small package plants has been estimated as 10% of the current total PE. AWS should be consulted regarding capacity at these works as sites come forward for development. Wastewater Collection • Assumed that the current maximum is slightly higher than Growth Options 3 and 4.although some upgrades will be required. Capacity severely limited in Sudbury and Great Cornard area. Water Quality and • For most of the WwTWs the maximum capacity with regards to water quality is Environmental greater than Growth Options 3 and 4. Designations • Growth Option 3 represents the maximum capacity at Nayland and Dedham WwTWs • Maximum capacity for Sproughton WwTW is slightly lower than Growth Option 4 - 890 dwellings with the full employment quota or 1.7ha less B8 development with the full 950 dwellings. Flood Risk • Due to area of land outside fluvial, tidal and surface water flood zones, maximum capacity is assumed to be high (greater than Growth Options 3 and 4), neglected other development constraints. • Site specific FRAs and mitigation measures will be required as appropriate. Demand Management • No maximum capacity - suitability depends on local conditions. and SUDS

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6 CONSTRAINTS MATRIX AND CONCLUSIONS

6.1 Development Location Specific Conclusions and Timelines

6.1.1 - 1 A summary of each of the elements of the water cycle with regards to the current situation, their ability to accommodate two higher scenarios of growth and their maximum capacity have been summarised at the end of Sections 3, 4 and 5. These summary tables also identify the required improvements and additional studies, in addition to sources of funding, to enable the potential development to take place. Appendix H summarises the conclusions for each of the potential development locations, highlighting any constraints and outlining the mitigation required. AWS have provided the following ‘RAG’ key for use in this WCS, which classifies the traffic light colour coded scheme utilised within Appendix H. To enable comparison this colour scheme has also been used to classify the current situation. Summary conclusions for each growth option are provided below.

Table 6.1 - RAG Key

Colour Implication Red Major Constraints to Provision of infrastructure and/or treatment to serve proposed growth Amber Infrastructure and/or treatment upgrades required to serve proposed growth Green Capacity available to serve the proposed growth N/A Outside AWS’ boundary of water supply and / or service for sewerage treatment purposes

6.1.2 Growth Option 1 - Current Situation

6.1.2 - 2 The current situation of the water cycle within the District is generally favourable in all locations. However, there is a requirement to improve the situation in terms of wastewater treatment, water quality and the status of environmentally designated sites, as discussed below:

 There are currently sufficient water resources to supply the existing requirements, although some abstraction restrictions are currently in force at low flows from all waterbodies and some waterbodies are over-abstracted at low flows.

 There are no capacity restrictions within the water supply network and no records of low flows. Some leakage does occur from the water supply network but this is relatively low and not considered to be an issue.

 The wastewater treatment system is the most concerning element of the water cycle for the current scenario, with the Dedham, Elmsett, Glemsford, Holbrook, Nayland, Sproughton and Sudbury WwTWs identified as currently being at capacity with no available headroom. An additional seven WwTWs - Bildeston, Boxford, Bures, Chelmondiston, Great Wenham, Hadleigh and Monks Eleigh - have minimal or limited headroom.

 No wastewater network restrictions have been identified by AWS, although some sewer flooding issues have been reported in the Sudbury, Stratford St Mary and East Bergholt areas due to surface water in storm events.

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 Some water quality issues have been identified within the District. Phosphorous levels are high and most watercourses classified as having ‘moderate’ ecological status. Ammonia levels are very low and should be maintained through implementation of the appropriate WwTW discharge limits, which should also seek to improve the ecological status of the watercourses to ‘good’ by 2027, as specified under the WFD.

 Two Environmentally Designated sites - Cattawade Marshes and Cornard Mere - have been identified as being in unfavourable condition due to water cycle processes, namely water level management, drainage and/or abstraction and partnership working between the Council, Natural England, the Environment Agency and AWS should be undertaken to seek resolution to these issues (please note it is unlikely these issues will be affected by the proposed development). Although located downstream of multiple WwTWs, WwTW discharge has not been identified as a cause of the current unfavourable or mixed status of the Stour and Orwell Estuaries.

 Tidal, fluvial and surface water flood risk affects many areas of the District. Much of this risk is already mitigated with flood defences and warning systems and some modelling and mapping has been undertaken to assess the residual hazard. Additional 2d modelling of the key flood risk areas, especially around the larger settlements, such as Sudbury, Bures, Long Melford, Nayland and Shotley to determine the flood hazard and residual risk would assist the Council in locating new developments and planning emergency strategies.

 Some demand management techniques are already in operation across the District, although improvements would assist in improving the current water resources and improve the sustainability of the current development. Metering is currently relatively high compared to other areas within the region, however additional voluntary uptake is required and planned by AWS. Retrofitting of existing development towards water neutrality.

 SUDS schemes should be retrofitted to existing development wherever possible to reduce surface water runoff, thereby reducing surface water flood risk and surface water sewer exceedence, and reduce the transmission of surface pollution to the watercourses.

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6.1.3 Growth Options 2, 3 and 4 - Former RSS Targets, Draft RSS Review to 2031 and Alternative Options

6.1.3 - 3 Most elements of the water cycle have sufficient capacity to accommodate Growth Options 2, 3 and 4 although some locations require infrastructure upgrade, dependent upon the site specifics at each settlement. This will require review by the developer on a site specific basis once the exact locations have been defined.

6.1.3 - 4 All the recommendations for the current situation, outlined in Section 6.1.1 above are still valid, regardless of the development scenario. To provide an idea of the changing constraints across the planning period, Table 6.2 provides a constraints timeline for each element of the water cycle. The RAG colours used match those shown in Appendix H (which should be referred to for more detail regarding individual locations) and reflect the ‘worst case’ location. Table 6.3 summarises the mitigation measures required to accommodate the proposed growth.

6.1.3 - 5 In summary:

 AWS are confident that sufficient water resources are available for the potential development, although mitigation measures are required for a number of locations.

 No major improvements are required to the water supply network, although all sites will require on-site connection, funded through developer contributions.

 Many of the WwTWs require capacity improvement to accommodate the potential development under all three growth scenarios, affecting Brantham (Growth Option 4 only), Dedham, Elmsett, Glemsford, Hadleigh, Holbrook, Nayland, Sproughton and Sudbury (see Table 4.10 for identification of the WwTWs affected by each Growth Option). A number are identified as having limited headroom early in the planning period, which should be accounted for by the Council when planning growth trajectories (these should be confirmed with AWS as soon as possible). Development within the catchments of these WwTWs may be delayed and/or require additional developer contributions due to the upgrades required to meet stricter discharge consent limits (see joint position statement in Section 7.5). The village of Assington is not connected to the WwTW network and, as such, the suitability of connection and installation of septic tanks should be assessed when planning applications are received.

 Although there is generally sufficient capacity to accommodate the Growth Options, the entire sewer network requires some upgrade in all locations. However, the capacity in Sudbury and Great Cornard is very limited and requires resolution before any additional development can take place (N.B. this does not directly impact the proposed growth scenarios). Funding should be sought from developers and AWS should be informed of final growth trajectories and site locations as early in the planning process as possible.

 The Indicative Consent Limits identify that the maximum proposed growth scenarios are not currently constrained by the WFD ‘no deterioration’ objective, although the capacity for growth in Nayland and Dedham is reached by the Growth Option 3. The proposed level of growth is also not constrained by the

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WFD ‘Good’ status, with the exception of Sproughton, for which the full quota of growth proposed in Growth Option 4 should not be pursued. AWS are required to review the deliverability of additional treatment processes on a site by site basis once development trajectories and sites are finalised and policies in the Council’s Core Strategy and accompanying documents need to be flexible enough to deal with potential deliverability issues surrounding any future revisions in discharge consents.

 No significant impact of the potential development upon the environmentally designated sites has been identified although confirmation is required through the Habitats Regulation assessment of the Core Strategy.

 Location of development within some settlements will be restricted by flood risk and development should be located in Flood Zone 1 as far as possible (the Sequential and Exception Tests (as necessary) must be applied where required) FRAs are required for all sites located within areas of flood risk (fluvial, tidal or surface water). Location of development within Sudbury, and the required improvements to the sewer network, would be assisted through undertaking a SWMP. The increased discharge from WwTWs as a result of development is relatively small in relation to the baseflow and is unlikely to impact flood risk downstream. Any mitigation measures should account for increased baseflow and climate change.

 Demand management techniques, including rainwater harvesting and greywater recycling, should be implemented, with an aim for water neutrality. Water meters should be promoted.

 Suitable SUDS schemes are required with all new development applications (in accordance with the FWMA), which ensure all surface water is dealt with on site and no pollution enters the waterbodies. Some restrictions have been identified to the suitability of some SUDS techniques, but this is not a constraint to the use of SUDS overall.

Table 6.2 - Ability of WCS to Accommodate Growth Options 2, 3 and 4 (See Appendix H for Detail)

Water Cycle Element 2010 - 2015 2015 - 2020 2020 - 2025 2025 - 2030 Water Resources PZ48 G G G A PZ62 G G G G PZ60 G A A A PZ61 G G G G Water Supply G G G G Wastewater Treatment G/A/R G/A/R G/A/R G/A/R Wastewater Collection A/R A/R A/R A/R Water Quality Growth Option 2 G/A G/A G/A G/A and the Growth Option 3 G/A G/A G/A G/A Environment Growth Option 4 G/A G/A G/A G/A/R Flood Risk G/A G/A G/A G/A Demand Management G G G G Suitability of SUDS G/A G/A G/A G/A

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Table 6.3 - Mitigation Measures Required for WCS to Accommodate Growth Options 2, 3 and 4 Water Cycle Element 2010 - 2015 2015 - 2020 2020 - 2025 2025 - 2030 Water Barnham Cross Leakage Control Leakage Control GOGS South Resources Transfer; (All Growth PZ48 Leakage Control; Options) Water Efficiency; Metering Leakage Control; Leakage Control; Leakage Control; Leakage Control; PZ62 Water Efficiency; Water Efficiency; Water Efficiency; Water Efficiency; Metering Metering Metering Metering Pressure Ipswich Discharge Water Efficiency; Water Efficiency; Reduction; Reuse; Metering Metering Bucklesham ASR; Water Efficiency; PZ60 Leakage Control; Metering Water Efficiency; Metering Leakage Control; Leakage Control; Leakage Control; Leakage Control; PZ61 Water Efficiency; Water Efficiency; Water Efficiency; Water Efficiency; Metering Metering Metering Metering Limited No abstraction at No abstraction at No abstraction at abstraction at Low Low Flows Low Flows Low Flows Flows Water Supply On site supply network Wastewater Consent Increase Consent Increase Consent Review - Consent Increase Treatment Growth - 7 WwTW - 1 WwTW 2 WwTW - 1 WwTW Option 2 Consent Review - Consent Review - 7 WwTW 1 WwTW Consent Increase Consent Increase Consent Review - Consent Review - Growth - 7 WwTW - 1 WwTW 2 WwTW 1 WwTW Option 3 Consent Review - Consent Review - Consent Increase 7 WwTW 1 WwTW - 1 WwTW Growth Consent Increase Consent Review - Consent Increase Consent Review - Option 4 - 1 WwTW 3 WwTW - 1 WwTW 1 WwTW Wastewater Collection Surface and Foul upgrades where necessary. Significant upgrade in Sudbury and Great Cornard to enable development. Water Quality and Review of required discharge volumes by Environment Agency to determine Environment appropriate discharge limits. Followed by tightening of discharge consents of (All Growth Options WwTW within the Economic Limit of Conventional Treatment by AWS. No capacity for deterioration in any watercourse. Water Quality and Redistribution of Environment some growth from (Option 4 only) Sproughton WwTW catchment to neighbouring catchment or alternative development site.

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Water Cycle Element 2010 - 2015 2015 - 2020 2020 - 2025 2025 - 2030 Flood Risk Site Specific FRAs, accounting for the impacts of Climate Change and residual flood risk behind defences. Any future modelling to account for increase in WwTW flows and climate change. Demand Management and Metering and water efficiency measures required in all developments. SUDS Suitable SUDS required for all developments, accounting for local ground conditions and restrictions.

6.1.4 Growth Option 5 - Maximum Capacity

6.1.4 - 6 Due to their nature, it is difficult to quantify the maximum capacity of many elements of the water cycle, although as far as possible this has been undertaken with the following conclusions:

 The maximum capacity of the water resources is assessed on a regional scale, but is greater than Growth Options 3 and 4.

 As no models have been undertaken it is not possible to quantify the maximum capacity of the water supply network, but from consultation with AWS it is deemed to be slightly greater than Growth Options 3 and 4 (dependent upon location and density).

 Seven of the WwTWs currently have no headroom available - the current situation can therefore be considered their current maximum capacity. The capacity of the all the other WwTWs is greater than the Growth Option 3 figures, with the exception of Hadleigh, which has a maximum capacity just less than Growth Option 2 and Brantham, which has a maximum capacity just less than Growth Option 4. Predicted maximum capacity numbers are provided in Appendix H.

 The overall capacity of the WwTW network is considered to be greater than Growth Options 3 and 4. However, although there is theoretically capacity to accommodate the growth, upgrades are required in specific locations. Most notably, without the implementation of any improvements, it can be assumed that the sewer network is already operating at maximum capacity within the Sudbury and Great Cornard areas.

 For most of the WwTWs the maximum capacity with regards to water quality is greater than Growth Options 3 and 4 (i.e. the consent limits within the economic limit of conventional treatment). However, Growth Option 3 represents the maximum capacity at Nayland and Dedham WwTWs and Sproughton’s maximum capacity is slightly lower than Growth Option 4.

 It is difficult to quantify the maximum capacity of the environment in terms of flood risk as the development locations cover a broad area. Within these locations the maximum capacity in terms of area located outside the Flood Zones 2 and 3 has been estimated and is far in exceedence of the Growth Options 3 and 4.

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 It is not possible to estimate the maximum capacity of the environment for demand management or SUDS, but both are greater than Growth Options 3 and 4, providing the identified restrictions are adhered to.

6.2 Recommendations

6.2.1 - 1 Overall there are no complete showstoppers to the required growth targets within Babergh District, although some redistribution of growth between areas may be required and site specific investment is essential. In most cases the maximum capacity is beyond Growth Options 3 and 4. However, there are a number of measures that require implementation or review to enable development (particularly for Growth Option 3 or Growth Option 4) to proceed. Many of these are required immediately, rather than as a result of the potential development scenarios, although some of the WwTW and water quality improvements are not required until the latter half of the planning period. Most are required on a site specific basis and will be funded through a combination of AWS funding and/or developer contributions at planning application stage. The more strategic measures, to be considered and implemented by the Council consist of policies to reduce pollution and further flood risk analysis for the larger developments. All the recommendations highlighted within this report are listed below:

6.2.1 - 2 Water Resources • Implementation of mitigation measures identified in FWRMP by AWS; • Promotion of water efficiency in all new developments by developers and the Council; • Alternative sources of water supply for agriculture other than abstraction, promoted by the Council; and • Funding to be applied for by AWS as part of Business Plans.

6.2.1 - 3 Water Supply • Funding of on-site connections by developers.

6.2.1 - 4 Wastewater Treatment • Review of required discharge volumes at Dedham, Elmsett, Glemsford, Holbrook, Nayland, Sproughton and Sudbury WwTWs by AWS and the Environment Agency before additional development takes place; • Review of required discharge volumes at Brantham, Hadleigh and Long Melford WwTWs within the planning period (dependent upon Growth Option); and • Funding sources to be agreed between AWS and developers.

6.2.1 - 5 Wastewater Collection • Foul upgrades in all locations (dependent upon location), funded by developer contributions and AWS; • Requirement for surface water upgrade will be dependent upon efficiency of SUDS and location of suitable ‘discharge’ watercourses; and • Immediate review and upgrade of Sudbury and Great Cornard sewers.

6.2.1 - 6 Water Quality and Environment • Growth Options 2 and 3 and most of Growth Option 4 are within the Current Economic Limit of Conventional Treatment for the Indicative Consent Limits;

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• With the exception of Sproughton the proposed growth is not currently constrained by the WFD ‘no deterioration’ or ‘good’ status; • The full quota of growth for Growth Option 4 cannot be accommodated within the Sproughton WwTW. • Consents to be reviewed by the Environment Agency and AWS to review and upgrade its WwTW processes. Funding may be sought through Business Plan submissions; • Flexibility within the Core Strategy is required to accommodate potential redistribution of growth between development sites; • Development must not negatively impact the current status of the watercourses and, where possible, assist in improving the quality of all watercourses to ‘good’ by 2015; and • No significant impacts to environmentally designated sites identified.

6.2.1 - 7 Flood Risk • Site specific FRAs required for locations in Flood Zones 2 or 3 or that are greater than 1 hectare in Flood Zone 1; • Development should be located as far as possible in Flood Zone 1; • SUDS required for all new development to reduce sewer and surface water flooding; • No significant flood risk identified from WwTWs; • Hazard mapping may benefit larger development sites, located close to defences or Flood Zones 2 and 3; and • SWMP may benefit future development of Sudbury.

6.2.1 - 8 Demand Management and SUDS • Promotion of sustainable housing, water efficiency and metering required across the District; • SUDS schemes required in all new development applications and retrofitting of SUDS within existing development, wherever possible; and • Some restrictions to SUDS due to GWV and SPZs.

6.3 Future Updates

6.3.1 - 1 The Water Cycle Study is not a static document. This report represents a moment in time within a rapidly developing and changing environment. For the Study to maintain its usefulness and to grow, future updates will be essential. Key areas will be to monitor actual developments and revisions to the projections for growth, together with changes to infrastructure and other water related activities. In addition changes to legislation and guidance in the production of Water Cycle Studies may need to be included. Furthermore, additional detail should be considered as and when data is available.

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7 GUIDANCE DOCUMENTS

7.1 Flood Risk

7.1.1 Flood Zone Restrictions

7.1.1 - 1 Table 7.1 below shows the Flood Risk Vulnerability and Flood Zone Compatibility (from PPS25), together with the requirement for application of the Exception Test. The Sequential Test is required for all development except for changes of use and minor development as set out within paragraph D15 of PPS 25.

Table 7.1 - Flood Risk Vulnerability and Flood Zone “Compatibility” (from PPS25)

Flood Definition Flood Risk Vulnerability Classification Zone Essential Water Highly More Less Infrastructure Compatible Vulnerable Vulnerable Vulnerable Zone 1 Low Probability: less than 1:1000 probability      of river or sea flooding in any year (<0.1%) Zone 2 Medium Probability: 1%-0.1% probability of Exception Test river flooding or 0.5%-0.1% probability of sea     Required flooding in any year Zone 3a High Probability: >1% probability of river Exception Test Exception Test flooding or >0.5% probability of sea flooding    Required Required in any year Zone 3b Functional Floodplain: annual probability of Exception Test flooding of 1:20 years (5%) or greater, where     Required flood water flows or is stored

7.1.2 The Sequential and Exception Tests

7.1.2 - 2 The Sequential Test aims to steer all development to areas at the lowest probability of flooding. When land is allocated for development, the Sequential Test should be applied to demonstrate that all other sites reasonably available for development in areas at a lower probability of flooding have been considered first.

7.1.2 - 3 Following the application of the Sequential test, the Exception test may also be required as set out in table 7.1. PPS 25 states “The Exception Test is only appropriate for use when there are large areas in Flood Zones 2 and 3, where the Sequential Test alone cannot deliver acceptable sites, but where some continuing development is necessary for wider sustainable development reasons.”

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7.1.2 - 4 The Exception Test shows:

• if a potential development provides wider sustainability benefits that outweigh the increased flood risk; • the development should be on developable and previously developed land or, if its not on previously developed land, that there are no reasonable alterative sites on developable previously developed land; • that the development does not subsequently increase flood risk; • that, where possible, the development will reduce flood risk; and • most importantly that the development will be safe.

7.1.2 - 5 Police, ambulance and fire stations (which are not required to be operational during flooding), employment use, including shops, financial, professional and other services, restaurants and cafes, hot food takeaways, offices, general industry, storage and distribution, non residential institutions and assembly and leisure, agricultural and forestry land and buildings, waste treatment, minerals working and processing, water treatment works and sewage treatment works are identified within PPS25 as being ‘Less Vulnerable’29. These are therefore permitted in Flood Zones 2 or 3a, following application of the Sequential Test. Residential use is generally classified as ‘More Vulnerable’, unless it consists of caravans, mobile homes or park homes intended for permanent use or includes basement dwellings, in which case it is classified as ‘Highly Vulnerable’. Following application of the Sequential Test, application of the Exception Test is required for More Vulnerable use development in Flood Zone 3a and Highly Vulnerable development in Flood Zone 2.

