Waste Issues and Options

Dear Sir/Madam
Nottingham and Nottinghamshire Local Waste Plan

Thank you for the opportunity to comment on your consultation, on the issues and options stage of the Nottingham and Nottinghamshire Local Waste Plan. We do not generally have any comments on, but there are a few sections that we would like to highlight specific issues with.

Q13: Are the above objectives appropriate? Are there others we should consider?
We believe that the plan for the environment could be more ambitious. Objective 3 is loosely defined around protecting the environment. More importantly, there should be a commitment to work with other stakeholders, including Severn Trent Water, to ensure that there is not deterioration against Water Framework Directive waterbody status and, where possible, enhance the environmental status.

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
Severn Trent note that paragraph 6.1 details that new waste facilities will be close to the main urban areas. Whilst this approach may be appropriate for Recycling and Households Waste Sites (RHWS), it is not appropriate for Wastewater Treatment Works (WwTW), historically WwTW have generally been located away from built up areas due to the nature of their operation and the nuisance that could be caused. WwTW area also generally located in low lying locations near watercourses as such the location of any new WwTW may not fit with the principles outlined within paragraph 6.1 this should be accounted for by clarifying that Sewerage assets such as WwTW and Pumping stations, area exempt from the principles of paragraph 6.1.
It is also important to note that Severn Trent have a significant amount of groundwater abstraction sources in the planned area. Care will be needed to ensure that any new waste management facility is appropriately located at suitable distances from groundwater source protection zones, as defined by the Environment Agency.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Severn Trent would highlight that as detailed within our response to Question 14, sites required for new sewerage assets, will need to meet a different needs to other Waste Management sites, whilst there are similarities in term of need to protect the environmental and the risk of nuisance from odour, traffic, lighting etc. as Sewerage assets also rely of topographical and hydrological features to identify appropriate sites, it should be clear that a separate process will be needed to identify the
most suitable sites.
We would also highlight the need to ensure that residential development near existing assets should
be managed carefully to protect these assets, and enable their continued operation.

Q16: What do you think of our proposals for the scope of the development
management policies? Are there any others that should be covered such as for
specific types of waste management facility?
Severn Trent would support the inclusion of and continued consideration of ‘flooding and water
resources’ as highlighted in paragraph 7.2.
To enable the sustainable supply of potable water for Nottinghamshire residents and businesses, it
is vital that groundwater and surface waters are protected from pollution. Due to the nature of waste
sites, they pose a greater risk to water than domestic dwellings, and we therefore support the need
to highlight water resources and the need to protect them.
We are also aware that as part of several pollution mitigation process for waste sites, it may be
necessary to connect surface water to the foul / combined sewers. This approach has the risk to
exceed the standard design capacity for the sewerage system. It is therefore important that where
possible, surface water is managed appropriately. The following principles should therefore be
followed unless other pollution prevention requirements are needed.
1) All non-waste operational area’s i.e. roofs, roads (where possible) should be directed
towards a sustainable surface water outfall in accordance with the Drainage Hierarchy.
2) All areas of a waste site that can be drained to a sustainable surface water outfall are treated
through an appropriate number of treatment train / process to ensure pollution is not caused
or flood risk increased.
3) Where possible any waste handling / storage areas should be covered to prevent excess
rainwater entering the foul sewerage system
4) Any areas of a waste site connected to the foul /combined sewer should incorporate suitable
mitigation / attenuation of storm flows, where not separated.
The Idle and Torne Permo-Triassic aquifer is currently at poor status. We have an obligation as
abstractions under the Water Framework Directive to not further deteriorate the waterbody by
increasing abstractions. Demand management is one of the mechanisms we have in our Water
Resource Management Plan to manage this risk. We are working with stakeholders to ensure that
we use water resources more effectively. We therefore recommend that rainwater harvesting and
(where appropriate) grey water harvesting is utilised on site, to minimise the water consumption
needs, especially for tasks such as wheel washing or dust suppression.
As per our response to Question 15, we would highlight the need to protect existing sewerage and
water supply assets from new development, in such that the operation of these sites is not
adversely effected by new development.
Please keep us informed when your plans are further developed when we will be able to offer more
detailed comments and advice.

For your information we have set out some general guidelines that may be useful to you.

Position Statement
As a water company we have an obligation to provide water supplies and sewage treatment
capacity for domestic flows from future development. It is important for us to work collaboratively
with Local Planning Authorities to provide relevant assessments of the impacts of future
developments. For outline proposals we are able to provide general comments. Once detailed
developments and site-specific locations are confirmed by local councils, we are able to provide
more specific comments and modelling of the network if required. For most developments we do not
foresee any particular issues that would prevent the supply of water or sewerage. Where we
consider there may be an issue we would discuss in further detail with the Local Planning Authority.
Where Waste Sites are proposed to be developed or extended, we do not anticipate there will be
any significant need to supply water or sewerage due to the nature of development. If however you
anticipate that there will be a requirement for Severn Trent to provide these services it is strongly
advised that you contact us to ensure that capacity can be made available at the appropriate time

Sewage Strategy
Once detailed plans are available and we have modelled the additional capacity, in areas where
sufficient capacity is not currently available and we have sufficient confidence that developments
will be built, we will complete necessary improvements to provide the capacity. We will ensure that
our assets have no adverse effect on the environment and that we provide appropriate levels of
treatment at each of our sewage treatment works.
Surface Water and Sewer Flooding
We expect surface water to be managed in line with the Government’s Water Strategy, Future
Water. The strategy sets out a vision for more effective management of surface water to deal with
the dual pressures of climate change and housing development. Surface water needs to be
managed sustainably. For new developments we would not expect surface water to be conveyed to
our foul or combined sewage system and, where practicable, we support the removal of surface
water already connected to foul or combined sewer.
We believe that greater emphasis needs to be paid to consequences of extreme rainfall. In the past,
even outside of the flood plain, some properties have been built in natural drainage paths. We
request that developers providing sewers on new developments should safely accommodate floods
which exceed the design capacity of the sewers.
To encourage developers to consider sustainable drainage, Severn Trent currently offer a 100%
discount on the sewerage infrastructure charge if there is no surface water connection and a 75%
discount if there is a surface water connection via a sustainable drainage system. More details can
be found on our website
https://www.stwater.co.uk/building-and-developing/regulations-and-forms/application-forms-andguidance/
infrastructure-charges/

Groundwater
Severn Trent strongly recommends that all appropriate EA guidance is followed with reference to
site management and any future abstraction of water to ensure the WFD ‘No-Deterioration’
Principles are followed.
Water Quality
Good quality river water and groundwater is vital for provision of good quality drinking water. We
work closely with the Environment Agency and local farmers to ensure that water quality of supplies
are not impacted by our or others operations. The Environment Agency’s Source Protection Zone
(SPZ) and Safe Guarding Zone policy should provide guidance on development. Any proposals
should take into account the principles of the Water Framework Directive and River Basin
Management Plan for the Severn River basin unit as prepared by the Environment Agency.
Water Supply
When specific detail of planned development location and sizes are available a site specific
assessment of the capacity of our water supply network could be made. Any assessment will
involve carrying out a network analysis exercise to investigate any potential impacts.
We would not anticipate capacity problems within the urban areas of our network, any issues can be
addressed through reinforcing our network. However, the ability to support significant development
in the rural areas is likely to have a greater impact and require greater reinforcement to
accommodate greater demands.

We hope this information has been useful to you and we look forward in hearing from you in the
near future.
Yours sincerely

Dear Sir/Madam
Nottingham and Nottinghamshire Local Waste Plan

Thank you for the opportunity to comment on your consultation, on the issues and options stage of the Nottingham and Nottinghamshire Local Waste Plan. We do not generally have any comments on, but there are a few sections that we would like to highlight specific issues with.

Q13: Are the above objectives appropriate? Are there others we should consider?
We believe that the plan for the environment could be more ambitious. Objective 3 is loosely defined around protecting the environment. More importantly, there should be a commitment to work with other stakeholders, including Severn Trent Water, to ensure that there is not deterioration against Water Framework Directive waterbody status and, where possible, enhance the environmental status.