7.1.3 FRAs

7.1.3 - 6 Site specific flood risk assessments will be required for all developments over 1ha in size in Flood Zone 1 and all development sites (regardless of size) located in Flood Zones 2 and 3. This WCS has provided an overview assessment of the development areas, but this will require review at a smaller site specific scale, with reference to all the sources of information quoted and the guidance provided within PPS25. To assist developers and the Council in procuring FRA’s, Royal Haskoning’s FRA Guidance leaflet is included in Appendix I.

29 See Table D.2 in PPS25 for full classification list.

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7.2 Demand Management

7.2.1 Code for Sustainable Homes

7.2.1 - 1 The full Code for Sustainable Homes practice guide is available online (http://www.planningportal.gov.uk/uploads/code_for_sust_homes.pdf). A home meeting any level of the Code will have to meet minimum standards for certain items depending on what level is desired. This practice guide summarises the code standards and provides practical examples of various levels, with the Level 3 requirements repeated below for reference:

Level 3 Code for Sustainable Homes Requirements

The home will have to be 25% more energy efficient than one built to the 2006 Building Regulations standards. This could be achieved by:

• Improving the thermal efficiency of the walls, windows, and roof as far as is practically possible (by using more insulation or better glass for example); • Reducing air permeability to the minimum consistent with health requirements (a certain amount of air ventilation is needed in a home for health reasons); • Installing a high efficiency condensing boiler; • Carefully designing the fabric of the home to reduce thermal bridging (thermal bridging allows heat to easily escape between the inner walls and the outer walls of a home); • Possibly using district heating systems or low and zero carbon technologies such as solar thermal panels or biomass boilers to help heat the hot water.

The home will have to be designed to use no more than about 105 litres of water per person per day. This could be achieved by fitting a number of items such as: • 6/4 Dual Flush WC; • Flow Reducing/Aerating taps throughout; • 6-9 litres per minute shower (note that an average electric shower is about • 6/7 litres per minute); • a smaller, shaped bath – still long enough to lie down in, but less water required to fill it to a level consistent with personal comfort; • 18ltr maximum volume dishwasher; • 60ltr maximum volume washing machine.

Other minimum requirements are required for: • Surface water management – this may mean the provision of soakaways and areas of porous paving; • Materials – this means a minimum number of materials meeting at least a ‘D’ grade in the Building Research Establishment’s Green Guide (the scale goes from A+ to E); • Waste management – this means having a site waste management plan in place during the home’s construction, and adequate space for waste storage during its use. • Additional elements must be supplied by builder/developer to obtain the required number of points, such as: • Providing drying space (so that tumble dryers need not be used); • Providing more energy efficient lighting (both internally and externally); • Providing cycle storage; • Providing a room that can be easily set up as a home office; • Reducing the amount of water than runs off the site into the storm drains; • Using much more environmentally friendly materials; • Providing recycling capacity either inside or outside the home; • Enhancing the security of the home; • Enhancing the sound insulation used in the home.

7.2.2 Water Efficiency

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7.2.2 - 2 The two main water efficiency schemes promoted within this WCS are greywater recycling and rainwater harvesting. These are discussed in further detail below:

Greywater Recycling

7.2.2 - 3 There are two types of greywater recycling systems. A water diversion system diverts greywater directly to the subsoil in the garden and a water recycling system with purification for the reuse of water in the home. The water for the water recycling system is collected from bath, shower and sink waste. The system then consists of a cleaning tank to remove any solids and then ‘treat’ the water, with the addition of disinfection tablets. This water is then collected in a tank ready for use, but provision must be made to discharge the water if it is stored for too long, as it may become hazardous. The water can then be reused for toilet flushing. More information and guidance regarding greywater recycling can be found in the Environment Agency’s document ‘Greywater: an Information Guide, 2008’30. However, although this technique works well at the community or large development scale, it is not always appropriate for individual properties or small scale developments.

Rainwater Harvesting

7.2.2 - 4 Rainwater harvesting is also a growing sector of water recycling. This is where rainwater from the roof area of the property is collected, and then reused to flush toilets, supply washing machines and outside tap use or, for external use, the collection of rainwater in water butts or rain water tanks (the latter being suitable for all developments including individual properties). Systems that combine the collection of rainwater and the reuse of greywater are also in use. However, it is now understood that this method works well at the community level but not necessarily at the individual property level due to cost and reliability issues. It is therefore most effective when implemented as part of a large-scale development.

7.2.2 - 5 More information regarding rainwater harvesting can be found in the Environment Agency’s document ‘Harvesting Rainwater for Domestic Uses: An information guide, October 2010’31

30 http://publications.environment-agency.gov.uk/pdf/GEHO0408BNWQ-E-E.pdf

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7.3 SUDS

7.3.1 Requirements of PPS25 regarding surface water management

7.3.1 - 1 Urban developments can have a big effect on the quantity and speed of surface water runoff. By replacing vegetated ground with buildings and paved areas the amount of water being absorbed into the ground is severely reduced, therefore increasing the amount of surface water present. This additional surface water increases the demand on drainage systems in built up areas. Traditional drainage systems are designed to get rid of the water as quickly as possible to prevent flooding in the built up area. This can cause problems, particularly downstream, by altering the natural flow patterns of the catchment. In addition, water quality can be affected due to pollutants from the built up areas being washed into the watercourse due to the lack of treatment of the water. One technique which can reduce this problem is the use of Sustainable Drainage Systems (SUDS).

7.3.2 What are SUDS?

7.3.2 - 2 Sustainable Drainage Systems (SUDS) are techniques designed to control surface water runoff before it enters the watercourse. They are designed to mimic natural drainage processes, along with treating the water to reduce the amount of pollutants getting into the watercourse. They can be located as close as possible to where the rainwater falls and provide varying degrees of treatment for the surface water, using the natural processes of sedimentation, filtration, adsorption and biological degradation.

Within the Floods and Water Management Act, 2010. the term “drainage system” refers a structure designed to receive rainwater except:

(a) a public sewer, or (b) a natural watercourse.

References to ‘structures’ include

(a) any part of an existing or proposed structure, and (b) any feature or aspect of a design that is intended to receive or facilitate the receipt of rainwater.

The term “Sustainable drainage” refers to the management of rainwater (including snow and other precipitation) with the aim of:

(a) reducing damage from flooding, (b) improving water quality, (c) protecting and improving the environment, (d) protecting health and safety, and (e) ensuring the stability and durability of drainage systems.

31 http://publications.environment-agency.gov.uk/PDF/GEHO1110BTEN-E-E.pdf

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7.3.3 The Purpose of SUDS

7.3.3 - 3 SUDS are more sustainable than traditional methods because they can: • Manage the speed of the runoff • Protect or enhance the water quality • Reduce the environmental impact of developments • Provide a habitat for wildlife • Encourage natural groundwater recharge.

7.3.3 - 4 In addition, they can be used to create more imaginative and attractive developments and are designed so that less damage is done, than conventional systems, if their capacity is exceeded.

7.3.4 Where are SUDS appropriate?

7.3.4 - 5 Surface water management using SUDS can be implemented at all scales and in most urban settings, ranging from hard-surfaced areas to soft landscaped features, even if there is limited space. Even where infiltration type SUDS are inappropriate due to underlying ground conditions, alternative conveyance, detention or retention types, such as green roofs, permeable surfaces, swales and ponds can still be used.

7.3.5 Requirements of the Flood and Water Management Act 2010

7.3.5 - 6 The Flood and Water Management Act 2010 now requires that all new developments have SUDS incorporated to deal with the surface water run off from the development. These are to be included in the drainage proposal submitted by the developer to the SUDS Approval Board (SAB) located within the Lead Local Authority (in this case, Suffolk County Council). The SAB then has a duty to adopt the approved SUDS scheme if they meet the following criteria:

• Condition 1 – the system is constructed as stated in the approved proposal • Condition 2 – the SAB is satisfied that the drainage system was constructed and functions in accordance with the approved proposal (including any conditions added by the SAB for approval, or the SAB can or have issued a certificate under a non-performance bond • Condition 3 – the drainage system is a sustainable drainage system as defined by the SUDS standards (currently under development).

7.3.5 - 7 The only exceptions to the ‘duty to adopt’ relate to systems, or part of systems, designed to handle surface water from a single property only or systems that are located on a publicly maintained road.

7.3.5 - 8 Further guidance, relating the Floods and Water Management Act is currently being development by CIRIA.

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7.3.6 The different types of measures

7.3.6 - 9 SUDS are made up of one or more structures built to manage surface water runoff, and used in conjunction with good site management. There are five general methods, listed below. These are shown in hierarchical order in terms of the ‘management train’, described in the CIRIA SUDS Manual, 2007 (Prevention  Source Control  Site Control  Regional Control). The techniques that are higher in the hierarchy are preferred to those further down so that prevention and control of water at source should always be considered before, and in association with site or regional controls, such as balancing ponds and wetlands.

i. Prevention – this can involve minimizing paved areas, replacing tarmac with gravel, rainwater recycling, cleaning and sweeping, careful disposal of pollutants, and general maintenance. ii. Filter strips and swales – these are vegetated surface features that drain water evenly off impermeable areas. Swales (figure 1) are long shallow channels whilst filter strips (figure 2) are gently sloping areas of ground. Both of these mimic natural drainage by allowing rainwater to run in sheets through vegetation, slowing and filtering the flow.

                 



     iii. Permeable surfaces and filter drains – these are devices that have a volume of permeable material below ground to store surface water. Runoff can flow to storage areas, the sub soil (via infiltration) or a detention basin. iv. Infiltration devices – these enhance the natural capacity of the ground to store and drain water. They include soakaways, infiltration trenches and infiltration basins. See figure 3. v. Basins and ponds – these are areas for storage of surface runoff e.g. floodplains, wetlands, and flood storage reservoirs. They can be designed to control flows by storing water then releasing it slowly once the risk of flooding has passed. See fig 4.

                 

  

   

     

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7.3.7 SUDS Selection

7.3.7 - 10 SUDS systems should ideally be based upon Sustainable Drainage principles aimed at simulating natural processes and mitigating the impact of polluted surface water runoff upon the environment. Within the design of these systems, appropriate consideration of safe exceedence flows must be made, for example, to account for the predicted impact of climate change and possible blockages. Moreover, full advantage should be made of the opportunities for environmental enhancement posed by the utilisation of these systems. Proposed SUDS schemes should also consider operation and maintenance issues. The system should be robust in design in order to prevent blockages, allow ease of maintenance and reduce long term maintenance costs. Moreover, a suitable maintenance scheme should be proposed although the operation of the system should not be overly reliant upon maintenance being carried out.

7.3.7 - 11 It is essential to consider source control within the surface water drainage proposals; techniques which aim to manage the surface water at or close to the receiving surface should be utilised as widely as possible. For example, paved surfaces (e.g. car parks and access roads) could be of permeable construction allowing water to be stored prior to discharge. Other areas could be drained using a network of grassed swales which would serve to improve the quality of the surface water and reduce the flow rate, whilst directing it to the attenuation area or discharge point. Furthermore, it is recommended that rainwater re-use schemes be utilised, such as, rainwater harvesting for domestic use, such as toilet flushing, as well as the encouragement of the use of water butts and rainwater storage tanks. Further source control techniques would include the installation of green roofs where practical. Incorporation of such measures would serve to greatly reduce the volume of surface water requiring discharge, reduce water demand, and would also further satisfy the Code for Sustainable Homes.

7.3.7 - 12 However, it must be appreciated that any discussions regarding SUDS provision must be commenced early in the development process as it can take a long time decide upon the most appropriate type of SUDS to use on a particular site, how they should be adopted and who is responsible for their maintenance.

7.3.7 - 13 Additional information on the planning, design, construction and operation of SUDS can be found in the CIRIA publication C697, The SUDS Manual, and the associated site handbook C698, both of which can be downloaded from the CIRIA website32.

7.3.7 - 14 As stated within their Groundwater Protection Policy33, the Environment Agency will support the use of sustainable drainage systems for new discharges to ground of surface run-off from roads, vehicle parking and public and amenity areas outside of Source Protection Zone 1 (Inner Zone), provided that an appropriate level of risk assessment demonstrates the groundwater conditions to be suitable. There should also be adequate protective measures for groundwater and arrangements for effective management and maintenance of the system.

32 http://www.ciria.org.uk/suds/publications.htm 33 The Environment Agency’s Groundwater Protection Policy is available on the Environment Agency’s website: http://www.environment-agency.gov.uk/research/library/publications/40741.aspx

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7.3.7 - 15 To determine the applicability of the various SUDS techniques outlined above for a specific site, a number of characteristics for the site in question must first be assessed. This will enable the most appropriate SUDS to be installed. The CIRIA SUDS Manual34, 2007, outlines five criteria which must be addressed when selecting the most suitable SUDS design for a development, consisting of:

• Land use characteristics; • Site characteristics; • Catchment characteristics; • Quantity and quality performance requirements; and • Amenity and environmental requirements.

7.3.7 - 16 The most important criteria from a planning perspective are the site characteristics and these are discussed in more detail below. However, as proven by the SUDS schemes implemented by Royal Haskoning in Cambourne, Cambridgeshire, located on clay, alternative SUDS schemes can be implemented on soils with low or bad permeability through detention and retention techniques, although these will be restricted where groundwater or source protection zones exist. More information can be found within the Environment Agency’s Groundwater Policy and Protection (GP3) document.

7.3.8 Site Characteristics

7.3.8 - 17 The characteristics discussed are based upon the CIRIA SUDS Manual and include the following:

• Soil Type; • Groundwater; • Drainage Area; • Topography; • Hydraulic Head; • Availability of Space; and • Intended Usage (this is considered a separate criteria within the CIRIA SUDS Manual but has been included here as it also important from a planning perspective).

Soil Type

7.3.8 - 18 The permeability of the subsoil beneath a potential development site influences the range of applicable techniques; permeable soils lend themselves to the application of infiltration based SUDS whilst the application of a SUDS system to a site with a soil of low permeability will necessitate the presence of a watercourse in which to discharge attenuated flows. However, in the absence of a watercourse, an agreement could be possible with the surface water regulating authority to discharge attenuated flows into a nearby surface water drain. Within an assessment of the feasibility of SUDS for a development site, it is recommended that an infiltration test be conducted. Table 7.2 provides a rough assessment of the applicability of various SUDS techniques dependent upon soil type, as discussed in Section 3.

34 The SUDS Manual, CIRIA C697, 2007

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Table 7.2 - Applicable SUDS Techniques Based Upon Soil Type

Permeable Impermeable Filter Strips and Swales   Filter drains and Pervious Surfaces  ? Infiltration Devices   Basins, Ponds and Wetlands ?  Green Roofs   Underground Storage   Water Butts  

 Feasible  Not Feasible ? Marginal – needs careful consideration

7.3.8 - 19 Some of the techniques not considered feasible due to the soil type may be mitigated against. For example, basins, ponds and wetlands may be lined to prevent rapid infiltration into highly permeable soils.

Groundwater

7.3.8 - 20 As outlined in the CIRIA Manual, all infiltration devices require at least 1m of soil depth between the base of the device and the maximum expected groundwater level (the seasonal high). This ensures that the system continues to operate during periods of exceptionally wet weather and reduces the risk of groundwater flooding as a result of the SUDS. This is therefore of greatest concern where SUDS are installed on permeable ground, especially those techniques relying upon the passage of water through the soil profile, such as porous pavement or infiltration devices.

7.3.8 - 21 For sites located above areas of high Groundwater Vulnerability (highly vulnerable aquifers), see Figure 8, increased pollutant attenuation measures will need to be employed and straight infiltration systems will not be applicable.

7.3.8 - 22 Figure 9 shows a large number of SPZs located beneath the study area. Depending upon the proposed catchment and estimated surface water runoff pollutant load, the application of SUDS, especially those based upon infiltration, must be done so with care within areas designated as Source Protection Zones (SPZ). SUDS schemes serving these catchments must fully integrate the management train concept and be lined in the upper stages (i.e. where the pollutant load is likely to be at its highest) in order to minimise the potential for pollutant laden surface water to infiltrate the ground. The management train concept describes a set of drainage techniques in series to reduce pollution, flow rates and volumes. However, in addition to consideration of the actual pollutant loading of the surface water to be attenuated, attention must also be given to the ground which the surface water soaks through (i.e. the contaminated status of the site). The Environment Agency will object to enhanced infiltration through contaminated land where not accompanied by an appropriate risk assessment, leachate test, and/or associated soil remedial plan to show it would not cause increased pollution of groundwater. Where regeneration is planned within the urban areas issues surrounding contaminated land will be very important to note and may require further site specific surveys.

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7.3.8 - 23 An overview of the applicability of different SUDS techniques based upon the locations of high vulnerability catchments and SPZs is given in Table 7.3.

Table 7.3 - Applicable SUDS Techniques Based Upon GWV and SPZs

High Water Table High Vulnerability Low Vulnerability SPZ Catchments (<1m) Catchments Catchments Filter Strips and Swales  ?  ? Filter drains and Pervious Surfaces    ? Infiltration Devices     Basins, Ponds and Wetlands  ?  ? Green Roofs     Underground Storage  ?  ? Water Butts    

 Feasible  Not Feasible ? Marginal – needs careful consideration

Drainage Area

7.3.8 - 24 The area of a catchment draining to a particular SUDS scheme is an important consideration as large flows may overwhelm the ability of the SUDS system to treat the runoff. This is especially prominent where vegetation is used as a filter, for example in swales and filter strips. The CIRIA guidance recommends that areas larger than 2ha should not drain to a single SUDS component. However, large scale basins, ponds and wetlands can be utilised in larger sites (> 5ha), although the most effective mechanism will involve the use of other SUDS mechanisms upstream as part of a SUDS management train. This information should be made available by the developer.

7.3.8 - 25 The drainage area of a site in question can be calculated through comparison of the site plans with the topography of the area in order to determine the prominent drainage routes of surface water. This is summarised in Table 7.4.

Table 7.4 - Applicable SUDS Techniques as Single Components, Based Upon Drainage Area

Larger Catchment Smaller Catchments

(>2ha) (<2ha) Filter Strips and Swales   Filter drains and Pervious Surfaces ?  Infiltration Devices   Basins, Ponds and Wetlands   Green Roofs   Underground Storage   Water Butts  

 Feasible  Not Feasible ? Marginal – needs careful consideration

Topography

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7.3.8 - 26 The gradient of the slope in a potential development site is an important consideration for SUDS as many cannot operate, or will require modification to function, on steep slopes due to the limited infiltration time provided. For example filter strips and infiltration practices generally require infiltration times that are only achievable on gentler slopes to fulfil their function, however, swales, for example, can be adapted and located along the contours of a slope. It is also difficult to achieve sufficient volumes in ponds and basins located on steeper slopes and the infiltration of water may result in saturation of the slope further down creating slope instability or the re-emergence of stormwater.

7.3.8 - 27 In addition, many SUDS designs are limited by low site gradients as they require the surface runoff to reach the system with minimal infiltration en route. On completely flat ground it may prove difficult to encourage the surface water to reach the SUDS systems at all. This is discussed further in the following section regarding the hydraulic head and related to compatible SUDS techniques in Table 7.5.

Table 7.5 - Applicable SUDS Techniques Based Upon Topography

Steep Gradient Shallow Gradient

(>5%) (0-5%)

Filter Strips and Swales ?  Filter drains and Pervious Surfaces   Infiltration Devices   Basins, Ponds and Wetlands   Green Roofs   Underground Storage ?  Water Butts  

 Feasible  Not Feasible ? Marginal – needs careful consideration

Hydraulic Head

7.3.8 - 28 As mentioned above, many SUDS schemes require a difference in elevation between the source and the outflow to enable the surface water to reach the required treatment location. The situation in which little, or no, head exists is summarised below. However, where the hydraulic head is low, it can be created artificially through excavation of the site or the installation of embankments, which may enable the use of the techniques identified as ‘not feasible’ below. Information regarding the hydraulic head should be indicated through a site survey or review of LiDAR data on a site specific basis. The applicable SUDS techniques for the various gradients are shown in Table 7.6:

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Table 7.6 - Applicable SUDS Techniques Based Upon Hydraulic Head

0-1m 1-2m Filter Strips and Swales  ? Filter drains and Pervious Surfaces   Infiltration Devices   Basins, Ponds and Wetlands   Green Roofs   Underground Storage   Water Butts  

 Feasible  Not Feasible ? Marginal – needs careful consideration

Availability of Space

7.3.8 - 29 As indicated in the descriptions of the various SUDS techniques, some require more land than others. Inevitably, the area required also increases with the size of the development. In many instances they can be incorporated into the design within open space and playing fields included as part of a development (e.g. as a pond), or areas located within the Flood Zones 2 or 3, which in many cases will not be granted permission for development anyway and can be designed to flood on rare occasions. The applicability of various SUDS techniques based upon the availability of space is summarised in Table 7.7.

Table 7.7 - Applicable SUDS Techniques Based Upon the Availability of Space

High Space Availability Low Space Availability Filter Strips and Swales   Filter drains and Pervious Surfaces   Infiltration Devices  ? Basins, Ponds and Wetlands  ? Green Roofs   Underground Storage   Water Butts  

 Feasible  Not Feasible ? Marginal – needs careful consideration

Intended Usage

7.3.8 - 30 The intended usage of a site should always be considered alongside the site characteristics mentioned above when selecting SUDS features and should be obtained from the developer for all aspects considered in the site. For example, commercial or industrial uses, which are likely to experience increased pollutant loads, would require more robust SUDS features, such as lined ponds and treatment of the collected water, and application of the Treatment Train concept to ensure adequate pollutant removal. In many cases infiltration systems will not be appropriate without remedial measures and most techniques will require the use of liners. Residential uses, however, can commonly be expected to receive lower pollutant input and lower inflow volumes in

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comparison, thus allowing smaller and fewer SUDS features to be used. The eight different classifications (ranging from very low density development to contaminated land) are discussed in more detail within the CIRIA Manual. The main classifications are summarised below.

Table 7.8 - Applicable SUDS Techniques Based Upon the Intended Use of the Land

Contaminated Residential Commercial Brownfield Land Filter Strips and Swales    ? Filter drains and Pervious Surfaces    ? Infiltration Devices    ? Basins, Ponds and Wetlands    ? Green Roofs     Underground Storage    ? Water Butts    

 Feasible  Not Feasible ? Marginal – needs careful consideration

7.3.9 The Adoption of SUDS

7.3.9 - 31 The maintenance of SUDS systems has been subject to a great deal of discussion over the last few years. Following Royal Assent of the Floods and Water Management Act on 8th April 2010, legislation is now in place to implement a standardised process for their adoption and developers are now responsible for the inclusion of SUDS within their designs to accommodate all surface water discharge from the finished site. The water companies are no longer obliged to accept any surface water drainage from new development. Responsibility for adoption and maintenance of the schemes rests with the local approving body (in this case, Suffolk County Council). As such, it is vital that the Council works together with the County Council in reviewing and approving SUDS schemes proposed with all new developments, inline with the SUDS standards currently under development.

7.3.9 - 32 There are already a number of good practice case examples where relevant organisations including local authorities, developers and water companies have developed acceptable adoption solutions for developments or development areas. Defra is currently working with its partners to develop an agreed national adoption system for SUDS. Some options for these are already being tested within the ongoing Defra Integrated Urban drainage pilots. In the meantime it is good practice for the relevant key stakeholders including developers, water companies, Local Council and County Council (Highways) to develop agreed bespoke adoption agreements for development areas to enable whole life management of SUDS. The Construction Industry Research and Information Association (CIRIA) has already published guidance that enable maintenance and adoption agreements to be set-up35.

7.3.9 - 33 Section 106 of the Town and Country Planning Act 1990 allows Planning Authorities to enter into legally binding agreements with the local unitary authority in order to offset the

35 Interim Code of Practice for Sustainable Drainage Systems, July 2004 (http://www.ciria.org/suds/icop.htm)

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cost of the development. This may be in the form of a fee, say as a contribution to a new school, or it could be an agreement, such as a section of the development site is developed as an amenity area and handed to the Local Authority.

7.3.9 - 34 The use of the Section 106 agreement has been considered as a method of collecting a financial contribution from developers in order to fund the future maintenance of SUDS schemes. An alternative method of collection could be through the Water Authorities Infrastructure Charge, which is paid in relation to all new properties.

7.4 Developer Contributions

7.4.1 Introduction

7.4.1 - 1 Please note, due to the ongoing overhaul of the planning policy system the following guidance may be superseded.

7.4.1 - 2 When a local planning authority considers a planning application it should be based on whether it is consistent with the development plan for the area. Where it is not consistent, it is normally refused; however, there are some cases where planning conditions or the use of Planning Obligations will make this acceptable.

7.4.1 - 3 A Planning Obligation is the means for a developer to make a contribution where a development causes an impact that needs to be addressed, so it can mitigate these impacts in order to make a development acceptable.

7.4.1 - 4 There are three basic types of outcomes that can be achieved through using a Planning Obligation; Prescribing, Mitigating and Compensation. A Planning Obligation can prescribe the type of development to be achieved under a planning policy which would otherwise not be acceptable. An example of this is the provision of affordable housing within a housing development. Where a development creates a need for a certain facility, a planning obligation can mitigate for this by providing this facility such as the provision of a new road which is not provided for in the planning application. Planning Obligations can also compensate for the loss or damage that may be caused by a development. For example a public rights of way can be rerouted so that it is not lost.

7.4.1 - 5 Overall, a Planning Obligation will enable a contribution from a developer in some form. Without such a payment, the development would be considered unacceptable in planning terms.

7.4.2 National Policy Framework

7.4.2 - 6 Planning Policy Statement 1 (PPS1) (OPDM, 2005) identifies a number of areas within Paragraph 26 to address when preparing development plans, which relate to Planning Obligations. These are:

(iii) Not impose disproportionate costs, in terms of environmental and social impacts by unnecessarily constraining otherwise beneficial economic or social development.

(iv) Have regard to the resources likely to be available for implementation and the

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costs likely to be incurred, and be realistic about what can be implemented over the period of the plan;

(viii) Recognise that the impact of potential development may adversely affect people who do not benefit directly. Local planning authorities can use planning conditions or obligations to ameliorate such impacts;

7.4.2 - 7 Paragraph 16 also makes reference to ensuring that the “impact of development on the social fabric of communities” is taken account of.

7.4.2 - 8 In terms of more specific guidance on this issue, Planning Policy Statement (PPS25) on Development and Flood risk (CLG, 2010) addresses a number of issues in relation to Developer Contributions and flood risk management in Annex G.

7.4.2 - 9 Where a development requires flood risk management measures, these are normally expected to be provided by the developer, but this will only be acceptable where they:

• conform with the appropriate flood-risk management policies • meet the Sequential and Exception Tests and • do not have a major adverse impact on flood flows or storage

7.4.2 - 10 Although the funding of such works is normally the responsibility of the developer, where works have already been provided to protect existing development, this may provide opportunities for additional development, but it should not add to flood risk elsewhere.

7.4.2 - 11 Where flood risk management measurement works are required they are likely to required under a Section 106 agreement (addressed below), which will cover both the works and their maintenance.

7.4.3 Planning Obligations and Circular 5/05

7.4.3 - 12 The main method to make a financial contribution is by a planning obligation; a type of legal agreement which is permitted by Section 106 of the Town and Country Planning Act 1990 (as amended by section 12 (1) of the Planning and Compensation Act 1991).

7.4.3 - 13 The basis of a Planning Obligation is that it may or may not be subject to conditions, it may make a restriction or requirement for a given or indefinite period of time. Also it may ensure that money should be paid on the basis of a formula or specific amount, paid periodically by a given or indefinite period of time.

7.4.3 - 14 Circular 5/05 therefore supports the use of a formulae and standard charges as part of a framework for negotiating and securing planning obligations. It also supports the used of pooled these contributions:

“Where the combined impact of a number of developments creates the need for infrastructure, it may be reasonable for associated developers’ contributions to be pooled, in order to allow the infrastructure to be secured in a fair and equitable way” (paragraph B21).

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7.4.3 - 15 Research by Sheffield University (Valuing Planning Obligations in England: Update Study for 2005-06) shows that negotiations tend to occur for the larger developments due to the costs and time involved.

Tests for Planning Obligation

7.4.3 - 16 They should only be sought where they meet all of the following tests:

(i) relevant to planning; (ii) necessary to make the potential development acceptable in planning terms; (iii) directly related to the potential development; (iv) fairly and reasonably related in scale and kind to the potential development; and (v) reasonable in all other respects. (ODPM Circular 5/05 ‘Planning Obligations)

Types of Planning Obligation

7.4.3 - 17 There are two types of obligation that can be used, which depend on the depending on the difficulty of the issues involved, a “unilateral undertaking” and a bilateral “Section 106 Agreement”.

7.4.3 - 18 A unilateral undertaking is the more simple form of planning obligation and is only entered into by one party. Generally, they tend to be used where person entering into the undertaking is the landowner, where it only needs to cover straightforward financial contributions and where the local authority’s costs are paid by the landowner. The terms of the agreement are identified by the applicant.

7.4.3 - 19 A Section 106 Agreement” or Planning Agreement is used in more complex and major developments. It involves a legal bilateral agreement between the planning authority and an applicant or developer and sometimes others who have an interest in the land e.g. another local authority.

7.4.3 - 20 Those entering such agreements should not be asked to solve existing problems, but they may be asked to make a contribution towards solving an existing problem if the potential development would make things worse.

7.4.4 Community Infrastructure Levy

7.4.4 - 21 The Community and Infrastructure Levy came into force on 6th April 2010. The purpose of the Community Infrastructure Levy (CIL) is to extend the number of developers that are required to contribute towards infrastructure costs as well as providing more certainty about these costs through a more standardised approach.

Background

7.4.4 - 22 Since 2003 the Government has been looking for a new method to gain some of the increased valve that is achieved when a site is given planning permission and developed for the local community through some form of development charge.

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7.4.4 - 23 The 2004 Planning and Compensation Act made provisions for an “Optional Planning Charge”, but this was never been implemented. This was shortly followed by the Planning-gain Supplement (PGS) which was proposed by the 2004 Barker review of housing supply. However, the 2007 Housing Green Paper outlined the need to consider whether the PGS or other mechanism would raise sufficient funds to provide the infrastructure needed for a development in an equitable way. This was followed by an announcement in the October 2007 Budget that PGS would be deferred and the implementation of the Levy earlier this year.

Setting

7.4.4 - 24 It enables local authorities to apply CIL on new developments within their area to enable the delivery of the necessary new infrastructure; it should not address existing problems in an area.

7.4.4 - 25 The CIL needs to relate to the local development plan and its vision and proposals for development (within the Local Development Framework - LDF) for the area and therefore only those that produce such plans can set this charge, except Minerals and Waste Authorities.

7.4.4 - 26 Panning Policy Statement 12 on Local Spatial Planning identifies that the development plan should be accompanied by a mechanism to identify what the local infrastructure requirements are to deliver the plan (Paras 4.8-4.12). This infrastructure needs to be costed and after other means to fund this are accounted for, the remaining gap will form the basis of what needs to come from CIL and especially how much from each use class of development.

7.4.4 - 27 It is proposed that the means to charge CIL will come from a “charging schedule” which will be a new document within the LDF and therefore subject to public consultation and scrutiny. Although it will not form part of the development plan, it will be tested at a public inquiry and be binding by an independent person, but the local authority does not have to adopt it if there remained issues; this would be resolved through a new examination.

7.4.4 - 28 CIL must be levied in pounds per square metre of the net additional increase in floorspace of any given development. This will ensure that charging CIL does not discourage the redevelopment of sites.

Charging

7.4.4 - 29 The amount owed will be determined when planning consent is given. CIL charges will become due from the date that a chargeable development is commenced in accordance with the terms of the relevant planning permission. The definition of commencement of development for CIL purposes is the same as that used in planning legislation, unless planning permission has been granted after commencement.

7.4.4 - 30 When planning permission is granted, the collecting authority will issue a liability notice setting out the amount of CIL that will be due for payment when the development is commenced, the payment procedure and the possible consequences of not following

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this procedure. The payment procedure encourages someone to assume liability to pay CIL before development commences. Where liability has been assumed, and the Collecting Authority has been notified of commencement, parties liable to pay CIL will benefit from a 60 day window in which they can make payment.

7.4.4 - 31 Where the CIL charge is over £10,000, the liable parties will be able to pay CIL within a series of instalment periods from the commencement date. The number of instalments will vary, depending on the size of the amount due. If the payment procedure is not followed, payment will become due in full.

Spending

7.4.4 - 32 The CIL can only be spent on infrastructure and not for example services for an area. It can be used to fund both local and sub-regional development, which is of benefit to more than one local authority area. This will enable local authorities to work together and bring together their CIL.

7.4.4 - 33 The issue of flood defences is one of a number of different infrastructure requirements identified by the Government as being appropriate for spending CIL on. However, please note that general policy options are aspirational and delivery of the policy may be dependent upon gaining approvals for future defence schemes and the availability of future funding, which may have to be sourced with wholly, or in part, from local sources. There are also other ways the funds could be used, such as for “forward funding” where another body such as a Development Agency pay for some infrastructure and are paid back from the Levy from the benefiting Local Authorities.

7.4.5 The relationship between the CIL and Planning Obligations

7.4.5 - 34 Overall the Government accepts that Planning Obligations are an effective means to address a number of planning-related issues and it will keep it in an amended form, rather than remove it completely, as had been previously proposed. This will enable those local authorities who chose not to operate a CIL in their area, to still use this method, albeit in an amended form.

7.4.6 Regional Policy

7.4.6 - 35 Until 2010, Regional Policy was defined within the East of England Plan and RSS. Following the abolition of the RSS, the new strategy for Babergh District is yet to be redefined.

7.4.7 Further Information

7.4.7 - 36 Further information regarding the CIL can be obtained from the Communities and Local Government (CLG) website: http://www.communities.gov.uk/planningandbuilding/

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7.5 Water Industry Funding

7.5.1 - 1 AWS and the Environment Agency have provided a Water Cycle Framework guidance document for use in this study, which provides a Joint Positions Statement for water industry funding, which states the following:

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Appendix A Figures

  

Appendix B Data Register

APPENDIX B - DATA REGISTER

Data Date Received Source

Core Strategy 7 May 2010 - Draft Core Strategy (April 2010) - Key Options Diagram - Babergh Key Diagram

SFRA Final (PDF) 7 May 2010

SHLAA sites 7 May 2010 - PDF Maps - SHLAA report (2009) - Site Worksheets

Final AMR 2008-09 (PDF) 7 May 2010

Housing Trajectory 2009-21 7 May 2010 Babergh DC

Housing Trajectory 2009-21 plus SHLAA reference 7 May 2010

Trajectory_Shapefiles 1 June 2010

AWS Comments on Core Strategy 1 June 2010

Surface Water Flood Maps 3 June 2010

EA_Flood Maps 3 June 2010

SFRA shapefiles 3 June 2010

Proposed Development Sites 3 June 2010 (8th June 10)

OS Mapping 30 June 2010

SFRA shapefiles 8th June 10

CAMS 5 May 2010

CFMPs 5 May 2010

RBMP 21 May 2010

WFD Standards 24 May 10

LiDAR Catalogue Outline 17 May 10

River Centre Lines 9 June 10 Environment Agency

Flood Zones 9 June 10

Defences 9 June 10

Ground Water Vulnerability and Source Protection Zones 9 June 10

WFD Classifications 11 June 10

Indicative Permit Limits 3 May 11

5 May 2010 FWRMP and Statement of Response 21 May 2010 Sewage Treatment Work Data 24 May 10 AWS WCS Checklist - Oultine and Detailed 21 June 10 Anglian Water Services Wastewater Assetts 5 July 10 Wastewater Catchments 30 July 10 Receiving Watercourses 30 July 10 Water Data

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Data Date Received Source 3 Aug 10 Additional Receiving Watercourse Info 22 March 2011 Updated JR Data

SSSIs 18 Aug 10

RAMSAR 18 Aug 10 Natural England

SACs 18 Aug 10

East of England Plan 2031_Draft 5 May 2010

Haven Gateway Sub Area Profile to 2031 5 May 2010

Housing Statement 2010 - 2014 5 May 2010 Internet Suffolk Flood Plan 5 May 10

RFRA 3 Aug 10

SMP 4 Aug 10

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Appendix C Growth Trajectories

APPENDIX C - GROWTH TRAJECTORIES

GROWTH OPTION 2: RESIDENTIAL (Dwellings)

WwTW WwTW Ref Settlments Total Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 Bentley BENTST Bentley Infill 0000000000000000000000 0 Bildeston BILDST Bildeston; Hitcham 27; Infill 0 722222221112222222211 42 Boxford BOXFST Boxford 27 00222222221112222222211 55 Brantham BRANST Brantham ; Stutton; Tattingstone 27; Infill; Infill 0 552222221112222222211 43 Bures-Wissington Road BUREST Bures 27 001718222221112222222211 66 Chantry CHANST Copdock and Washbrook Infill 0 7 404040400000000000000000 167 Chelmondiston CHEMST Chelmondiston 27 0022222222223333333322 48 Cliff Quay CLQYST 0000000000000000000000 0 Cockfield-Green Lane COCGST Cockfield Infill 0000000000000000000000 0 Cockfield-McKenzie Place COCMST 0000000000000000000000 0 Dedham DEDHST Stratford St Mary Infill 0000000000000000000000 0 East Bergholt EBERST East Bergholt 27 0022222221112222222211 35 Elmsett ELMSST Elmsett Infill 0000000000000000000000 0 Erwarton ERWAST 0000000000000000000000 0 Glemsford GLEMST Glemsford; Hartest 27; Infill 0 92323222221112222222211 104 Great Cornard GCORST Sudbury Area 6 725 0 113 162 177 83 103 57 36 36 36 36 36 67 67 67 66 66 66 66 66 66 66 1538 Great Waldingfield GWLDST Great Waldingfield 27 0032323222221112222222211 125 Great Wenham GWENST Capel St Mary 27 0 13222222221112222222211 68 Groton Castlings Heath GROCST 0000000000000000000000 0 Hadleigh HADLST Hadleigh All 290 0 15 80 59 59 58 15 14 15 14 15 14 28 27 28 26 27 26 27 26 27 26 626 Hintlesham-Wilderness Hill HINTST Hintlesham Infill 0000000000000000000000 0 Holbrook HOLKST Holbrook 27 0022222221112222222211 35 Kersey KERSST Kersey Infill 0000000000000000000000 0 Lavenham LAVHST Lavenham 27 0 722222221112222222211 42 Long Melford LMELST Sudbury Area 5; Acton; Long Melford 725; 27; 27 0 6 4741414141404038383870707070707070707070 1111 Monks Eleigh MONEST Monks Eleigh Infill 0000000000000000000000 0 Nayland NAYLST Nayland; Polstead; Stoke by Nayland 27; Infill; Infill 0022222221112222222211 35 Assington NONE Assington Infill 0000000000000000000000 0 Shimpling SHIMST Lawshall Infill 0000000000000000000000 0 Shotley-Overhall Fm SHOTST Shotley and Shotley Gate 27 0 852821021027252271112222222211 518 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton 265; Infill 0014 29 29 14 14 13 13 13 13 13 24 24 24 24 24 24 24 24 24 24 405 Sudbury SUDBST 0 74 86 95 100 100 100 80 70 70 70 70 0000000000 915 Nedging NEDGST 12 SUB TOTAL 0 264 585 643 538 482 323 259 225 185 186 185 216 215 216 213 214 213 214 213 201 200 5978

GROWTH OPTION 2: EMPLOYMENT (ha)

WwTW WwTW Ref Employment Area Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 B1 0.08 0.08 0.08 0.08 0.31 Brantham BRANST Brantham B2 0.43 0.43 0.43 0.43 1.73 B8 0.45 0.45 0.45 0.45 1.81 B1 0.08 0.06 0.14 Chantry CHANST Wherestead Office Park, Wherstead; Sprties Lane Ipswich B2 0.00 B8 0.00 B1 0.16 0.16 0.16 0.48 Great Cornard GCORST Sudbury Area 6 B2 0.48 0.48 0.48 1.45 B8 0.32 0.32 0.32 0.95 B1 0.30 0.43 0.43 1.15 Hadleigh HADLST Hadleigh Area 1 ; Lady Lane Hadleigh B2 0.70 0.15 0.15 1.00 B8 1.00 0.43 0.43 1.85 B1 0.64 0.64 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13 2.27 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton B2 0.00 0.00 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 2.02 B8 0.33 0.33 1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06 9.15 B1 0.26 0.26 0.26 0.26 0.26 1.32 Long Melford LMELST Chilton Woods, Sudbury B2 0.50 0.50 0.50 0.50 0.50 2.50 B8 0.90 0.90 0.90 0.90 0.90 4.50 SUB TOTAL 000021.7482 1.664 2.6265 2.6265 4.642 2.9225 0 0 1.44 1.44 2.4 2.4 2.4 1.44 1.44 1.44 0 32.63