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
Severn Trent note that paragraph 6.1 details that new waste facilities will be close to the main urban areas. Whilst this approach may be appropriate for Recycling and Households Waste Sites (RHWS), it is not appropriate for Wastewater Treatment Works (WwTW), historically WwTW have generally been located away from built up areas due to the nature of their operation and the nuisance that could be caused. WwTW area also generally located in low lying locations near watercourses as such the location of any new WwTW may not fit with the principles outlined within paragraph 6.1 this should be accounted for by clarifying that Sewerage assets such as WwTW and Pumping stations, area exempt from the principles of paragraph 6.1.
It is also important to note that Severn Trent have a significant amount of groundwater abstraction sources in the planned area. Care will be needed to ensure that any new waste management facility is appropriately located at suitable distances from groundwater source protection zones, as defined by the Environment Agency.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Severn Trent would highlight that as detailed within our response to Question 14, sites required for new sewerage assets, will need to meet a different needs to other Waste Management sites, whilst there are similarities in term of need to protect the environmental and the risk of nuisance from odour, traffic, lighting etc. as Sewerage assets also rely of topographical and hydrological features to identify appropriate sites, it should be clear that a separate process will be needed to identify the
most suitable sites.
We would also highlight the need to ensure that residential development near existing assets should
be managed carefully to protect these assets, and enable their continued operation.

Q16: What do you think of our proposals for the scope of the development
management policies? Are there any others that should be covered such as for
specific types of waste management facility?
Severn Trent would support the inclusion of and continued consideration of ‘flooding and water
resources’ as highlighted in paragraph 7.2.
To enable the sustainable supply of potable water for Nottinghamshire residents and businesses, it
is vital that groundwater and surface waters are protected from pollution. Due to the nature of waste
sites, they pose a greater risk to water than domestic dwellings, and we therefore support the need
to highlight water resources and the need to protect them.
We are also aware that as part of several pollution mitigation process for waste sites, it may be
necessary to connect surface water to the foul / combined sewers. This approach has the risk to
exceed the standard design capacity for the sewerage system. It is therefore important that where
possible, surface water is managed appropriately. The following principles should therefore be
followed unless other pollution prevention requirements are needed.
1) All non-waste operational area’s i.e. roofs, roads (where possible) should be directed
towards a sustainable surface water outfall in accordance with the Drainage Hierarchy.
2) All areas of a waste site that can be drained to a sustainable surface water outfall are treated
through an appropriate number of treatment train / process to ensure pollution is not caused
or flood risk increased.
3) Where possible any waste handling / storage areas should be covered to prevent excess
rainwater entering the foul sewerage system
4) Any areas of a waste site connected to the foul /combined sewer should incorporate suitable
mitigation / attenuation of storm flows, where not separated.
The Idle and Torne Permo-Triassic aquifer is currently at poor status. We have an obligation as
abstractions under the Water Framework Directive to not further deteriorate the waterbody by
increasing abstractions. Demand management is one of the mechanisms we have in our Water
Resource Management Plan to manage this risk. We are working with stakeholders to ensure that
we use water resources more effectively. We therefore recommend that rainwater harvesting and
(where appropriate) grey water harvesting is utilised on site, to minimise the water consumption
needs, especially for tasks such as wheel washing or dust suppression.
As per our response to Question 15, we would highlight the need to protect existing sewerage and
water supply assets from new development, in such that the operation of these sites is not
adversely effected by new development.
Please keep us informed when your plans are further developed when we will be able to offer more
detailed comments and advice.

For your information we have set out some general guidelines that may be useful to you.

Position Statement
As a water company we have an obligation to provide water supplies and sewage treatment
capacity for domestic flows from future development. It is important for us to work collaboratively
with Local Planning Authorities to provide relevant assessments of the impacts of future
developments. For outline proposals we are able to provide general comments. Once detailed
developments and site-specific locations are confirmed by local councils, we are able to provide
more specific comments and modelling of the network if required. For most developments we do not
foresee any particular issues that would prevent the supply of water or sewerage. Where we
consider there may be an issue we would discuss in further detail with the Local Planning Authority.
Where Waste Sites are proposed to be developed or extended, we do not anticipate there will be
any significant need to supply water or sewerage due to the nature of development. If however you
anticipate that there will be a requirement for Severn Trent to provide these services it is strongly
advised that you contact us to ensure that capacity can be made available at the appropriate time