Babergh WCS 9V9327/R00005/303671/Soli Final Report June 2011 APPENDIX C - GROWTH TRAJECTORIES

GROWTH OPTION 3: RESIDENTIAL (Dwellings)

WwTW WwTW Ref Settlments Total Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 Bentley BENTST Bentley Infill 0000000000000000000000 Bildeston BILDST Bildeston; Hitcham 40; Infill 0 722222222224333333333 58 Boxford BOXFST Boxford 40 00222222222224333333333 71 Brantham BRANST Brantham ; Stutton; Tattingstone 40; Infill; Infill 0 552222222224333333333 59 Bures-Wissington Road BUREST Bures 40 001718222222224333333333 82 Chantry CHANST Copdock and Washbrook Infill 0 7 404040400000000000000000 167 Chelmondiston CHEMST Chelmondiston 40 0022222223335444444444 64 Cliff Quay CLQYST 0000000000000000000000 0 Cockfield-Green Lane COCGST Cockfield Infill 0000000000000000000000 0 Cockfield-McKenzie Place COCMST 0000000000000000000000 0 Dedham DEDHST Stratford St Mary Infill 0000000000000000000000 0 East Bergholt EBERST East Bergholt 40 0022222222224333333333 51 Elmsett ELMSST Elmsett Infill 0000000000000000000000 0 Erwarton ERWAST 0000000000000000000000 0 Glemsford GLEMST Glemsford; Hartest 40; Infill 0 92323222222224333333333 120 Great Cornard GCORST Sudbury Area 6 1068 0 113 179 194 100 120 74 54 54 54 53 53 82 82 82 82 82 82 82 82 81 81 1866 Great Waldingfield GWLDST Great Waldingfield 40 0032323222222224333333333 141 Great Wenham GWENST Capel St Mary 40 0 13222222222224333333333 84 Groton Castlings Heath GROCST 0000000000000000000000 0 Hadleigh HADLST Hadleigh All 427 0 15 87 67 66 66 22 22 22 21 21 21 33 33 33 33 32 32 32 32 32 32 754 Hintlesham-Wilderness Hill HINTST Hintlesham Infill 0000000000000000000000 0 Holbrook HOLKST Holbrook 40 0022222222224333333333 51 Kersey KERSST Kersey Infill 0000000000000000000000 0 Lavenham LAVHST Lavenham 40 0 722222222224333333333 58 Long Melford LMELST Sudbury Area 5; Acton; Long Melford 1068; 40; 40 0 6 6458585858585858575788888888888888888888 1470 Monks Eleigh MONEST Monks Eleigh Infill 0000000000000000000000 0 Nayland NAYLST Nayland; Polstead; Stoke by Nayland 40; Infill; Infill 0022222222224333333333 51 Assington NONE Assington Infill 0000000000000000000000 0 Shimpling SHIMST Lawshall Infill 0000000000000000000000 0 Shotley-Overhall Fm SHOTST Shotley and Shotley Gate 40 0 852821021027252272224333333333 534 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton 392; Infill 0020 35 35 20 20 20 20 20 20 20 31 31 30 30 30 29 29 29 29 29 527 Sudbury SUDBST 0 74 86 95 100 100 100 80 70 70 70 70 0000000000 915 NEDGING-CROWCROFT RD STWNEDGST 0012 0000000000000000000 12 SUB TOTAL 0 264 632 691 585 530 370 310 275 250 248 248 287 274 273 273 272 271 271 271 270 270 7135

GROWTH OPTION 3: EMPLOYMENT (ha)

WwTW WwTW Ref Employment Area Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 B1 0.08 0.08 0.08 0.08 0.31 Brantham BRANST Brantham B2 0.43 0.43 0.43 0.43 1.73 B8 0.45 0.45 0.45 0.45 1.81 B1 0.08 0.06 0.14 Chantry CHANST Wherestead Office Park, Wherstead; Sprties Lane Ipswich B2 0.00 B8 0.00 B1 0.16 0.16 0.16 0.48 Great Cornard GCORST Sudbury Area 6 B2 0.48 0.48 0.48 1.45 B8 0.32 0.32 0.32 0.95 B1 0.30 0.43 0.43 1.15 Hadleigh HADLST Hadleigh Area 1 ; Lady Lane Hadleigh B2 0.70 0.15 0.15 1.00 B8 1.00 0.43 0.43 1.85 B1 0.64 0.64 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13 2.27 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton B2 0.00 0.00 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 2.02 B8 0.33 0.33 1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06 9.15 B1 0.26 0.26 0.26 0.26 0.26 1.32 Long Melford LMELST Chilton Woods, Sudbury B2 0.50 0.50 0.50 0.50 0.50 2.50 B8 0.90 0.90 0.90 0.90 0.90 4.50 SUB TOTAL 000021.7482 1.664 2.6265 2.6265 4.642 2.9225 0 0 1.44 1.44 2.4 2.4 2.4 1.44 1.44 1.44 0 32.63

Babergh WCS 9V9327/R00005/303671/Soli Final Report June 2011 APPENDIX C - GROWTH TRAJECTORIES

GROWTH OPTION 4: RESIDENTIAL (COMBINED WITH RSS 1)

WwTW WwTW Ref Settlments Total Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 Brantham BRANST Brantham ; Stutton; Tattingstone 250; Infill; Infill 0 5 3 0 0 0 0 0 18 18 18 18 19 19 19 19 19 19 19 19 17 17 266 Brantham BRANST Brantham ; Stutton; Tattingstone 700; Infill; Infill 0 5 3 000005050505051515151515151515050 716 Great Cornard GCORST Sudbury Area 6 500 0 113 125 140 46 66 20 0 36 36 36 36 67 67 67 66 66 66 65 65 65 65 1313 Long Melford LMELST Sudbury Area 5; Acton; Long Melford 350;27; 27 0 6 10 444442927272759595959595959595959 736 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton 950; Infill 0 0 0 15 15 0 0 0 68 68 68 68 79 79 79 79 79 79 79 79 78 78 1090

GROWTH OPTION 4: RESIDENTIAL (COMBINED WITH RSS 2)

WwTW WwTW Ref Settlments Total Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 Brantham BRANST Brantham ; Stutton; Tattingstone 250; Infill; Infill 0 5 3 0 0 0 0 0 18 18 18 18 20 19 19 19 19 19 19 19 18 18 269 Brantham BRANST Brantham ; Stutton; Tattingstone 700; Infill; Infill 0 5 3 000005050505052515151515151515151 719 Great Cornard GCORST Sudbury Area 6 500 0 113 125 140 46 66 20 0 36 36 36 36 65 65 65 65 65 65 64 64 63 63 1298 Long Melford LMELST Sudbury Area 5; Acton; Long Melford 350; 40;40 0 6 10 444442929292961616161616161616161 762 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton 950; Infill 0 0 0 15 15 0 0 0 68 68 68 68 79 79 79 79 79 78 78 78 77 77 1085

GROWTH OPTION 4: EMPLOYMENT (SAME FOR BOTH RSS COMBINATIONS)

WwTW WwTW Ref Settlments Total Development 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 TOTAL 2010 - 31 B1 0.08 0.08 0.08 0.08 0.31 Brantham BRANST Brantham B2 0.43 0.43 0.43 0.43 1.73 B8 0.45 0.45 0.45 0.45 1.81 B1 0.16 0.16 0.16 0.48 Great Cornard GCORST Sudbury Area 6 B2 0.48 0.48 0.48 1.45 B8 0.32 0.32 0.32 0.95 B1 0.64 0.64 0.13 0.13 0.13 0.13 0.13 0.13 0.13 0.13 2.27 Sproughton-Church Lane SPRCST Ipswich Area 8; Sproughton B2 0.00 0.00 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 2.02 B8 0.33 0.33 1.06 1.06 1.06 1.06 1.06 1.06 1.06 1.06 9.15 B1 0.26 0.26 0.26 0.26 0.26 1.32 Long Melford LMELST Chilton Woods, Sudbury B2 0.50 0.50 0.50 0.50 0.50 2.50 B8 0.90 0.90 0.90 0.90 0.90 4.50

Babergh WCS 9V9327/R00005/303671/Soli June 2011 June 2011

  

Appendix D RBMP Summary

APPENDIX D - RBMP SUMMARY

Tables D.1 and D.2 below identify the current ecological and physio-chemical / quantitative status of the watercourses and groundwater bodies located within Babergh District and assessed within the RBMP. Red shading indicates poor or bad water quality. Green shading indicates good or very good water quality.

Table E.1 - RBMP Watercourse Status Summary

Watercourse Code Ammonia Phosphorous Dissolved Overall Ecological Status Freshwater Fish Nitrates Urban Oxygen Ecological Status Objective Directive Directive Wastewater Treatment Directive

Stour Estuary R45 Moderate Not Classified Not Classified Moderate Good by 2027 Plus Natura 2000 (Habitats and/or Birds Directive)   Holbrook R 35 High Good Moderate Moderate Good by 2027 Plus Natura 2000 (Habitats and/or Birds Directive)

River Brett R39 High Poor Good Moderate Good by 2027  

   Stutton Brook R113 High Good Moderate Moderate Good by 2027 Plus Natura 2000 (Habitats and/or Birds Directive)    Lower Stour R114 High Poor Good Moderate Good by 2027 Plus Natura 2000 (Habitats and/or Birds Directive)

River Gipping R3 High Moderate Good Poor Good by 2027   

R15 +  River Orwell (tidal) Moderate Not Classified Not Classified Good Good by 2015 R16 Plus Natura 2000 (Habitats and/or Birds Directive) Belstead Brook R20 High Moderate High Poor Good by 2027 

Lavenham Brook R96 High Moderate Moderate Moderate Good by 2027 

River Box R38 High Poor Good Moderate Good by 2027   

Bildeston Brook R27 High Good High Poor Good by 2027     Alton Water L3 High Good Not Classified Moderate Good by 2027 Reservoir Plus Drinking Water Protected Area

Babergh WCS 9V932/R00005/303671/Soli Final Report_v2 July 2011 APPENDIX D - RBMP SUMMARY

Table E.2 - RBMP Groundwater Status Summary

Freshwater Fish Urban Wastewater Watercourse Code Quantitative Status Overall Status Status Objective Nitrates Directive Directive Treatment Directive

 Quantitative: Good by Waveney and East Suffolk G8 Good Poor 2015 Chalk & Crag

Plus Drinking Water Protected Area

 Quantitative: Good by North Essex Chalk G5 Poor Poor 2027

Plus Drinking Water Protected Area

Babergh WCS 9V932/R00005/303671/Soli Final Report_v2 July 2011   

Appendix E WwTW Flow Data

APPENDIX E - WwTW FLOWS

Growth Option 2 - Residential ONLY

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 NONE Assington No WwTW Infill 0 Infill 0 N/A BENTST Bentley 0 Infill 0 Infill 83 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 BILDST Bildeston; Hitcham LIMITED CAPACITY 7 8 27; Infill 0 42 plus infill 310 250 252.793 253.591 254.389 255.187 255.985 256.783 257.581 258.379 258.778 259.177 259.576 260.374 261.172 261.97 262.768 263.566 264.364 265.162 265.96 266.359 266.758 BOXFST Boxford 20 8 27 1 56 420 343 343 343.798 352.975 353.773 354.571 355.369 356.167 356.965 357.364 357.763 358.162 358.96 359.758 360.556 361.354 362.152 362.95 363.748 364.546 364.945 365.344 BRANST Brantham ; Stutton; Tattingstone 8 8 27; Infill; Infill 0 43 plus infill 910 552 553.995 555.99 556.788 557.586 558.384 559.182 559.98 560.778 561.177 561.576 561.975 562.773 563.571 564.369 565.167 565.965 566.763 567.561 568.359 568.758 569.157 BRENST SMALL PACKAGE PLANT 0 0 0 0 N/A BRETST SMALL PACKAGE PLANT 0 0 0 0 N/A BUREST Bures 31 8 27 0 66 250 207 207 213.783 220.965 221.763 222.561 223.359 224.157 224.955 225.354 225.753 226.152 226.95 227.748 228.546 229.344 230.142 230.94 231.738 232.536 232.935 233.334 CHANST Copdock and Washbrook 167 Infill 4 171 plus infill 5200 3402 3404.793 3421.152 3437.511 3453.87 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 CHEMST Chelmondiston LIMITED CAPACITY 13 8 27 0 48 191 129 129 129.798 130.596 131.394 132.192 132.99 133.788 134.586 135.384 136.182 136.98 138.177 139.374 140.571 141.768 142.965 144.162 145.359 146.556 147.354 148.152 CLQYST 0 0 0 34213 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 COCGST Cockfield SMALL PACKAGE PLANT Infill 0 Infill 0 N/A COCMST SMALL PACKAGE PLANT 0 0 0 0 N/A COCWST SMALL PACKAGE PLANT 0 0 0 0 N/A DEDHST Stratford St Mary Infill 0 Infill 610 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 EBERST East Bergholt 8270 35 560 397 397 397.798 398.596 399.394 400.192 400.99 401.788 402.586 402.985 403.384 403.783 404.581 405.379 406.177 406.975 407.773 408.571 409.369 410.167 410.566 410.965 ELMSST Elmsett NO CAPACITY Infill 0 Infill 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 ERWAST SMALL PACKAGE PLANT 0 0 0 0 N/A GLEMST Glemsford; Hartest 69 8 27; Infill 2 106 plus infill 1032 1426 1429.591 1430.389 1443.556 1456.723 1457.521 1458.319 1459.117 1459.915 1460.314 1460.713 1461.112 1461.91 1462.708 1463.506 1464.304 1465.102 1465.9 1466.698 1467.496 1467.895 1468.294 GCORST Sudbury Area 6 510 303 725 75 1613 2450 1524 1571.481 1639.311 1713.525 1748.238 1791.33 1815.27 1830.432 1845.594 1860.756 1875.918 1891.08 1919.01 1946.94 1974.87 2002.401 2029.932 2057.463 2084.994 2112.525 2140.056 2167.587 GWLDST Great Waldingfield 90 8 27 3 128 470 315 315 328.167 341.334 354.501 355.299 356.097 356.895 357.693 358.092 358.491 358.89 359.688 360.486 361.284 362.082 362.88 363.678 364.476 365.274 365.673 366.072 GWENST Capel St Mary LIMITED CAPACITY 33 8 27 0 68 617 345 350.187 358.965 359.763 360.561 361.359 362.157 362.955 363.753 364.152 364.551 364.95 365.748 366.546 367.344 368.142 368.94 369.738 370.536 371.334 371.733 372.132 GROCST SMALL PACKAGE PLANT 0 0 0 0 N/A GROPST SMALL PACKAGE PLANT 0 0 0 0 N/A HADLST Hadleigh All LIMITED CAPACITY 213 123 290 4 630 1700 1486 1491.985 1524.304 1548.244 1572.184 1595.725 1601.71 1607.296 1613.281 1618.867 1624.852 1630.438 1641.61 1652.383 1663.555 1673.929 1684.702 1695.076 1705.849 1716.223 1726.996 1737.37 HINTST Hintlesham Infill 0 Infill 136 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 HOLKST Holbrook NO CAPACITY 8270 35 500 500 500 500.798 501.596 502.394 503.192 503.99 504.788 505.586 505.985 506.384 506.783 507.581 508.379 509.177 509.975 510.773 511.571 512.369 513.167 513.566 513.965 KERSST Kersey SMALL PACKAGE PLANT Infill 0 Infill 0 N/A LAVHST Lavenham 78 270 42 480 232 234.793 235.591 236.389 237.187 237.985 238.783 239.581 240.379 240.778 241.177 241.576 242.374 243.172 243.97 244.768 245.566 246.364 247.162 247.96 248.359 248.758 LINCST SMALL PACKAGE PLANT 0 0 0 0 N/A LINFST SMALL PACKAGE PLANT 0 0 0 0 N/A LMELST Sudbury Area 5; Acton; Long Melford 12 320 725; 27; 27 30 1141 1571 798 800.394 819.546 836.304 853.062 869.82 886.578 902.937 919.296 934.857 950.418 965.979 994.707 1023.435 1052.163 1080.891 1109.619 1138.347 1167.075 1195.803 1224.531 1253.259 MILPST SMALL PACKAGE PLANT 0 0 0 4 N/A MONEST Monks Eleigh Infill 0 Infill 111 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 NAYLST Nayland; Polstead; Stoke by Nayland NO CAPACITY 8 27; Infill; Infill 0 35 plus infill 1038 1038 1038 1038.798 1039.596 1040.394 1041.192 1041.99 1042.788 1043.586 1043.985 1044.384 1044.783 1045.581 1046.379 1047.177 1047.975 1048.773 1049.571 1050.369 1051.167 1051.566 1051.965 NEDGST SMALL PACKAGE PLANT 12 0 0 12 0 N/A NEDTST SMALL PACKAGE PLANT 0 0 0 0 N/A PRESST SMALL PACKAGE PLANT 0 0 0 0 N/A SHIMST Lawshall Infill 0 Infill 260 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 SHOTST Shotley and Shotley Gate 483 8 27 19 537 662 339 342.192 363.738 397.653 439.947 482.241 512.166 533.712 544.884 545.283 545.682 546.081 546.879 547.677 548.475 549.273 550.071 550.869 551.667 552.465 552.864 553.263 SPRCST Ipswich Area 8; Sproughton NO CAPACITY 30 110 265; Infill 54 459 plus infill 418 418 418 424.384 437.551 450.718 457.102 463.486 469.471 475.456 481.441 487.426 493.411 504.184 514.957 525.73 536.503 547.276 558.049 568.822 579.595 590.368 601.141 SUDBST NO CAPACITY 915 0 0 18 933 4902 4902 4932.324 4967.436 5006.139 5046.837 5087.535 5128.233 5160.951 5189.28 5217.609 5245.938 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 THOSST SMALL PACKAGE PLANT 0 0 0 0 N/A THMBST SMALL PACKAGE PLANT 0 0 0 0 N/A THMPST SMALL PACKAGE PLANT 0 0 0 0 N/A WHATST 0 0 0 95 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44

Growth Option 2 - Employment + Residential (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham 0.3072 1.7303 1.8125 3.85 910 552 553.995 555.99 556.788 557.586 558.384 559.182 596.3285 633.475 670.2225 706.97 707.369 708.167 708.965 709.763 710.561 711.359 712.157 712.955 713.753 714.152 714.551 CHANST Wherstead; Sprites Lane 0.1397 0 0 0.1397 5200 3402 3404.793 3421.152 3437.511 3453.87 3476.544 3476.544 3476.544 3476.544 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 GCORST Sudbury Area 6 0.48 1.45 0.95 2.88 2450 1524 1571.481 1639.311 1713.525 1748.238 1791.33 1815.27 1830.432 1845.594 1860.756 1875.918 1891.08 1919.01 1946.94 1974.87 2045.734333 2116.598667 2187.463 2214.994 2242.525 2270.056 2297.587 HADLST Hadleigh Area 1; Lady Lane, Hadleigh LIMITED CAPACITY 1.15 1 1.85 4 1700 1486 1491.985 1524.304 1548.244 1648.184 1671.725 1677.71 1683.296 1689.281 1741.367 1793.852 1799.438 1810.61 1821.383 1832.555 1842.929 1853.702 1864.076 1874.849 1885.223 1895.996 1906.37 LMELST Chilton Woods, Sudbury 1.32 2.5 4.5 8.32 1571 798 800.394 819.546 836.304 853.062 930.62 1008.178 1085.337 1162.496 1238.857 1254.418 1269.979 1298.707 1327.435 1356.163 1384.891 1413.619 1442.347 1471.075 1499.803 1528.531 1557.259 SPRCST Ipswich Area 8, Sproughton NO CAPACITY 2.27 2.02 9.15 13.44 418 418 418 424.384 437.551 450.718 457.102 463.486 469.471 475.456 533.941 592.426 598.411 609.184 659.157 709.13 759.103 809.076 859.049 909.022 958.995 1008.968 1019.741

KEY: Package plant expecting some growth RED TEXT Status Provided by AWS

Water Usage Values Used in Calculations Residential Development 145litres/capita/day 0.145 m³/capita/day B1 750litres/day/100m³ 75 m³/ha developable land/day Industrial Development: B2 550litres/day/100m³= 55 m³/ha developable land/day B8 150litres/day/100m³ 15 m³/ha developable land/day Infiltration 45litres/capita/day 0.045 m³/capita/day Assumed average dwelling occupancy 2.1 People

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX E - WwTW FLOWS

Growth Option 3 - Residential ONLY

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 NONE Assington No WwTW Infill 0 Infill 0 N/A BENTST Bentley 0 Infill 0 Infill 83 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 64 BILDST Bildeston; Hitcham LIMITED CAPACITY 7 11 40; Infill 0 58 plus infill 310 250 252.793 253.591 254.389 255.187 255.985 256.783 257.581 258.379 259.177 259.975 260.773 262.369 263.566 264.763 265.96 267.157 268.354 269.551 270.748 271.945 273.142 BOXFST Boxford 20 11 40 1 72 420 343 343 343.798 352.975 353.773 354.571 355.369 356.167 356.965 357.763 358.561 359.359 360.955 362.152 363.349 364.546 365.743 366.94 368.137 369.334 370.531 371.728 BRANST Brantham ; Stutton; Tattingstone 8 11 40; Infill; Infill 0 59 plus infill 910 552 553.995 555.99 556.788 557.586 558.384 559.182 559.98 560.778 561.576 562.374 563.172 564.768 565.965 567.162 568.359 569.556 570.753 571.95 573.147 574.344 575.541 BRENST SMALL PACKAGE PLANT 0 0 0 N/A BRETST SMALL PACKAGE PLANT 0 0 0 N/A BUREST Bures 31 11 40 0 82 250 207 207 213.783 220.965 221.763 222.561 223.359 224.157 224.955 225.753 226.551 227.349 228.945 230.142 231.339 232.536 233.733 234.93 236.127 237.324 238.521 239.718 CHANST Copdock and Washbrook 167 Infill 4 171 plus infill 5200 3402 3404.793 3421.152 3437.511 3453.87 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 3470.229 CHEMST Chelmondiston LIMITED CAPACITY 13 11 40 0 64 191 129 129 129.798 130.596 131.394 132.192 132.99 133.788 134.586 135.783 136.98 138.177 140.172 141.768 143.364 144.96 146.556 148.152 149.748 151.344 152.94 154.536 CLQYST 0 0 0 34213 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 23370 COCGST Cockfield SMALL PACKAGE PLANT Infill 0 Infill 0 N/A COCMST SMALL PACKAGE PLANT 0 0 0 0 N/A COCWST SMALL PACKAGE PLANT 0 0 0 N/A DEDHST Stratford St Mary Infill 0 Infill 610 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 757 EBERST East Bergholt 11 40 0 51 560 397 397 397.798 398.596 399.394 400.192 400.99 401.788 402.586 403.384 404.182 404.98 406.576 407.773 408.97 410.167 411.364 412.561 413.758 414.955 416.152 417.349 ELMSST Elmsett NO CAPACITY Infill 0 Infill 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 334 ERWAST SMALL PACKAGE PLANT 0 0 0 0 N/A GLEMST Glemsford; Hartest 69 11 40; Infill 2 122 plus infill 1032 1426 1429.591 1430.389 1443.556 1456.723 1457.521 1458.319 1459.117 1459.915 1460.713 1461.511 1462.309 1463.905 1465.102 1466.299 1467.496 1468.693 1469.89 1471.087 1472.284 1473.481 1474.678 GCORST Sudbury Area 6 510 288 1068 95 1961 2450 1524 1571.481 1646.493 1727.889 1769.784 1820.058 1851.18 1873.923 1896.666 1919.409 1941.753 1964.097 1998.411 2032.725 2067.039 2101.353 2135.667 2169.981 2204.295 2238.609 2272.524 2306.439 GWLDST Great Waldingfield 90 11 40 3 144 470 315 315 328.167 341.334 354.501 355.299 356.097 356.895 357.693 358.491 359.289 360.087 361.683 362.88 364.077 365.274 366.471 367.668 368.865 370.062 371.259 372.456 GWENST Capel St Mary LIMITED CAPACITY 33 11 40 0 84 617 345 350.187 358.965 359.763 360.561 361.359 362.157 362.955 363.753 364.551 365.349 366.147 367.743 368.94 370.137 371.334 372.531 373.728 374.925 376.122 377.319 378.516 GROCST SMALL PACKAGE PLANT 0 0 0 0 N/A GROPST SMALL PACKAGE PLANT 0 0 0 N/A HADLST Hadleigh All LIMITED CAPACITY 213 114 427 15 769 1700 1486 1491.985 1527.496 1554.628 1581.361 1608.094 1616.872 1625.65 1634.428 1642.807 1651.186 1659.565 1673.131 1686.697 1700.263 1713.829 1726.996 1740.163 1753.33 1766.497 1779.664 1792.831 HINTST Hintlesham Infill 0 Infill 136 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 60 HOLKST Holbrook NO CAPACITY 11 40 0 51 500 500 500 500.798 501.596 502.394 503.192 503.99 504.788 505.586 506.384 507.182 507.98 509.576 510.773 511.97 513.167 514.364 515.561 516.758 517.955 519.152 520.349 KERSST Kersey SMALL PACKAGE PLANT Infill 0 Infill 0 N/A LAVHST Lavenham 711 400 58 480 232 234.793 235.591 236.389 237.187 237.985 238.783 239.581 240.379 241.177 241.975 242.773 244.369 245.566 246.763 247.96 249.157 250.354 251.551 252.748 253.945 255.142 LINCST SMALL PACKAGE PLANT 0 0 0 N/A LINFST SMALL PACKAGE PLANT 0 0 0 N/A LMELST Sudbury Area 5; Acton; Long Melford 12 310 1068; 40; 40 40 1510 1571 798 800.394 826.728 850.668 874.608 898.548 922.488 946.428 970.368 994.308 1017.849 1041.39 1077.3 1113.21 1149.12 1185.03 1220.94 1256.85 1292.76 1328.67 1364.58 1400.49 MILPST SMALL PACKAGE PLANT 0 0 4 N/A MONEST Monks Eleigh Infill 0 Infill 111 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 NAYLST Nayland; Polstead; Stoke by Nayland NO CAPACITY 11 40; Infill; Infill 0 51 plus infill 1038 1038 1038 1038.798 1039.596 1040.394 1041.192 1041.99 1042.788 1043.586 1044.384 1045.182 1045.98 1047.576 1048.773 1049.97 1051.167 1052.364 1053.561 1054.758 1055.955 1057.152 1058.349 NEDGST SMALL PACKAGE PLANT 12 0 12 0 N/A NEDTST SMALL PACKAGE PLANT 0 0 0 N/A PRESST SMALL PACKAGE PLANT 0 0 0 N/A SHIMST Lawshall Infill 0 Infill 260 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 132 SHOTST Shotley and Shotley Gate 483 11 40 19 553 662 339 342.192 363.738 397.653 439.947 482.241 512.166 533.712 544.884 545.682 546.48 547.278 548.874 550.071 551.268 552.465 553.662 554.859 556.056 557.253 558.45 559.647 SPRCST Ipswich Area 8; Sproughton NO CAPACITY 30 105 392; Infill 74 601 plus infill 418 418 418 427.177 443.137 459.097 468.274 477.451 486.628 495.805 504.982 514.159 523.336 537.301 551.266 564.832 578.398 591.964 605.131 618.298 631.465 644.632 657.799 SUDBST NO CAPACITY 915 0 0 18 933 4902 4902 4932.324 4967.436 5006.139 5046.837 5087.535 5128.233 5160.951 5189.28 5217.609 5245.938 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 5274.267 THOSST SMALL PACKAGE PLANT 0 0 0 N/A THMBST SMALL PACKAGE PLANT 0 0 0 N/A THMPST SMALL PACKAGE PLANT 0 0 0 N/A WHATST 0 0 95 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44

Growth Option 3 - Employment + Residential (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham 0.3072 1.7303 1.8125 3.85 910 552 553.995 555.99 556.788 557.586 558.384 559.182 596.3285 633.475 670.6215 707.768 708.566 710.162 711.359 712.556 713.753 714.95 716.147 717.344 718.541 719.738 720.935 CHANST Wherstead; Sprites Lane 0.1397 0 0 0.1397 5200 3405 3404.793 3421.152 3437.511 3453.87 3476.544 3476.544 3476.544 3476.544 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 3480.7065 GCORST Sudbury Area 6 0.48 1.45 0.95 2.88 2450 1571 1571.481 1646.493 1727.889 1769.784 1820.058 1851.18 1873.923 1896.666 1919.409 1941.753 1964.097 1998.411 2032.725 2067.039 2144.686333 2222.333667 2299.981 2334.295 2368.609 2402.524 2436.439 HADLST Hadleigh Area 1; Lady Lane, Hadleigh NO CAPACITY 1.15 1 1.85 4 1700 1486 1491.985 1527.496 1554.628 1657.361 1684.094 1692.872 1701.65 1710.428 1765.307 1820.186 1828.565 1842.131 1855.697 1869.263 1882.829 1895.996 1909.163 1922.33 1935.497 1948.664 1961.831 LMELST Chilton Woods, Sudbury 1.32 2.5 4.5 8.32 1571 800 800.394 826.728 850.668 874.608 959.348 1044.088 1128.828 1213.568 1298.308 1321.849 1345.39 1381.3 1417.21 1453.12 1489.03 1524.94 1560.85 1596.76 1632.67 1668.58 1704.49 SPRCST Ipswich Area 8, Sproughton NO CAPACITY 2.27 2.02 9.15 13.44 418 418 418 427.177 443.137 459.097 468.274 477.451 486.628 495.805 557.482 619.159 628.336 642.301 695.466 748.232 800.998 853.764 906.131 958.498 1010.865 1063.232 1076.399

KEY: Package plant expecting some growth RED TEXT Status Provided by AWS

Water Usage Values Used in Calculations Residential Development 145litres/capita/day 0.145 m³/capita/day B1 750litres/day/100m³ 75 m³/ha developable land/day Industrial Development: B2 550litres/day/100m³ = 55 m³/ha developable land/day B8 150litres/day/100m³ 15 m³/ha developable land/day Infiltration 45litres/capita/day 0.045 m³/capita/day Assumed average dwelling occupancy 2.1 People

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX E - WwTW FLOWS

Growth Option 4 - ALTERNATIVE GROWTH OPTIONS a) 250 Properties in Brantham (INCREASE ON GROWTH OPTIONS 2 AND 3 ) On top of RSS 1 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 8 8 250; Infill; Infill 250 266 910 552 553.995 555.192 555.192 555.192 555.192 555.192 555.192 562.374 569.556 576.738 583.92 591.501 599.082 606.663 614.244 621.825 629.406 636.987 644.568 651.351 658.134

On top of RSS 1 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 0.3072 1.7303 1.8125 3.85 910 552 553.995 555.192 555.192 555.192 556.455 556.455 613.82 678.367 743.7465 808.2935 815.4755 823.0565 830.6375 838.2185 845.7995 853.3805 860.9615 868.5425 876.1235 882.9065 889.6895

On top of RSS 2 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 8 11 250; Infill; Infill 250 269 910 552 553.995 555.192 555.192 555.192 555.192 555.192 555.192 562.374 569.556 576.738 583.92 591.9 599.481 607.062 614.643 622.224 629.805 637.386 644.967 652.149 659.331

On top of RSS 2 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 0.3072 1.7303 1.8125 3.85 910 552 553.995 555.192 555.192 555.192 556.455 556.455 613.82 678.367 743.7465 808.2935 815.4755 823.4555 831.0365 838.6175 846.1985 853.7795 861.3605 868.9415 876.5225 883.7045 890.8865

b) 700 Properties in Brantham (INCREASE ON GROWTH OPTIONS 2 AND 3 ) On top of RSS 1 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 8 8 700; Infill; Infill 14 730 plus infill 910 552 553.995 555.192 555.192 555.192 555.192 555.192 555.192 575.541 595.89 616.239 636.588 657.336 678.084 698.832 719.58 740.328 761.076 781.824 802.572 822.921 843.27

On top of RSS 1 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 0.3072 1.7303 1.8125 4 910 552 553.995 555.192 555.192 555.192 556.455 556.455 613.82 691.534 770.0805 847.7945 868.1435 888.8915 909.6395 930.3875 951.1355 971.8835 992.6315 1013.3795 1034.1275 1054.4765 1074.8255

On top of RSS 2 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 8 11 700; Infill; Infill 14 733 plus infill 910 552 553.995 555.192 555.192 555.192 555.192 555.192 555.192 575.541 595.89 616.239 636.588 657.735 678.483 699.231 719.979 740.727 761.475 782.223 802.971 823.719 844.467

On top of RSS 2 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 BRANST Brantham ; Stutton; Tattingstone 0.3072 1.7303 1.8125 4 910 552 553.995 555.192 555.192 555.192 556.455 556.455 613.82 691.534 770.0805 847.7945 868.1435 889.2905 910.0385 930.7865 951.5345 972.2825 993.0305 1013.7785 1034.5265 1055.2745 1076.0225

c) 500 Properties in Sudbury Area 6 (DECREASE ON GROWTH OPTIONS 2 AND 3) On top of RSS 1 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 GCORST Sudbury Area 6 510 303 500 63 1376 2450 1524 1571.481 1623.75 1682.403 1701.555 1729.086 1737.465 1737.465 1752.627 1767.789 1782.951 1798.113 1826.043 1853.973 1881.903 1909.434 1936.965 1964.496 1991.628 2018.76 2045.892 2073.024

On top of RSS 1 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 GCORST Sudbury Area 6 0.48 1.45 0.95 2.88 2450 1571 1571.481 1623.75 1682.403 1706.055 1733.586 1741.965 1741.965 1757.127 1778.664 1800.201 1815.363 1843.293 1871.223 1899.153 1980.350667 2061.548333 2142.746 2169.878 2197.01 2224.142 2251.274

On top of RSS 2 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 GCORST Sudbury Area 6 510 288 500 63 1361 2450 1524 1571.481 1623.75 1682.403 1701.555 1729.086 1737.465 1737.465 1752.627 1767.789 1782.951 1798.113 1825.245 1852.377 1879.509 1906.641 1933.773 1960.905 1987.638 2014.371 2040.705 2067.039

On top of RSS 2 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 GCORST Sudbury Area 6 0.48 1.45 0.95 2.88 2450 1571 1571.481 1623.75 1682.403 1706.055 1733.586 1741.965 1741.965 1757.127 1778.664 1800.201 1815.363 1842.495 1869.627 1896.759 1977.557667 2058.356333 2139.155 2165.888 2192.621 2218.955 2245.289

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX E - WwTW FLOWS

d) 350 Properties in Sudbury Area 5 (DECREASE FROM GROWTH OPTIONS 2 AND 3) On top of RSS 1 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 LMELST Sudbury Area 5; Acton; Long Melford 12 320 350;27; 27 24 760 1571 798 800.394 804.384 805.98 807.576 809.172 810.768 812.364 824.334 835.506 846.678 857.85 882.189 906.528 930.867 955.206 979.545 1003.884 1028.223 1052.562 1076.901 1101.24

On top of RSS 1 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 LMELST Sudbury Area 6 1.32 2.5 4.5 8.32 1571 798 800.394 804.384 805.98 807.576 896.172 984.768 1073.364 1172.334 1270.506 1281.678 1292.85 1317.189 1341.528 1365.867 1390.206 1414.545 1438.884 1463.223 1487.562 1511.901 1536.24

On top of RSS 2 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 LMELST Sudbury Area 5; Acton; Long Melford 12 310 350;40; 40 24 776 1571 798 800.394 804.384 805.98 807.576 809.172 810.768 812.364 824.334 836.304 848.274 860.244 884.982 909.72 934.458 959.196 983.934 1008.672 1033.41 1058.148 1082.886 1107.624

On top of RSS 2 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 LMELST Sudbury Area 6 1.32 2.5 4.5 8.32 1571 798 800.394 804.384 805.98 807.576 896.172 984.768 1073.364 1172.334 1271.304 1283.274 1295.244 1319.982 1344.72 1369.458 1394.196 1418.934 1443.672 1468.41 1493.148 1517.886 1542.624

e) 950 Properties in Ipswich Area 8 (INCREASE ON GROWTH OPTIONS 2 AND 3) On top of RSS 1 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 SPRCST Ipswich Area 8; Sproughton NO CAPACITY 30 110 950; Infill 154 1244 418 418 418 418 424.783 431.566 431.566 431.566 431.566 462.688 493.81 524.932 556.054 591.964 627.874 663.784 699.694 735.604 771.514 807.424 843.334 878.845 914.356

On top of RSS 1 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 SPRCST Ipswich Area 8; Sproughton NO CAPACITY 2.27 2.02 9.15 13.44 418 418 418 418 424.783 431.566 435.526 439.486 443.446 478.528 531.485 580.482 611.604 647.514 760.799 874.084 987.369 1100.654 1213.939 1327.224 1440.509 1553.395 1588.906

On top of RSS 2 Windfalls - Residential only

Residential Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Total Predicted in Catchment Consented Current WwTW Potential Growth Locations WwTW Special Status Commitments Windfalls Proposed New Development Holiday PE (dwellings) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 SPRCST Ipswich Area 8; Sproughton NO CAPACITY 30 105 950; Infill 154 1239 418 418 418 418 424.783 431.566 431.566 431.566 431.566 462.688 493.81 524.932 556.054 591.964 627.874 663.784 699.694 735.604 771.115 806.626 842.137 877.249 912.361

On top of RSS 2 Windfalls - Residential and Employment (residential growth as shown above)

Employment Development Dry Weather Flow (DWF) Predicted DWF Over Planning Period (m3/day) Consented Current WwTW Potential Growth Locations WwTW Special Status Type B1 Type B2 Type B8 Total (ha) (For WwTW Calcs) (Average) 2010/11 2011/12 2012/13 2013/14 2014/15 2015/16 2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2026/27 2027/28 2028/29 2029/30 2030/31 SPRCST Ipswich Area 8; Sproughton NO CAPACITY 2.27 2.02 9.15 13.44 418 418 418 418 424.783 431.566 435.526 439.486 443.446 478.528 531.485 580.482 611.604 647.514 760.799 874.084 987.369 1100.654 1213.54 1326.426 1439.312 1551.799 1586.911

Water Usage Values Used in Calculations Residential Development 145litres/capita/day 0.145 m³/capita/day B1 750litres/day/100m³ 75 m³/ha developable land/day Industrial Development: B2 550litres/day/100m³= 55 m³/ha developable land/day B8 150litres/day/100m³ 15 m³/ha developable land/day Infiltration 45litres/capita/day 0.045 m³/capita/day Assumed average dwelling occupancy 2.1 People

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX E - WwTW FLOWS

Maximum Capacity

Maximum Residential Capacity Maximum Employment Capacity (ha) Package Plants Consented with Safety (for Current Headroom on Dwelling Consented WwTW Calcs), (Average) CDWF/Safety Headroom in Dwelling Equivalence Approx Limit for Additional Growth WwTW Potential Growth Locations WwTW Special Status DWF where applicable DWF WwTW Special Status Headroom Dwellings # Dwellings (rounded) B1 B2 B8 Current Total PE 10% of PE Equivalence (Rounded) (ALL REQUIRE CONSULTATION WITH AWS)

NONE Assington No WwTW 0 N/A No WwTW N/A N/A N/A N/A N/A N/A  N/A 0

BENTST Bentley 83 64 19 47.5 48 0.25 0.35 1.27

BILDST Bildeston; Hitcham LIMITED CAPACITY 342 310 250 Limited Capacity 60 150 150 0.80 1.09 4.00

BOXFST Boxford 420 343 77 192.5 193 1.03 1.40 5.13

BRANST Brantham ; Stutton; Tattingstone 910 552 358 895 895 4.77 6.51 23.87

BRENST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  52 5.2 2.476190476 2 2

BRETST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  25 2.5 1.19047619 1 1