Sewage Strategy
Once detailed plans are available and we have modelled the additional capacity, in areas where
sufficient capacity is not currently available and we have sufficient confidence that developments
will be built, we will complete necessary improvements to provide the capacity. We will ensure that
our assets have no adverse effect on the environment and that we provide appropriate levels of
treatment at each of our sewage treatment works.
Surface Water and Sewer Flooding
We expect surface water to be managed in line with the Government’s Water Strategy, Future
Water. The strategy sets out a vision for more effective management of surface water to deal with
the dual pressures of climate change and housing development. Surface water needs to be
managed sustainably. For new developments we would not expect surface water to be conveyed to
our foul or combined sewage system and, where practicable, we support the removal of surface
water already connected to foul or combined sewer.
We believe that greater emphasis needs to be paid to consequences of extreme rainfall. In the past,
even outside of the flood plain, some properties have been built in natural drainage paths. We
request that developers providing sewers on new developments should safely accommodate floods
which exceed the design capacity of the sewers.
To encourage developers to consider sustainable drainage, Severn Trent currently offer a 100%
discount on the sewerage infrastructure charge if there is no surface water connection and a 75%
discount if there is a surface water connection via a sustainable drainage system. More details can
be found on our website
https://www.stwater.co.uk/building-and-developing/regulations-and-forms/application-forms-andguidance/
infrastructure-charges/

Groundwater
Severn Trent strongly recommends that all appropriate EA guidance is followed with reference to
site management and any future abstraction of water to ensure the WFD ‘No-Deterioration’
Principles are followed.
Water Quality
Good quality river water and groundwater is vital for provision of good quality drinking water. We
work closely with the Environment Agency and local farmers to ensure that water quality of supplies
are not impacted by our or others operations. The Environment Agency’s Source Protection Zone
(SPZ) and Safe Guarding Zone policy should provide guidance on development. Any proposals
should take into account the principles of the Water Framework Directive and River Basin
Management Plan for the Severn River basin unit as prepared by the Environment Agency.
Water Supply
When specific detail of planned development location and sizes are available a site specific
assessment of the capacity of our water supply network could be made. Any assessment will
involve carrying out a network analysis exercise to investigate any potential impacts.
We would not anticipate capacity problems within the urban areas of our network, any issues can be
addressed through reinforcing our network. However, the ability to support significant development
in the rural areas is likely to have a greater impact and require greater reinforcement to
accommodate greater demands.

We hope this information has been useful to you and we look forward in hearing from you in the
near future.
Yours sincerely

Dear Sir/Madam
Nottingham and Nottinghamshire Local Waste Plan

Thank you for the opportunity to comment on your consultation, on the issues and options stage of the Nottingham and Nottinghamshire Local Waste Plan. We do not generally have any comments on, but there are a few sections that we would like to highlight specific issues with.

Q13: Are the above objectives appropriate? Are there others we should consider?
We believe that the plan for the environment could be more ambitious. Objective 3 is loosely defined around protecting the environment. More importantly, there should be a commitment to work with other stakeholders, including Severn Trent Water, to ensure that there is not deterioration against Water Framework Directive waterbody status and, where possible, enhance the environmental status.

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
Severn Trent note that paragraph 6.1 details that new waste facilities will be close to the main urban areas. Whilst this approach may be appropriate for Recycling and Households Waste Sites (RHWS), it is not appropriate for Wastewater Treatment Works (WwTW), historically WwTW have generally been located away from built up areas due to the nature of their operation and the nuisance that could be caused. WwTW area also generally located in low lying locations near watercourses as such the location of any new WwTW may not fit with the principles outlined within paragraph 6.1 this should be accounted for by clarifying that Sewerage assets such as WwTW and Pumping stations, area exempt from the principles of paragraph 6.1.
It is also important to note that Severn Trent have a significant amount of groundwater abstraction sources in the planned area. Care will be needed to ensure that any new waste management facility is appropriately located at suitable distances from groundwater source protection zones, as defined by the Environment Agency.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Severn Trent would highlight that as detailed within our response to Question 14, sites required for new sewerage assets, will need to meet a different needs to other Waste Management sites, whilst there are similarities in term of need to protect the environmental and the risk of nuisance from odour, traffic, lighting etc. as Sewerage assets also rely of topographical and hydrological features to identify appropriate sites, it should be clear that a separate process will be needed to identify the
most suitable sites.
We would also highlight the need to ensure that residential development near existing assets should
be managed carefully to protect these assets, and enable their continued operation.

Q16: What do you think of our proposals for the scope of the development
management policies? Are there any others that should be covered such as for
specific types of waste management facility?
Severn Trent would support the inclusion of and continued consideration of ‘flooding and water
resources’ as highlighted in paragraph 7.2.
To enable the sustainable supply of potable water for Nottinghamshire residents and businesses, it
is vital that groundwater and surface waters are protected from pollution. Due to the nature of waste
sites, they pose a greater risk to water than domestic dwellings, and we therefore support the need
to highlight water resources and the need to protect them.
We are also aware that as part of several pollution mitigation process for waste sites, it may be
necessary to connect surface water to the foul / combined sewers. This approach has the risk to
exceed the standard design capacity for the sewerage system. It is therefore important that where
possible, surface water is managed appropriately. The following principles should therefore be
followed unless other pollution prevention requirements are needed.
1) All non-waste operational area’s i.e. roofs, roads (where possible) should be directed
towards a sustainable surface water outfall in accordance with the Drainage Hierarchy.
2) All areas of a waste site that can be drained to a sustainable surface water outfall are treated
through an appropriate number of treatment train / process to ensure pollution is not caused
or flood risk increased.
3) Where possible any waste handling / storage areas should be covered to prevent excess
rainwater entering the foul sewerage system
4) Any areas of a waste site connected to the foul /combined sewer should incorporate suitable
mitigation / attenuation of storm flows, where not separated.
The Idle and Torne Permo-Triassic aquifer is currently at poor status. We have an obligation as
abstractions under the Water Framework Directive to not further deteriorate the waterbody by
increasing abstractions. Demand management is one of the mechanisms we have in our Water
Resource Management Plan to manage this risk. We are working with stakeholders to ensure that
we use water resources more effectively. We therefore recommend that rainwater harvesting and
(where appropriate) grey water harvesting is utilised on site, to minimise the water consumption
needs, especially for tasks such as wheel washing or dust suppression.
As per our response to Question 15, we would highlight the need to protect existing sewerage and
water supply assets from new development, in such that the operation of these sites is not
adversely effected by new development.
Please keep us informed when your plans are further developed when we will be able to offer more
detailed comments and advice.

For your information we have set out some general guidelines that may be useful to you.

Position Statement
As a water company we have an obligation to provide water supplies and sewage treatment
capacity for domestic flows from future development. It is important for us to work collaboratively
with Local Planning Authorities to provide relevant assessments of the impacts of future
developments. For outline proposals we are able to provide general comments. Once detailed
developments and site-specific locations are confirmed by local councils, we are able to provide
more specific comments and modelling of the network if required. For most developments we do not
foresee any particular issues that would prevent the supply of water or sewerage. Where we
consider there may be an issue we would discuss in further detail with the Local Planning Authority.
Where Waste Sites are proposed to be developed or extended, we do not anticipate there will be
any significant need to supply water or sewerage due to the nature of development. If however you
anticipate that there will be a requirement for Severn Trent to provide these services it is strongly
advised that you contact us to ensure that capacity can be made available at the appropriate time

Sewage Strategy
Once detailed plans are available and we have modelled the additional capacity, in areas where
sufficient capacity is not currently available and we have sufficient confidence that developments
will be built, we will complete necessary improvements to provide the capacity. We will ensure that
our assets have no adverse effect on the environment and that we provide appropriate levels of
treatment at each of our sewage treatment works.
Surface Water and Sewer Flooding
We expect surface water to be managed in line with the Government’s Water Strategy, Future
Water. The strategy sets out a vision for more effective management of surface water to deal with
the dual pressures of climate change and housing development. Surface water needs to be
managed sustainably. For new developments we would not expect surface water to be conveyed to
our foul or combined sewage system and, where practicable, we support the removal of surface
water already connected to foul or combined sewer.
We believe that greater emphasis needs to be paid to consequences of extreme rainfall. In the past,
even outside of the flood plain, some properties have been built in natural drainage paths. We
request that developers providing sewers on new developments should safely accommodate floods
which exceed the design capacity of the sewers.
To encourage developers to consider sustainable drainage, Severn Trent currently offer a 100%
discount on the sewerage infrastructure charge if there is no surface water connection and a 75%
discount if there is a surface water connection via a sustainable drainage system. More details can
be found on our website
https://www.stwater.co.uk/building-and-developing/regulations-and-forms/application-forms-andguidance/
infrastructure-charges/