BUREST Bures 250 207 43 107.5 108 0.57 0.78 2.87

CHANST Copdock and Washbrook 5200 3402 1798 4495 4495 23.97 32.69 119.87

CHEMST Chelmondiston LIMITED CAPACITY 229 191 129 Limited Capacity 62 155 155 0.83 1.13 4.13

CLQYST 34213 23370 10843 27107.5 27108 144.57 197.15 722.87

COCGST Cockfield SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  176 17.6 8.380952381 8 8

COCMST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  45 4.5 2.142857143 2 2

COCWST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  42 4.2 2 2 2

DEDHST Stratford St Mary 610 757 No Capacity -147 -367.5 0 0.00 0.00 0.00

EBERST East Bergholt 560 397 163 407.5 408 2.17 2.96 10.87

ELMSST Elmsett NO CAPACITY 334 334 No Capacity 0 00 0.00 0.00 0.00

ERWAST SMALL PACKAGE PLANT 0 N/A N/A N/A N/A N/A N/A N/A  25 2.5 1.19047619 1 1

GLEMST Glemsford; Hartest 1032 1426 No Capacity -394 -985 0 0.00 0.00 0.00

GCORST Sudbury Area 6 2450 1524 926 2315 2315 12.35 16.84 61.73

GWLDST Great Waldingfield 470 315 155 387.5 388 2.07 2.82 10.33

GWENST Capel St Mary LIMITED CAPACITY 740 617 345 Limited Capacity 272 680 680 3.63 4.95 18.13 EQUALS: OR OR OR GROCST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  20 2 0.952380952 1 1

GROPST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  20 2 0.952380952 1 1

HADLST Hadleigh All LIMITED CAPACITY 1877 1700 1486 Limited Capacity 391 977.5 978 5.21 7.11 26.07

HINTST Hintlesham 136 60 76 190 190 1.01 1.38 5.07

HOLKST Holbrook NO CAPACITY 500 500 No Capacity 0 00 0.00 0.00 0.00

KERSST Kersey SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  211 21.1 10.04761905 10 10

LAVHST Lavenham 480 232 248 620 620 3.31 4.51 16.53

LINCST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  19 1.9 0.904761905 1 1

LINFST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  23 2.3 1.095238095 1 1

LMELST Sudbury Area 5; Acton; Long Melford 1571 798 773 1932.5 1933 10.31 14.05 51.53

MILPST SMALL PACKAGE PLANT 4 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  29 2.9 1.380952381 1 1

MONEST Monks Eleigh 111 100 11 27.5 28 0.15 0.20 0.73

NAYLST Nayland; Polstead; Stoke by Nayland NO CAPACITY 1038 1038 0 00 0.00 0.00 0.00

NEDGST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  22 2.2 1.047619048 1 1

NEDTST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  113 11.3 5.380952381 5 5

PRESST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  71 7.1 3.380952381 3 3

SHIMST Lawshall 260 132 128 320 320 1.71 2.33 8.53

SHOTST Shotley and Shotley Gate 662 339 323 807.5 808 4.31 5.87 21.53

SPRCST Ipswich Area 8; Sproughton NO CAPACITY 418 418 No Capacity 0 00 0.00 0.00 0.00

SUDBST NO CAPACITY 4902 4902 No Capacity 0 00 0.00 0.00 0.00

THOSST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  81 8.1 3.857142857 4 4

THMBST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  17 1.7 0.80952381 1 1

THMPST SMALL PACKAGE PLANT 0 N/A Small Package Plant N/A N/A N/A N/A N/A N/A  20 2 0.952380952 1 1

WHATST 95 44 51 127.5 128 0.68 0.93 3.40

KEY: Package plant expecting some growth RED TEXT Status Provided by AWS

9V9327/R00005/303671/Soli Babergh WCS July 2011 Final Report

  

Appendix F Indicative Permit Consents

APPENDIX F - INDICATIVE PERMIT LIMITS

WwTW Growth Scenario Dry Limits required to ensure ‘no Limits required to meet ‘Good Status’ Existing Permit Limits Weather deterioration’ under the WFD under the WFD Flow Ammonia BOD SRP Ammonia BOD SRP Ammonia BOD SRP (m³/day) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) 90%ile 90%ile AA 90%ile 90%ile AA 90%ile 90%ile AA

Current (2010) 1032 82 20 12 4 20 0.64 Glemsford 8 20 n/a Predicted (2030/31) 4 14751 82 16 9 3 16 0.4 (Worst Case Scenario = RSS2)

Current (2010) 1571 7 402 19 7 402 14 Long 15 40 n/a Melford Predicted (2030/31) 1 1705 2 2 4 (Worst Case Scenario = RSS2 7 40 18 7 40 1

& Employment)

Current (2010) 4902 7 252 8 7 252 0.54 Sudbury 8 25 2 Predicted (2030/31) (Worst Case Scenario = 52741 2 252 7 2 252 0.44 Existing commitment)

Current (2010) 1038 102 252 1 102 252 3.84 Nayland 10 25 n/a Predicted (2030/31) 10581 102 252 1 102 252 3.74 (Worst Case Scenario = RSS2)

Current (2010) 610 3 152 5 3 152 0.34 Dedham 15 15 n/a Predicted (2030/31) (Worst Case Scenario = RSS1/ 7571 1 152 4 1 152 0.34 RSS2)

Current (2010) 1877 3 102 12 3 102 0.64

Hadleigh 7 10 n/a Predicted (2030/31) (Worst Case Scenario = RSS2 19621 3 102 12 3 102 0.64 & Employment)

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX F - INDICATIVE PERMIT LIMITS

WwTW Growth Scenario Dry Limits required to ensure ‘no Limits required to meet ‘Good Status’ Existing Permit Limits Weather deterioration’ under the WFD under the WFD Flow Ammonia BOD SRP Ammonia BOD SRP Ammonia BOD SRP (m³/day) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l) 90%ile 90%ile AA 90%ile 90%ile AA 90%ile 90%ile AA

Current (2010) 334 3 25 5 3 25 0.34 Elmsett 6 25 n/a Not applicable – no increase in flows proposed. Assessment will be required if Predicted (2030/31) n/a development is identified within the catchment.

Current (2010) 418 252 402 6 252 402 24 Sproughton 25 40 n/a Predicted (2030/31) (Worst Case Scenario = RSS1 15891 13 402 2 13 402 0.74 & Employment)

Current (2010) 910 Not applicable for transitional (tidal) Brantham 12 20 n/a 103 173 n/a receiving waters – potential consideration of Predicted (2030/31) dissolved inorganic nitrogen (Worst Case Scenario = RSS2 10761 & Employment)

NOTES: BOD = Biological Oxygen Demand SRP = Soluble Reactive Phosphorous 1 Based on the worst case flows stated within this WCS. 2 Based on no relaxation of existing permit. 3 Based on no increase in existing permitted load. 4 Calculated assuming ‘good’ upstream quality. This approach is taken to ensure the onus for achieving good status is not purely on a particular discharge or operator. A catchment approach to permitting will be explored when a more sophisticated model of the Stour catchment is completed. This is expected by December 2012.

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011   

Appendix G Constraints Matrix

APPENDIX G - CONSTRAINTS MATRIX

Current Situation

Site # Potential Development Location Development Group Water Resources Water Supply Wastewater Treatment Wastewater Collection Water Quality Flood Risk Demand Management SUDS RESIDENTIAL 1 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich Sufficient No Issues HADLST Limited Headroom No Issues Moderate Metering, Leakage and Efficiency Targets Few Restrictions 2 Hadleigh (west: area 2) Town/Urban Area PZ60 - Ipswich Sufficient No Issues HADLST Limited Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 3 Hadleigh (north area 3) Town/Urban Area PZ60 - Ipswich Sufficient No Issues HADLST Limited Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 4 Sudbury (north area 5) Town/Urban Area PZ62 - Sudbury Sufficient No Issues LMELST Currently ok Historic Issue Moderate Se Metering, Leakage and Efficiency Targets Some Restrictions 5 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury Sufficient No Issues GCORST Currently ok Historic Issue Moderate Se Metering, Leakage and Efficiency Targets Few Restrictions 6 Ipswich Fringe (western area 8) Town/Urban Area PZ60 - Ipswich Sufficient No Issues SPRCST No Headroom No Issues Poor F,T & S Metering, Leakage and Efficiency Targets Few Restrictions 7 Acton Key Service Centre PZ62 - Sudbury Sufficient No Issues LMELST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 8 Bildeston Key Service Centre PZ61 - Semer Sufficient No Issues BILDST Limited Headroom No Issues Poor F & S Metering, Leakage and Efficiency Targets Some Restrictions 9 Boxford Key Service Centre PZ60 - Ipswich Sufficient No Issues BOXFST Minimal Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 10 Brantham Key Service Centre PZ60 - Ipswich Sufficient No Issues BRANST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 11 Bures St Mary Key Service Centre PZ62 - Sudbury Sufficient No Issues BUREST Minimal Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 12 Capel St Mary Key Service Centre PZ60 - Ipswich Sufficient No Issues GWENST Limited Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 13 Chelmondiston Key Service Centre PZ60 - Ipswich Sufficient No Issues CHEMST Limited Headroom No Issues Moderate T Metering, Leakage and Efficiency Targets Few Restrictions 14 East Bergholt Key Service Centre PZ60 - Ipswich Sufficient No Issues EBERST Currently ok No Issues Moderate S, Se Metering, Leakage and Efficiency Targets Few Restrictions 15 Glemsford Key Service Centre PZ48 - Bury St Edmunds Sufficient No Issues GLEMST No Headroom No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 16 Great Waldingfield Key Service Centre PZ62 - Sudbury Sufficient No Issues GLWDST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Few Restrictions 17 Holbrook Key Service Centre PZ60 - Ipswich Sufficient No Issues HOLKST No Headroom No Issues Moderate S Metering, Leakage and Efficiency Targets Few Restrictions 18 Lavenham Key Service Centre PZ48 - Bury St Edmunds Sufficient No Issues LAVHST Currently ok No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 19 Long Melford Key Service Centre PZ62 - Sudbury Sufficient No Issues LMELST Currently ok No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 20 Nayland Key Service Centre PZ60 - Ipswich Sufficient No Issues NAYLST No Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 21 Shotley Key Service Centre PZ60 - Ipswich Sufficient No Issues SHOTST Currently ok No Issues Moderate T Metering, Leakage and Efficiency Targets Few Restrictions 22 Assington Other Villages PZ62 - Sudbury Sufficient No Issues NONE Moderate Metering, Leakage and Efficiency Targets Few Restrictions 23 Bentley Other Villages PZ60 - Ipswich Sufficient No Issues BENTST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Few Restrictions 24 Cockfield Other Villages PZ48 - Bury St Edmunds Sufficient No Issues COCGST Small Package Plant - No Consent No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 25 Copdock and Washbrook Other Villages PZ60 - Ipswich Sufficient No Issues CHANST Currently ok No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 26 Elmsett Other Villages PZ61 - Semer Sufficient No Issues ELMSST No Headroom No Issues Moderate Metering, Leakage and Efficiency Targets Few Restrictions 27 Hartest Other Villages PZ48 - Bury St Edmunds Sufficient No Issues GLEMST No Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 28 Hintlesham Other Villages PZ61 - Semer Sufficient No Issues HINTST Currently ok No Issues Poor Metering, Leakage and Efficiency Targets Some Restrictions 29 Hitcham Other Villages PZ61 - Semer Sufficient No Issues BILDST Limited Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 30 Kersey Other Villages PZ61 - Semer Sufficient No Issues KERSST Small Package Plant - No Consent No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions 31 Lawshall Other Villages PZ48 - Bury St Edmunds Sufficient No Issues SHIMST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 32 Monks Eleigh Other Villages PZ61 - Semer Sufficient No Issues MONEST Minimal Headroom No Issues Moderate F & S Metering, Leakage and Efficiency Targets Some Restrictions 33 Polstead Other Villages PZ60 - Ipswich Sufficient No Issues NAYLST No Headroom No Issues Moderate S Metering, Leakage and Efficiency Targets Some Restrictions 34 Sproughton Other Villages PZ60 - Ipswich Sufficient No Issues SPRCST No Headroom No Issues Moderate T & S Metering, Leakage and Efficiency Targets Some Restrictions 35 Stoke by Nayland Other Villages PZ60 - Ipswich Sufficient No Issues NAYLST No Headroom No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 36 Stratford St Mary Other Villages PZ60 - Ipswich Sufficient No Issues DEDHST No Headroom No Issues Moderate F, S & Se Metering, Leakage and Efficiency Targets Some Restrictions 37 Stutton Other Villages PZ60 - Ipswich Sufficient No Issues BRANST Currently ok No Issues Moderate S Metering, Leakage and Efficiency Targets Few Restrictions 38 Tattingstone Other Villages PZ60 - Ipswich Sufficient No Issues BRANST Currently ok No Issues Moderate F & S Metering, Leakage and Efficiency Targets Few Restrictions EMPLOYMENT 39 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich Sufficient No Issues HADLST Limited Headroom No Issues Moderate Metering, Leakage and Efficiency Targets Few Restrictions 40 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury Sufficient No Issues GCORST Currently ok Historic Issue Moderate Se Metering, Leakage and Efficiency Targets Few Restrictions 41 Ipswich Fringe (western area 8) Town/Urban Area PZ60 - Ipswich Sufficient No Issues SPRCST No Headroom No Issues Poor F,T & S Metering, Leakage and Efficiency Targets Few Restrictions 42 Chilton Woods, Sudbury Town/Urban Area PZ62 - Sudbury Sufficient No Issues LMELST Currently ok Historic Issue Moderate Se Metering, Leakage and Efficiency Targets Some Restrictions 43 Brantham Key Service Centre PZ60 - Ipswich Sufficient No Issues BRANST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 44 Sproughton Other Villages PZ60 - Ipswich Sufficient No Issues SPRCST No Headroom No Issues Poor T & S Metering, Leakage and Efficiency Targets Some Restrictions 45 Lady Lane, Hadleigh Town/Urban Area PZ60 - Ipswich Sufficient No Issues HADLST Limited Headroom No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 46 Wherstead Office Park, Wherstead Other PZ60 - Ipswich Sufficient No Issues CHANST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Some Restrictions 47 Sprites Lane, Ipswich Town/Urban Area PZ60 - Ipswich Sufficient No Issues CHANST Currently ok No Issues Moderate Metering, Leakage and Efficiency Targets Few Restrictions

Key/Notes WRZ09 Water Quality based on Taken from 'Overall Ecological Satus' of Babergh SFRA See Table 3.5 for Derivation Red Major Constraints to Provision of infrastructure and/or treatment to serve proposed growth downstream watercourse, as (see Table 3.4) WRZ10 Amber Infrastructure and/or treatment upgrades required to serve proposed growth provided in RBMP F - Fluvial Green Capacity available to serve the proposed growth S - Surface N/A Outside Anglian Water's boundary of water supply and / or service for sewerage treatment purposes T - Tidal Se - Sewer

Babergh WCS 9V9327/R00002/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Growth Option 2 - Former RSS Targets

Site # Potential Development Location Development Group Water Resources Water Supply Wastewater Treatment Wastewater Collection Water Quality Flood Risk Demand Management SUDS RESIDENTIAL Not constrained by Increased Limited Capacity from 2010, <10% Limited Capacity development but WwTW Dependent on Mitigation On Site Connection 1 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich HADLST capacity from 2012, No Capacity from (site specific investigation should be Phosphate beyond discharge Metering, Leakage and Efficiency Targets Few Restrictions Measures Only 2018 undertaken as sites come forward) economic limit to meet requires further Good Status of WFD modelling FZ3 + CC ; Not constrained by Increased Limited Capacity from 2010, <10% Limited Capacity development but Dependent on Mitigation On Site Connection WwTW 2 Hadleigh (west: area 2) Town/Urban Area PZ60 - Ipswich HADLST capacity from 2012, No Capacity from (site specific investigation should be Phosphate beyond Metering, Leakage and Efficiency Targets Few Restrictions Measures Only discharge 2018 undertaken as sites come forward) economic limit to meet requires further Good Status of WFD modelling FZ3 + CC ; Not constrained by Increased Limited Capacity from 2010, <10% Limited Capacity development but Dependent on Mitigation On Site Connection WwTW 3 Hadleigh (north area 3) Town/Urban Area PZ60 - Ipswich HADLST capacity from 2012, No Capacity from (site specific investigation should be Phosphate beyond Metering, Leakage and Efficiency Targets Some Restrictions Measures Only discharge 2018 undertaken as sites come forward) economic limit to meet requires further Good Status of WFD modelling Not constrained by Severe Restrictions development but On Site Connection Limited Capacity from 2020, <10% 4 Sudbury (north area 5) Town/Urban Area PZ62 - Sudbury Sufficient LMELST (site specific investigation should be Phosphate close to Metering, Leakage and Efficiency Targets Some Restrictions Only Capacity from 2025 undertaken as sites come forward) economic limit to meet Good Status of WFD

Severe Restrictions On Site Connection Limited Capacity from 2023, <10% Not constrained by 5 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury Sufficient GCORST (site specific investigation should be Metering, Leakage and Efficiency Targets Few Restrictions Only Capacity from 2027 development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 6 Ipswich Fringe (western area 8) Town/Urban Area PZ60 - Ipswich SPRCST No Capacity from 2010 (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Not constrained by Limited Capacity development but On Site Connection Limited Capacity from 2020, <10% 7 Acton Key Service Centre PZ62 - Sudbury Sufficient LMELST (site specific investigation should be Phosphate close to Metering, Leakage and Efficiency Targets Some Restrictions Only Capacity from 2025 undertaken as sites come forward) economic limit to meet Good Status of WFD

Limited Capacity On Site Connection Not constrained by 8 Bildeston Key Service Centre PZ61 - Semer Sufficient BILDST Limited Capacity from 2010 (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 9 Boxford Key Service Centre PZ60 - Ipswich BOXFST Limited Capacity from 2010 (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Not constrained by development but Limited Capacity Dependent on Mitigation On Site Connection Phosphate close to 10 Brantham Key Service Centre PZ60 - Ipswich BRANST Currently OK (site specific investigation should be Metering, Leakage and Efficiency Targets Some Restrictions Measures Only economic limit to meet undertaken as sites come forward) No Deterioration Status of WFD

Limited Capacity On Site Connection Limited Capacity from 2010, <10% Not constrained by 11 Bures St Mary Key Service Centre PZ62 - Sudbury Sufficient BUREST (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Only Capacity from 2018 development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 12 Capel St Mary Key Service Centre PZ60 - Ipswich GWENST Limited Capacity from 2010 (site specific investigation should be Partial FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Measures Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 13 Chelmondiston Key Service Centre PZ60 - Ipswich CHEMST Limited Capacity from 2010 (site specific investigation should be Partial FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 14 East Bergholt Key Service Centre PZ60 - Ipswich EBERST Currently OK (site specific investigation should be Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Not constrained by Increased Limited Capacity development but WwTW Dependent on Mitigation On Site Connection 15 Glemsford Key Service Centre PZ48 - Bury St Edmunds GLEMST No Capacity from 2010 (site specific investigation should be Phosphate beyond discharge Metering, Leakage and Efficiency Targets Some Restrictions Measures Only undertaken as sites come forward) economic limit to meet requires further Good Status of WFD modelling

Limited Capacity On Site Connection Not constrained by 16 Great Waldingfield Key Service Centre PZ62 - Sudbury Sufficient GWLDST Currently OK (site specific investigation should be Metering, Leakage and Efficiency Targets Few Restrictions Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection 17 Holbrook Key Service Centre PZ60 - Ipswich HOLKST No Capacity from 2010 (site specific investigation should be Not assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 18 Lavenham Key Service Centre PZ48 - Bury St Edmunds LAVHST Currently OK (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Not constrained by Limited Capacity development but On Site Connection Limited Capacity from 2020, <10% 19 Long Melford Key Service Centre PZ62 - Sudbury Sufficient LMELST (site specific investigation should be Phosphate close to FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Only Capacity from 2025 undertaken as sites come forward) economic limit to meet Good Status of WFD Not constrained by development but Limited Capacity Dependent on Mitigation On Site Connection Phosphate close to 20 Nayland Key Service Centre PZ60 - Ipswich NAYLST No Capacity from 2010 (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Measures Only economic limit to meet undertaken as sites come forward) No Deterioration Status of WFD

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 21 Shotley Key Service Centre PZ60 - Ipswich SHOTST Limited Capacity from 2016 (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

On Site Connection Assessment required on suitability of 22 Assington Other Villages PZ62 - Sudbury Sufficient NONE Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only septic tanks

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 23 Bentley Other Villages PZ60 - Ipswich BENTST Currently OK (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection 24 Cockfield Other Villages PZ48 - Bury St Edmunds COCGST Small Package Plant (site specific investigation should be Small Package Plant Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection 25 Copdock and Washbrook Other Villages PZ60 - Ipswich CHANST Currently OK (site specific investigation should be Small Package Plant Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only undertaken as sites come forward)

Not constrained by Limited Capacity development but On Site Connection 26 Elmsett Other Villages PZ61 - Semer Sufficient ELMSST No Capacity from 2010 (site specific investigation should be Phosphate beyond Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only undertaken as sites come forward) economic limit to meet Good Status of WFD Not constrained by Limited Capacity development but Dependent on Mitigation On Site Connection 27 Hartest Other Villages PZ48 - Bury St Edmunds GLEMST No Capacity from 2010 (site specific investigation should be Phosphate beyond Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only undertaken as sites come forward) economic limit to meet Good Status of WFD

Limited Capacity On Site Connection Not constrained by 28 Hintlesham Other Villages PZ61 - Semer Sufficient HINTST Currently OK (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Only development undertaken as sites come forward)

Limited Capacity On Site Connection Not constrained by 29 Hitcham Other Villages PZ61 - Semer Sufficient BILDST Limited Capacity from 2016 (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only development undertaken as sites come forward)

Limited Capacity On Site Connection Not constrained by 30 Kersey Other Villages PZ61 - Semer Sufficient KERSST Small Package Plant (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 31 Lawshall Other Villages PZ48 - Bury St Edmunds SHIMST Currently OK (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only development undertaken as sites come forward)

Limited Capacity On Site Connection Not constrained by 32 Monks Eleigh Other Villages PZ61 - Semer Sufficient MONEST <10% Capacity from 2010 (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Only development undertaken as sites come forward)

Not constrained by development but Limited Capacity Dependent on Mitigation On Site Connection Phosphate close to 33 Polstead Other Villages PZ60 - Ipswich NAYLST No Capacity from 2010 (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only economic limit to meet undertaken as sites come forward) No Deterioration Status of WFD Increased Limited Capacity WwTW Dependent on Mitigation On Site Connection Not constrained by 34 Sproughton Other Villages PZ60 - Ipswich SPRCST No Capacity from 2010 (site specific investigation should be discharge Metering, Leakage and Efficiency Targets Some Restrictions Measures Only development undertaken as sites come forward) requires further modelling Not constrained by development but Limited Capacity Dependent on Mitigation On Site Connection Phosphate close to 35 Stoke by Nayland Other Villages PZ60 - Ipswich NAYLST No Capacity from 2010 (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only economic limit to meet undertaken as sites come forward) No Deterioration Status of WFD Ammonia levels close Limited Capacity Dependent on Mitigation On Site Connection to economic limit of 36 Stratford St Mary Other Villages PZ60 - Ipswich DEDHST No Capacity from 2010 (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only treatment due to undertaken as sites come forward) growth

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 37 Stutton Other Villages PZ60 - Ipswich BRANST Currently OK (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection Not constrained by 38 Tattingstone Other Villages PZ60 - Ipswich BRANST Currently OK (site specific investigation should be Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only development undertaken as sites come forward)

EMPLOYMENT Hadleigh (east: area 1) Town/Urban Area Not constrained by Increased Limited Capacity from 2010, <10% Limited Capacity development but WwTW On Site Connection 39 PZ60 - Ipswich Sufficient HADLST capacity from 2012, No Capacity from (site specific investigation should be Phosphate beyond discharge Metering, Leakage and Efficiency Targets Few Restrictions Only 2018 undertaken as sites come forward) economic limit to meet requires further Good Status of WFD modelling Sudbury (east area 6) Town/Urban Area Severe Restrictions On Site Connection Limited Capacity from 2023, <10% Not constrained by 40 PZ62 - Sudbury Sufficient GCORST (site specific investigation should be Metering, Leakage and Efficiency Targets Few Restrictions Only Capacity from 2027 development undertaken as sites come forward)

Ipswich Fringe (western area 8) Town/Urban Area Limited Capacity On Site Connection Not constrained by 41 PZ60 - Ipswich Sufficient SPRCST No Capacity from 2010 (site specific investigation should be FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Only development undertaken as sites come forward)

Chilton Woods, Sudbury Town/Urban Area Not constrained by Severe Restrictions development but On Site Connection Limited Capacity from 2020, <10% 42 PZ62 - Sudbury Sufficient LMELST (site specific investigation should be Phosphate close to Metering, Leakage and Efficiency Targets Some Restrictions Only Capacity from 2025 undertaken as sites come forward) economic limit to meet Good Status of WFD

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Brantham Key Service Centre Limited Capacity Not constrained by 43 PZ60 - Ipswich Sufficient No Issues BRANST Currently OK (site specific investigation should be Metering, Leakage and Efficiency Targets Some Restrictions development undertaken as sites come forward)

Sproughton Other Villages Increased Limited Capacity WwTW On Site Connection Not constrained by 44 PZ60 - Ipswich Sufficient SPRCST No Capacity from 2010 (site specific investigation should be discharge Metering, Leakage and Efficiency Targets Some Restrictions Only development undertaken as sites come forward) requires further modelling Lady Lane, Hadleigh Town/Urban Area Not constrained by Increased Limited Capacity from 2010, <10% Limited Capacity development but WwTW On Site Connection 45 PZ60 - Ipswich Sufficient HADLST capacity from 2012, No Capacity from (site specific investigation should be Phosphate beyond discharge Metering, Leakage and Efficiency Targets Some Restrictions Only 2018 undertaken as sites come forward) economic limit to meet requires further Good Status of WFD modelling Wherstead Office Park, Wherstead Other Limited Capacity On Site Connection Not constrained by 46 PZ60 - Ipswich Sufficient CHANST Currently OK (site specific investigation should be Metering, Leakage and Efficiency Targets Some Restrictions Only development undertaken as sites come forward)

Sprites Lane, Ipswich Town/Urban Area Limited Capacity On Site Connection Not constrained by 47 PZ60 - Ipswich Sufficient CHANST Currently OK (site specific investigation should be Metering, Leakage and Efficiency Targets Few Restrictions Only development undertaken as sites come forward)

Key/Notes WRZ09 Taken from Babergh SFRA See Table 3.5 for Derivation Red Major Constraints to Provision of infrastructure and/or treatment to serve proposed growth (see Table 4.15) WRZ10 Amber Infrastructure and/or treatment upgrades required to serve proposed growth F - Fluvial Green Capacity available to serve the proposed growth S - Surface N/A Outside Anglian Water's boundary of water supply and / or service for sewerage treatment purposes T - Tidal

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Growth Option 3 - Draft RSS Review to 2031

Site # Potential Development Location Development GroupWater Resources Water SupplyWastewater Treatment Wastewater Collection Water Quality Flood Risk Demand Management SUDS RESIDENTIAL

Not constrained by Increased Limited Capacity Limited Capacity from 2010, <10% development but WwTW Dependent on Mitigation On Site Connection (site specific investigation 1 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich HADLST capacity from 2011, No Capacity Phosphate beyond discharge Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as from 2016 economic limit to meet requires further sites come forward) Good Status of WFD modelling

FZ3 + CC ; Not constrained by Limited Capacity Increased Limited Capacity from 2010, <10% development but Dependent on Mitigation On Site Connection (site specific investigation WwTW 2 Hadleigh (west: area 2) Town/Urban Area PZ60 - Ipswich HADLST capacity from 2011, No Capacity Phosphate beyond Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as discharge from 2016 economic limit to meet sites come forward) requires further Good Status of WFD modelling FZ3 + CC ; Not constrained by Limited Capacity Increased Limited Capacity from 2010, <10% development but Dependent on Mitigation On Site Connection (site specific investigation WwTW 3 Hadleigh (north area 3) Town/Urban Area PZ60 - Ipswich HADLST capacity from 2011, No Capacity Phosphate beyond Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as discharge from 2016 economic limit to meet sites come forward) requires further Good Status of WFD modelling

Not constrained by Severe Restrictions Limited Capacity from 2018, <10% development but On Site Connection (site specific investigation 4 Sudbury (north area 5) Town/Urban Area PZ62 - Sudbury Sufficient LMELST Capacity from 2022, No Capacity Phosphate close to Metering, Leakage and Efficiency Targets Some Restrictions Only should be undertaken as from 2027 economic limit to meet sites come forward) Good Status of WFD

Severe Restrictions On Site Connection Limited Capacity from 2020, <10% (site specific investigation Not constrained by 5 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury Sufficient GCORST Metering, Leakage and Efficiency Targets Few Restrictions Only Capacity from 2025 should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 6 Ipswich Fringe (western area 8) Town/Urban Area PZ60 - Ipswich SPRCST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Not constrained by Limited Capacity Limited Capacity from 2018, <10% development but On Site Connection (site specific investigation 7 Acton Key Service Centre PZ62 - Sudbury Sufficient LMELST Capacity from 2022, No Capacity Phosphate close to Metering, Leakage and Efficiency Targets Some Restrictions Only should be undertaken as from 2027 economic limit to meet sites come forward) Good Status of WFD

Limited Capacity On Site Connection (site specific investigation Not constrained by 8 Bildeston Key Service Centre PZ61 - Semer Sufficient BILDST Limited Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Only should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 9 Boxford Key Service Centre PZ60 - Ipswich BOXFST Limited Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Not constrained by Limited Capacity development but Dependent on Mitigation On Site Connection (site specific investigation Phosphate close to 10 Brantham Key Service Centre PZ60 - Ipswich BRANST Currently OK Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as economic limit to meet sites come forward) No Deterioration Status of WFD

Limited Capacity On Site Connection Limited Capacity from 2010, <10% (site specific investigation Not constrained by 11 Bures St Mary Key Service Centre PZ62 - Sudbury Sufficient BUREST FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Only Capacity from 2018 should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 12 Capel St Mary Key Service Centre PZ60 - Ipswich GWENST Limited Capacity from 2010 Partial FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 13 Chelmondiston Key Service Centre PZ60 - Ipswich CHEMST Limited Capacity from 2010 Partial FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 14 East Bergholt Key Service Centre PZ60 - Ipswich EBERST Currently OK Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Not constrained by Increased Limited Capacity development but WwTW Dependent on Mitigation On Site Connection (site specific investigation 15 Glemsford Key Service Centre PZ48 - Bury St Edmunds GLEMST No Capacity from 2010 Phosphate beyond discharge Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as economic limit to meet requires further sites come forward) Good Status of WFD modelling

Limited Capacity On Site Connection (site specific investigation Not constrained by 16 Great Waldingfield Key Service Centre PZ62 - Sudbury Sufficient GWLDST Currently OK Metering, Leakage and Efficiency Targets Few Restrictions Only should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation 17 Holbrook Key Service Centre PZ60 - Ipswich HOLKST No Capacity from 2010 Not assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 18 Lavenham Key Service Centre PZ48 - Bury St Edmunds LAVHST Currently OK FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Not constrained by Limited Capacity Limited Capacity from 2018, <10% development but On Site Connection (site specific investigation 19 Long Melford Key Service Centre PZ62 - Sudbury Sufficient LMELST Capacity from 2022, No Capacity Phosphate close to FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Only should be undertaken as from 2027 economic limit to meet sites come forward) Good Status of WFD

Not constrained by Limited Capacity development but Dependent on Mitigation On Site Connection (site specific investigation Phosphate close to 20 Nayland Key Service Centre PZ60 - Ipswich NAYLST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as economic limit to meet sites come forward) No Deterioration Status of WFD

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 21 Shotley Key Service Centre PZ60 - Ipswich SHOTST Limited Capacity from 2016 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

On Site Connection Assessment required on suitability 22 Assington Other Villages PZ62 - Sudbury Sufficient NONE Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only of septic tanks

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 23 Bentley Other Villages PZ60 - Ipswich BENTST Currently OK Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation 24 Cockfield Other Villages PZ48 - Bury St Edmunds COCGST Small Package Plant Small Package Plant Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation 25 Copdock and Washbrook Other Villages PZ60 - Ipswich CHANST Currently OK Small Package Plant Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as sites come forward)

Not constrained by Limited Capacity development but On Site Connection (site specific investigation 26 Elmsett Other Villages PZ61 - Semer Sufficient ELMSST No Capacity from 2010 Phosphate beyond Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only should be undertaken as economic limit to meet sites come forward) Good Status of WFD

Not constrained by Limited Capacity development but Dependent on Mitigation On Site Connection (site specific investigation 27 Hartest Other Villages PZ48 - Bury St Edmunds GLEMST No Capacity from 2010 Phosphate beyond Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as economic limit to meet sites come forward) Good Status of WFD

Limited Capacity On Site Connection (site specific investigation Not constrained by 28 Hintlesham Other Villages PZ61 - Semer Sufficient HINTST Currently OK Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Only should be undertaken as development sites come forward)

Limited Capacity On Site Connection (site specific investigation Not constrained by 29 Hitcham Other Villages PZ61 - Semer Sufficient BILDST Limited Capacity from 2016 Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only should be undertaken as development sites come forward)

Limited Capacity On Site Connection (site specific investigation Not constrained by 30 Kersey Other Villages PZ61 - Semer Sufficient KERSST Small Package Plant Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Only should be undertaken as development sites come forward)

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 31 Lawshall Other Villages PZ48 - Bury St Edmunds SHIMST Currently OK Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as development sites come forward)

Limited Capacity On Site Connection (site specific investigation Not constrained by 32 Monks Eleigh Other Villages PZ61 - Semer Sufficient MONEST <10% Capacity from 2010 Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Only should be undertaken as development sites come forward)

Not constrained by Limited Capacity development but Dependent on Mitigation On Site Connection (site specific investigation Phosphate close to 33 Polstead Other Villages PZ60 - Ipswich NAYLST No Capacity from 2010 Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as economic limit to meet sites come forward) No Deterioration Status of WFD

Increased Limited Capacity WwTW Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 34 Sproughton Other Villages PZ60 - Ipswich SPRCST No Capacity from 2010 discharge Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as development requires further sites come forward) modelling

Not constrained by Limited Capacity development but Dependent on Mitigation On Site Connection (site specific investigation Phosphate close to 35 Stoke by Nayland Other Villages PZ60 - Ipswich NAYLST No Capacity from 2010 Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as economic limit to meet sites come forward) No Deterioration Status of WFD

Limited Capacity Ammonia levels close Dependent on Mitigation On Site Connection (site specific investigation to economic limit of 36 Stratford St Mary Other Villages PZ60 - Ipswich DEDHST No Capacity from 2010 Not Assessed Metering, Leakage and Efficiency Targets Some Restrictions Measures Only should be undertaken as treatment due to sites come forward) growth

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 37 Stutton Other Villages PZ60 - Ipswich BRANST Currently OK Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

Limited Capacity Dependent on Mitigation On Site Connection (site specific investigation Not constrained by 38 Tattingstone Other Villages PZ60 - Ipswich BRANST Currently OK Not Assessed Metering, Leakage and Efficiency Targets Few Restrictions Measures Only should be undertaken as development sites come forward)

EMPLOYMENT Hadleigh (east: area 1) Town/Urban Area Not constrained by Increased Limited Capacity Limited Capacity from 2010, <10% development but WwTW (site specific investigation 39 PZ60 - Ipswich Sufficient No Issues HADLST capacity from 2011, No Capacity Phosphate beyond discharge Metering, Leakage and Efficiency Targets Few Restrictions should be undertaken as from 2016 economic limit to meet requires further sites come forward) Good Status of WFD modelling

Sudbury (east area 6) Town/Urban Area Severe Restrictions Limited Capacity from 2020, <10% (site specific investigation Not constrained by 40 PZ62 - Sudbury Sufficient No Issues GCORST Metering, Leakage and Efficiency Targets Few Restrictions Capacity from 2025 should be undertaken as development sites come forward)

Ipswich Fringe (western area 8) Town/Urban Area Limited Capacity (site specific investigation Not constrained by 41 PZ60 - Ipswich Sufficient No Issues SPRCST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions should be undertaken as development sites come forward)

Chilton Woods, Sudbury Town/Urban Area Not constrained by Severe Restrictions Limited Capacity from 2018, <10% development but (site specific investigation 42 PZ62 - Sudbury Sufficient No Issues LMELST Capacity from 2022, No Capacity Phosphate close to Metering, Leakage and Efficiency Targets Some Restrictions should be undertaken as from 2027 economic limit to meet sites come forward) Good Status of WFD

Brantham Key Service Centre Limited Capacity (site specific investigation Not constrained by 43 PZ60 - Ipswich Sufficient No Issues BRANST Currently OK Metering, Leakage and Efficiency Targets Some Restrictions should be undertaken as development sites come forward)

Sproughton Other Villages Increased Limited Capacity WwTW (site specific investigation Not constrained by 44 PZ60 - Ipswich Sufficient No Issues SPRCST No Capacity from 2010 discharge Metering, Leakage and Efficiency Targets Some Restrictions should be undertaken as development requires further sites come forward) modelling Lady Lane, Hadleigh Town/Urban Area Not constrained by Increased Limited Capacity Limited Capacity from 2010, <10% development but WwTW (site specific investigation 45 PZ60 - Ipswich Sufficient No Issues HADLST capacity from 2011, No Capacity Phosphate beyond discharge Metering, Leakage and Efficiency Targets Some Restrictions should be undertaken as from 2016 economic limit to meet requires further sites come forward) Good Status of WFD modelling

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Wherstead Office Park, Wherstead Other Limited Capacity (site specific investigation Not constrained by 46 PZ60 - Ipswich Sufficient No Issues CHANST Currently OK Metering, Leakage and Efficiency Targets Some Restrictions should be undertaken as development sites come forward)

Sprites Lane, Ipswich Town/Urban Area Limited Capacity (site specific investigation Not constrained by 47 PZ60 - Ipswich Sufficient No Issues CHANST Currently OK Metering, Leakage and Efficiency Targets Few Restrictions should be undertaken as development sites come forward)

Key/Notes WRZ09 Taken from Babergh SFRA See Table 3.5 for Derivation (see Table 4.15) Red Major Constraints to Provision of infrastructure and/or treatment to serve proposed growth WRZ10 Amber Infrastructure and/or treatment upgrades required to serve proposed growth F - Fluvial Green Capacity available to serve the proposed growth S - Surface N/A Outside Anglian Water's boundary of water supply and / or service for sewerage treatment T - Tidal

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Growth Option 4 - Alternative Options

Potential Development Option Development Development GroupWater Resources Water Supply Wastewater Treatment Wastewater Collection Water Quality Flood Risk Demand Management SUDS Location

Limited Capacity 250 Dwellings Brantham Dependent on Mitigation Limited Capacity from 2018, (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 1 - Residential Only) Measures <10% Capacity from 2021 should be undertaken as sites come forward)

Limited Capacity 250 Dwellings Brantham Dependent on Mitigation Limited Capacity from 2018, (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 1 - Residential & Employment) Measures <10% Capacity from 2021 should be undertaken as sites come forward)

Limited Capacity 250 Dwellings Brantham Dependent on Mitigation Limited Capacity from 2018, (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 2 - Residential Only) Measures <10% Capacity from 2021 should be undertaken as sites come forward)

Limited Capacity 250 Dwellings Brantham Dependent on Mitigation Limited Capacity from 2018, (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 2 - Residential & Employment) Measures <10% Capacity from 2021 should be undertaken as sites come forward)

Limited Capacity Limited Capacity from 2018, 700 Dwellings Brantham Dependent on Mitigation (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST <10% Capacity from 2019, Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 1 - Residential Only) Measures should be undertaken as No Capacity from 2022 sites come forward)

Limited Capacity Limited Capacity from 2018, 700 Dwellings Brantham Dependent on Mitigation (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST <10% Capacity from 2019, Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 1 - Residential & Employment) Measures should be undertaken as No Capacity from 2022 sites come forward)

Limited Capacity Limited Capacity from 2018, 700 Dwellings Brantham Dependent on Mitigation (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST <10% Capacity from 2019, Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 2 - Residential Only) Measures should be undertaken as No Capacity from 2022 sites come forward)