Groundwater
Severn Trent strongly recommends that all appropriate EA guidance is followed with reference to
site management and any future abstraction of water to ensure the WFD ‘No-Deterioration’
Principles are followed.
Water Quality
Good quality river water and groundwater is vital for provision of good quality drinking water. We
work closely with the Environment Agency and local farmers to ensure that water quality of supplies
are not impacted by our or others operations. The Environment Agency’s Source Protection Zone
(SPZ) and Safe Guarding Zone policy should provide guidance on development. Any proposals
should take into account the principles of the Water Framework Directive and River Basin
Management Plan for the Severn River basin unit as prepared by the Environment Agency.
Water Supply
When specific detail of planned development location and sizes are available a site specific
assessment of the capacity of our water supply network could be made. Any assessment will
involve carrying out a network analysis exercise to investigate any potential impacts.
We would not anticipate capacity problems within the urban areas of our network, any issues can be
addressed through reinforcing our network. However, the ability to support significant development
in the rural areas is likely to have a greater impact and require greater reinforcement to
accommodate greater demands.

We hope this information has been useful to you and we look forward in hearing from you in the
near future.
Yours sincerely

Dear Sir/Madam
Nottingham and Nottinghamshire Local Waste Plan

Thank you for the opportunity to comment on your consultation, on the issues and options stage of the Nottingham and Nottinghamshire Local Waste Plan. We do not generally have any comments on, but there are a few sections that we would like to highlight specific issues with.

Q13: Are the above objectives appropriate? Are there others we should consider?
We believe that the plan for the environment could be more ambitious. Objective 3 is loosely defined around protecting the environment. More importantly, there should be a commitment to work with other stakeholders, including Severn Trent Water, to ensure that there is not deterioration against Water Framework Directive waterbody status and, where possible, enhance the environmental status.

Q14: What do you think of our proposals for the broad locations of future waste management facilities across the Plan Area? Are there other options we should consider?
Severn Trent note that paragraph 6.1 details that new waste facilities will be close to the main urban areas. Whilst this approach may be appropriate for Recycling and Households Waste Sites (RHWS), it is not appropriate for Wastewater Treatment Works (WwTW), historically WwTW have generally been located away from built up areas due to the nature of their operation and the nuisance that could be caused. WwTW area also generally located in low lying locations near watercourses as such the location of any new WwTW may not fit with the principles outlined within paragraph 6.1 this should be accounted for by clarifying that Sewerage assets such as WwTW and Pumping stations, area exempt from the principles of paragraph 6.1.
It is also important to note that Severn Trent have a significant amount of groundwater abstraction sources in the planned area. Care will be needed to ensure that any new waste management facility is appropriately located at suitable distances from groundwater source protection zones, as defined by the Environment Agency.

Q15: Do you think that a general criteria approach is sufficient to deal with future provision or should the Plan be allocating specific sites? Are there other options we might consider?
Severn Trent would highlight that as detailed within our response to Question 14, sites required for new sewerage assets, will need to meet a different needs to other Waste Management sites, whilst there are similarities in term of need to protect the environmental and the risk of nuisance from odour, traffic, lighting etc. as Sewerage assets also rely of topographical and hydrological features to identify appropriate sites, it should be clear that a separate process will be needed to identify the
most suitable sites.
We would also highlight the need to ensure that residential development near existing assets should
be managed carefully to protect these assets, and enable their continued operation.

Q16: What do you think of our proposals for the scope of the development
management policies? Are there any others that should be covered such as for
specific types of waste management facility?
Severn Trent would support the inclusion of and continued consideration of ‘flooding and water
resources’ as highlighted in paragraph 7.2.
To enable the sustainable supply of potable water for Nottinghamshire residents and businesses, it
is vital that groundwater and surface waters are protected from pollution. Due to the nature of waste
sites, they pose a greater risk to water than domestic dwellings, and we therefore support the need
to highlight water resources and the need to protect them.
We are also aware that as part of several pollution mitigation process for waste sites, it may be
necessary to connect surface water to the foul / combined sewers. This approach has the risk to
exceed the standard design capacity for the sewerage system. It is therefore important that where
possible, surface water is managed appropriately. The following principles should therefore be
followed unless other pollution prevention requirements are needed.
1) All non-waste operational area’s i.e. roofs, roads (where possible) should be directed
towards a sustainable surface water outfall in accordance with the Drainage Hierarchy.
2) All areas of a waste site that can be drained to a sustainable surface water outfall are treated
through an appropriate number of treatment train / process to ensure pollution is not caused
or flood risk increased.
3) Where possible any waste handling / storage areas should be covered to prevent excess
rainwater entering the foul sewerage system
4) Any areas of a waste site connected to the foul /combined sewer should incorporate suitable
mitigation / attenuation of storm flows, where not separated.
The Idle and Torne Permo-Triassic aquifer is currently at poor status. We have an obligation as
abstractions under the Water Framework Directive to not further deteriorate the waterbody by
increasing abstractions. Demand management is one of the mechanisms we have in our Water
Resource Management Plan to manage this risk. We are working with stakeholders to ensure that
we use water resources more effectively. We therefore recommend that rainwater harvesting and
(where appropriate) grey water harvesting is utilised on site, to minimise the water consumption
needs, especially for tasks such as wheel washing or dust suppression.
As per our response to Question 15, we would highlight the need to protect existing sewerage and
water supply assets from new development, in such that the operation of these sites is not
adversely effected by new development.
Please keep us informed when your plans are further developed when we will be able to offer more
detailed comments and advice.