Limited Capacity Limited Capacity from 2018, 700 Dwellings Brantham Dependent on Mitigation (site specific investigation Brantham Key Service Centre PZ60 - Ipswich On Site Connection Only BRANST <10% Capacity from 2019, Not constrained by development Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 2 - Residential & Employment) Measures should be undertaken as No Capacity from 2022 sites come forward)

Severe Restrictions 500 Dwellings Sudbury (Area 6) Limited Capacity from 2024, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only GCORST Not constrained by development Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 1 - Residential Only) <10% Capacity from 2029 should be undertaken as sites come forward)

Severe Restrictions 500 Dwellings Sudbury (Area 6) Limited Capacity from 2024, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only GCORST Not constrained by development Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 1 - Residential & Employment) <10% Capacity from 2029 should be undertaken as sites come forward)

Severe Restrictions 500 Dwellings Sudbury (Area 6) Limited Capacity from 2024, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only GCORST Not constrained by development Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 2 - Residential Only) <10% Capacity from 2029 should be undertaken as sites come forward)

Severe Restrictions 500 Dwellings Sudbury (Area 6) Limited Capacity from 2024, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only GCORST Not constrained by development Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 2 - Residential & Employment) <10% Capacity from 2029 should be undertaken as sites come forward)

Severe Restrictions Not constrained by development but 350 Dwellings Sudbury (Area 5) Limited Capacity from 2018, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only LMELST Phosphate close to economic limit to Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 1 - Residential Only) <10% Capacity from 2025 should be undertaken as meet Good Status of WFD sites come forward)

Severe Restrictions Not constrained by development but 350 Dwellings Sudbury (Area 5) Limited Capacity from 2018, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only LMELST Phosphate close to economic limit to Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 1 - Residential & Employment) <10% Capacity from 2025 should be undertaken as meet Good Status of WFD sites come forward)

Severe Restrictions Not constrained by development but 350 Dwellings Sudbury (Area 5) Limited Capacity from 2018, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only LMELST Phosphate close to economic limit to Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 2 - Residential Only) <10% Capacity from 2025 should be undertaken as meet Good Status of WFD sites come forward)

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Severe Restrictions Not constrained by development but 350 Dwellings Sudbury (Area 5) Limited Capacity from 2018, (site specific investigation Sudbury Town/Urban Area PZ62 - Sudbury Sufficient On Site Connection Only LMELST Phosphate close to economic limit to Metering, Leakage and Efficiency Targets Some Restrictions (Combined with RSS 2 - Residential & Employment) <10% Capacity from 2025 should be undertaken as meet Good Status of WFD sites come forward)

Limited Capacity Exceeds economic limit to meet Good 950 Dwellings Ipswich (Area 8) Dependent on Mitigation (site specific investigation Status of WFD as a result of Ipswich Town/Urban Area PZ60 - Ipswich On Site Connection Only SPRCST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 1 - Residential Only) Measures should be undertaken as development. Full development quota sites come forward) cannot be accomodated

Limited Capacity Exceeds economic limit to meet Good 950 Dwellings Ipswich (Area 8) Dependent on Mitigation (site specific investigation Status of WFD as a result of Ipswich Town/Urban Area PZ60 - Ipswich On Site Connection Only SPRCST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 1 - Residential & Employment) Measures should be undertaken as development. Full development quota sites come forward) cannot be accomodated

Limited Capacity Exceeds economic limit to meet Good 950 Dwellings Ipswich (Area 8) Dependent on Mitigation (site specific investigation Status of WFD as a result of Ipswich Town/Urban Area PZ60 - Ipswich On Site Connection Only SPRCST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 2 - Residential Only) Measures should be undertaken as development. Full development quota sites come forward) cannot be accomodated

Limited Capacity Exceeds economic limit to meet Good 950 Dwellings Ipswich (Area 8) Dependent on Mitigation (site specific investigation Status of WFD as a result of Ipswich Town/Urban Area PZ60 - Ipswich On Site Connection Only SPRCST No Capacity from 2010 FZ3 + CC Metering, Leakage and Efficiency Targets Few Restrictions (Combined with RSS 2 - Residential & Employment) Measures should be undertaken as development. Full development quota sites come forward) cannot be accomodated

Key/Notes WRZ09 Taken from Babergh SFRA See Table 3.5 for Derivation (see Table 4.15) Red Major Constraints to Provision of infrastructure and/or treatment to serve proposed g WRZ10 Amber Infrastructure and/or treatment upgrades required to serve proposed growth F - Fluvial Green Capacity available to serve the proposed growth S - Surface N/A Outside Anglian Water's boundary of water supply and / or service for sewerage trea T - Tidal

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Maximum Capacity

Site # Potential Development Location Development Group Water Resources Water Supply Wastewater Treatment Wastewater Collection Water Quality Flood Risk (ha) Demand Management SUDS RESIDENTIAL Regional 2600 dwellings/yr 535 dwellings (but limited capacity stated by > Growth Option 4 1 Hadleigh (east: area 1) Town/Urban Area PZ60 - Ipswich > Growth Option 4 HADLST > Growth Option 4 90.2 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Regional 2600 dwellings/yr 535 dwellings (but limited capacity stated by > Growth Option 4 2 Hadleigh (west: area 2) Town/Urban Area PZ60 - Ipswich > Growth Option 4 HADLST > Growth Option 4 81.5 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Regional 2600 dwellings/yr 535 dwellings (but limited capacity stated by > Growth Option 4 3 Hadleigh (north area 3) Town/Urban Area PZ60 - Ipswich > Growth Option 4 HADLST > Growth Option 4 2.2 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement

Regional 700 dwellings/yr > Growth Option 4 4 Sudbury (north area 5) Town/Urban Area PZ62 - Sudbury > Growth Option 4 LMELST 1933 dwellings > Growth Option 4 151.1 No Maximum No Maximum Currently at abstraction capacity But requires immediate improvement

Regional 700 dwellings/yr > Growth Option 4 5 Sudbury (east area 6) Town/Urban Area PZ62 - Sudbury > Growth Option 4 GCORST 2315 dwellings > Growth Option 4 179.9 No Maximum No Maximum Currently at abstraction capacity But requires immediate improvement

Regional 2600 dwellings/yr > Growth Option 4 6 Ipswich Fringe (western area 8) Town/Urban Area PZ60 - Ipswich > Growth Option 4 SPRCST 0 dwellings 890 dwellings 88.8 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 7 Acton Key Service Centre PZ62 - Sudbury > Growth Option 4 LMELST 1933 dwellings > Growth Option 4 86.3 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr 150 dwellings (but limited capacity stated by > Growth Option 4 8 Bildeston Key Service Centre PZ61 - Semer > Growth Option 4 BILDST > Growth Option 4 74.7 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 9 Boxford Key Service Centre PZ60 - Ipswich > Growth Option 4 BOXFST 193 dwellings (within 20% of CDWF) > Growth Option 4 108.2 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 10 Brantham Key Service Centre PZ60 - Ipswich > Growth Option 4 BRANST 895 dwellings > Growth Option 4 112.4 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 11 Bures St Mary Key Service Centre PZ62 - Sudbury > Growth Option 4 BUREST 108 dwellings (within 20% of CDWF) > Growth Option 4 107.2 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr 680 dwellings (but limited capacity stated by > Growth Option 4 12 Capel St Mary Key Service Centre PZ60 - Ipswich > Growth Option 4 GWENST > Growth Option 4 191.8 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Regional 2600 dwellings/yr 15 dwellings (but limited capacity stated by > Growth Option 4 13 Chelmondiston Key Service Centre PZ60 - Ipswich > Growth Option 4 CHEMST > Growth Option 4 123.1 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 14 East Bergholt Key Service Centre PZ60 - Ipswich > Growth Option 4 EBERST 408 dwellings > Growth Option 4 118.6 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 15 Glemsford Key Service Centre PZ48 - Bury St Edmunds > Growth Option 4 GLEMST 0 dwellings > Growth Option 4 143.4 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 16 Great Waldingfield Key Service Centre PZ62 - Sudbury > Growth Option 4 GLWDST 388 dwellings > Growth Option 4 78.3 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 17 Holbrook Key Service Centre PZ60 - Ipswich > Growth Option 4 HOLKST 0 dwellings > Growth Option 4 194.2 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 18 Lavenham Key Service Centre PZ48 - Bury St Edmunds > Growth Option 4 LAVHST 620 dwellings > Growth Option 4 110 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 19 Long Melford Key Service Centre PZ62 - Sudbury > Growth Option 4 LMELST 1933 dwellings > Growth Option 4 117.9 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 20 Nayland Key Service Centre PZ60 - Ipswich > Growth Option 4 NAYLST 0 dwellings 51 dwellings 42.3 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 21 Shotley Key Service Centre PZ60 - Ipswich > Growth Option 4 SHOTST 808 dwellings > Growth Option 4 319.7 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr 22 Assington Other Villages PZ62 - Sudbury > Growth Option 4 NONE Not Assessed No Maximum No Maximum Currently at abstraction capacity Regional 2600 dwellings/yr > Growth Option 4 23 Bentley Other Villages PZ60 - Ipswich > Growth Option 4 BENTST 48 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 24 Cockfield Other Villages PZ48 - Bury St Edmunds > Growth Option 4 COCGST Small Package Plant - Assume 18 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 25 Copdock and Washbrook Other Villages PZ60 - Ipswich > Growth Option 4 CHANST 4495 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 26 Elmsett Other Villages PZ61 - Semer > Growth Option 4 ELMSST 0 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 27 Hartest Other Villages PZ48 - Bury St Edmunds > Growth Option 4 GLEMST 0 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 28 Hintlesham Other Villages PZ61 - Semer > Growth Option 4 HINTST 190 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr 150 dwellings (but limited capacity stated by > Growth Option 4 29 Hitcham Other Villages PZ61 - Semer > Growth Option 4 BILDST > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 30 Kersey Other Villages PZ61 - Semer > Growth Option 4 KERSST Small Package Plant - Assume 20 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 700 dwellings/yr > Growth Option 4 31 Lawshall Other Villages PZ48 - Bury St Edmunds > Growth Option 4 SHIMST 320 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 32 Monks Eleigh Other Villages PZ61 - Semer > Growth Option 4 MONEST 28 dwellings (within 20% of CDWF) > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 33 Polstead Other Villages PZ60 - Ipswich > Growth Option 4 NAYLST 0 dwellings 51 dwellings Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 34 Sproughton Other Villages PZ60 - Ipswich > Growth Option 4 SPRCST 0 dwellings 890 dwellings Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 35 Stoke by Nayland Other Villages PZ60 - Ipswich > Growth Option 4 NAYLST 0 dwellings 51 dwellings Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 36 Stratford St Mary Other Villages PZ60 - Ipswich > Growth Option 4 DEDHST 0 dwellings Infill Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 37 Stutton Other Villages PZ60 - Ipswich > Growth Option 4 BRANST 895 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement Regional 2600 dwellings/yr > Growth Option 4 38 Tattingstone Other Villages PZ60 - Ipswich > Growth Option 4 BRANST 895 dwellings > Growth Option 4 Not Assessed No Maximum No Maximum Currently at abstraction capacity But requires some improvement EMPLOYMENT Hadleigh (east: area 1) Town/Urban Area Regional 2600 dwellings/yr 535 dwellings (but limited capacity stated by > Growth Option 4 39 PZ60 - Ipswich > Growth Option 4 HADLST > Growth Option 4 90.2 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Sudbury (east area 6) Town/Urban Area Regional 2600 dwellings/yr > Growth Option 4 40 PZ62 - Sudbury > Growth Option 4 GCORST 2315 dwellings > Growth Option 4 179.9 No Maximum No Maximum Currently at abstraction capacity But requires immediate improvement

Ipswich Fringe (western area 8) Town/Urban Area Regional 2600 dwellings/yr > Growth Option 4 41 PZ60 - Ipswich > Growth Option 4 SPRCST 0 dwellings 890 dwellings 88.8 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Chilton Woods, Sudbury Town/Urban Area Regional 2600 dwellings/yr > Growth Option 4 42 PZ62 - Sudbury > Growth Option 4 LMELST 1933 dwellings > Growth Option 4 64.7 No Maximum No Maximum Currently at abstraction capacity But requires immediate improvement

Brantham Key Service Centre Regional 2600 dwellings/yr > Growth Option 4 43 PZ60 - Ipswich > Growth Option 4 BRANST 895 dwellings > Growth Option 4 112.4 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Sproughton Other Villages Regional 2600 dwellings/yr > Growth Option 4 44 PZ60 - Ipswich > Growth Option 4 SPRCST 0 dwellings 890 dwellings 38.9 No Maximum No Maximum Currently at abstraction capacity But requires some improvement

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011 APPENDIX G - CONSTRAINTS MATRIX

Lady Lane, Hadleigh Town/Urban Area Regional 2600 dwellings/yr 535 dwellings (but limited capacity stated by > Growth Option 4 45 PZ60 - Ipswich > Growth Option 4 HADLST > Growth Option 4 18 No Maximum No Maximum Currently at abstraction capacity AWS) But requires some improvement Wherstead Office Park, Wherstead Other Regional 2600 dwellings/yr > Growth Option 4 46 PZ60 - Ipswich > Growth Option 4 CHANST 4495 dwellings > Growth Option 4 35.1 No Maximum No Maximum Currently at abstraction capacity But requires some improvement Sprites Lane, Ipswich Town/Urban Area Regional 2600 dwellings/yr > Growth Option 4 47 PZ60 - Ipswich > Growth Option 4 CHANST 4495 dwellings > Growth Option 4 1.4 No Maximum No Maximum Currently at abstraction capacity But requires some improvement

Key/Notes WRZ09 Red Major Constraints to Provision of infrastructure and/or treatment to serve proposed growth F - Fluvial See Table 3.5 for Derivation WRZ10 Amber Infrastructure and/or treatment upgrades required to serve proposed growth S - Surface Green Capacity available to serve the proposed growth T - Tidal N/A Outside Anglian Water's boundary of water supply and / or service for sewerage treatment purposes

Babergh WCS 9V9327/R00005/303671/Soli Final Report July 2011   

Appendix H FRA Guidance Leaflet

Royal Haskoning is an international firm of consulting engineers and environmental scientists, our Coastal and Rivers division has 150 staff working across Flood Risk Assessment (FRA) the UK. Our consulting services focus on a broad field of interaction between people and the environment. We believe in working closely with our clients to assessing and managing risks build strong relationships that help address their needs as well as those of the public and the environment. We undertake a wide range of high profile, tech- nically demanding projects and have developed a reputation for technical excellence, innovation and project delivery.

1. Identify the flood risk 2. What level of FRA do you need? The first stage of any FRA is to establish the floodzone or zones the development site is in. The main sources for this information are given below: The location of the development site, notably in which floodzone the site is located, and the type of development to  Environment Agency Flood Online Map (http://www.environment-agency.gov.uk/homeandleisure/default.aspx ) be constructed will determine the level of FRA required with your planning permission application. There are a num-  Strategic Flood Risk Assessments (SFRAs), these can be obtained from the local authority or County Council. ber of important question that you need to ask:  Local Development Documents (LDDs), these can be obtained from the local planning authority. A  Area Action Plans (AAPs), these can be obtained from the local authority or County Council. 1. Which floodzone is the site in? 2. What is the size of the development? A With the knowledge of which floodzone or zones the development site is located in you can move onto step 2. 3. What is the vulnerability of the development?

Example Project With the answers to these questions, the table on the Environment The Bromsgrove and Redditch SFRA included a review of all sources of flooding and the potential impact of climate change across the study area, enabling the Agency’s website can help identify what information needs to support the planning applica- application of the Sequential Test, as set out in PPS25. It has also identified areas in which the Exception Test is required for future development to take place. tion (http://www.environment-agency.gov.uk/research/planning/93498.aspx). From projects carried out for local authorities like the Bromsgrove and Redditch SFRA we have detailed knowledge of the flood risk within the districts. In general terms if the site is less than 1 Ha and in floodzone 1 then a flood map showing the location of the site in 5. EA Decision relation to the flood zones is required but no FRA. Otherwise, if a development site is less than 1 Ha in area then flood The scope of the FRA should be agreed with the Local Planning Authority (LPA) in consultation with the Environment Agency, along with any risk to the site should be considered in an FRA and if the development site is greater than 1 Ha in area then an FRA is other relevant parties. The EA provide guidance documents that aim to highlight what needs to be in an FRA. These can be found at (http:// required regardless of which floodzone it is located within and it must identify flood risk both to and from the site. www.environment-agency.gov.uk/research/planning/93498.aspx). Below is a checklist that will help make sure everything is covered in the FRA: 3. Developing the FRA  Plans - a location plan and a plan of the site identifying existing, development proposals and should identify any structures The first stage of the FRA is to collect all the relevant data from the Environment Agency.  Surveys - referenced to Ordnance Datum and showing both existing and proposed levels. 1.  Assessments - including surface water management and disposal, volume of surface water runoff generated, allowance for climate  Historic flood record, this can change, information on all sources of flooding, and identify if EA consent is required. be in the form of residents 2 . surveys from local authorities Early consultation of all the relevant parties will help with obtaining all the necessary background information and will or the EA. . help with not only obtaining approval but will also improve the turnaround time for the decision. 5  Water levels and flows, these may be from previous model Example results if no new modelling is As part of the FRA for a large private development Royal Haskoning undertook hydraulic modelling to identify the to be undertaken or from current flood risk at the site and potential flood risk after development. Liaison with the Environment Agency formed a key part of the planning 4 . gauge records of nearby gauges. application process. The EA’s basic requirements were for compensatory flood plain storage as follows: . 3  Flood defence information, this might be from  A volume of flood plain equal to that lost to the proposed development must be created; the NFCDD (National Flood and Coastal Defence Database), Asset registers from  The equal volume must apply at all levels between the lowest point on the site and the design flood level. the Asset Systems Management team at the EA.  Details of the drainage system, this information would be obtained from the local 4. Adapting the design water company and the local Internal Drainage Board (IDB) if there is one. If the FRA initially shows unacceptable flood risk to the site, there are some questions that can be addressed towards helping get the approval to build:  Topographic data of the site, this might be from LiDAR data or from topographic ground surveys.  Is the layout/landuse of the site best suited to the floodzones present? For example can any highly vulnerable be moved to a part of the site that is in floodzone 1? Or  Details of the proposed development, in the form of drawings and plans, including can a public open space be located near the river/watercourse with built development further away? any proposed changes to defences, structures or watercourses.  Is there the possibility of including the construction/improvement of defences within the development proposal?  Have SUDS techniques been included in the development proposal? Can the surface water from the site be managed on site through these techniques? Example  Has providing flood warning been considered? We were commissioned to carry out modelling as part of an FRA for a 6th Form College in  Are the access and egress points to and from site located sensibly? Can they be relocated? Rochdale . The aim was to confirm the 100 year plus climate change flood level to inform the design of a new bridge at the 6th Form College. The modelling consisted of adapting Example Project a 1D ISIS model provided by the EA and including an area of 2D TUFLOW modelling The Holland Park development, on the outskirts of Spalding, is an example of adjusting the layout of the site to maximise the management of surface water and flood around the college and city centre. The hydrology was adapted from the previous model. risk protection. The boundary of the site that was bordered by the IDB drain was designated as a country park that contained a number of semi-permanent and permanent wetland basins The ISIS model was adapted to incorporate the proposed changes to the college buildings and ponds. These areas would not only act as storage of surface water from the site but as a defence should the IDB drain ever overtop its banks. SUDS were included in the drainage pro- and simulate new bridge access to the car park. The TUFLOW modelling uses filtered posal to show that the increased runoff from the site post development could be managed down to the pre-development greenfield runoff rate to ensure that the flood risk downstream on LiDAR data to simulate the floodplain at a grid size of 5 metres. The outputs of the model the IDB drainage system was not increased. were flood outlines, maximum flood depth and velocity and a hazard rating for the site.

Contact Our Experts: Tel: 0121 709 6520 Email: [email protected] www.royalhaskoning.co.uk Royal Haskoning Solihull Office 5th Floor, Radcliffe House Project Director Technical Director River Scientist Coastal Scientist Hydraulic Modeller Hydrologist Mike Stringer David Worth Rachel Ranger Nick Lewis Siripen Songprasit James Stickler Blenheim Court, Solihull West Midlands, B91 2AA Policy Reviewer United Kingdom Fola Ogunyoye Senior Engineer River Scientist Coastal Scientist Hydraulic Modeller GIS Technician Matt Balkham Laura Sanderson Victoria Clipsham Latha Yellampalli Jonathan Sortwell