For your information we have set out some general guidelines that may be useful to you.

Position Statement
As a water company we have an obligation to provide water supplies and sewage treatment
capacity for domestic flows from future development. It is important for us to work collaboratively
with Local Planning Authorities to provide relevant assessments of the impacts of future
developments. For outline proposals we are able to provide general comments. Once detailed
developments and site-specific locations are confirmed by local councils, we are able to provide
more specific comments and modelling of the network if required. For most developments we do not
foresee any particular issues that would prevent the supply of water or sewerage. Where we
consider there may be an issue we would discuss in further detail with the Local Planning Authority.
Where Waste Sites are proposed to be developed or extended, we do not anticipate there will be
any significant need to supply water or sewerage due to the nature of development. If however you
anticipate that there will be a requirement for Severn Trent to provide these services it is strongly
advised that you contact us to ensure that capacity can be made available at the appropriate time

Sewage Strategy
Once detailed plans are available and we have modelled the additional capacity, in areas where
sufficient capacity is not currently available and we have sufficient confidence that developments
will be built, we will complete necessary improvements to provide the capacity. We will ensure that
our assets have no adverse effect on the environment and that we provide appropriate levels of
treatment at each of our sewage treatment works.
Surface Water and Sewer Flooding
We expect surface water to be managed in line with the Government’s Water Strategy, Future
Water. The strategy sets out a vision for more effective management of surface water to deal with
the dual pressures of climate change and housing development. Surface water needs to be
managed sustainably. For new developments we would not expect surface water to be conveyed to
our foul or combined sewage system and, where practicable, we support the removal of surface
water already connected to foul or combined sewer.
We believe that greater emphasis needs to be paid to consequences of extreme rainfall. In the past,
even outside of the flood plain, some properties have been built in natural drainage paths. We
request that developers providing sewers on new developments should safely accommodate floods
which exceed the design capacity of the sewers.
To encourage developers to consider sustainable drainage, Severn Trent currently offer a 100%
discount on the sewerage infrastructure charge if there is no surface water connection and a 75%
discount if there is a surface water connection via a sustainable drainage system. More details can
be found on our website
https://www.stwater.co.uk/building-and-developing/regulations-and-forms/application-forms-andguidance/
infrastructure-charges/

Groundwater
Severn Trent strongly recommends that all appropriate EA guidance is followed with reference to
site management and any future abstraction of water to ensure the WFD ‘No-Deterioration’
Principles are followed.
Water Quality
Good quality river water and groundwater is vital for provision of good quality drinking water. We
work closely with the Environment Agency and local farmers to ensure that water quality of supplies
are not impacted by our or others operations. The Environment Agency’s Source Protection Zone
(SPZ) and Safe Guarding Zone policy should provide guidance on development. Any proposals
should take into account the principles of the Water Framework Directive and River Basin
Management Plan for the Severn River basin unit as prepared by the Environment Agency.
Water Supply
When specific detail of planned development location and sizes are available a site specific
assessment of the capacity of our water supply network could be made. Any assessment will
involve carrying out a network analysis exercise to investigate any potential impacts.
We would not anticipate capacity problems within the urban areas of our network, any issues can be
addressed through reinforcing our network. However, the ability to support significant development
in the rural areas is likely to have a greater impact and require greater reinforcement to
accommodate greater demands.

We hope this information has been useful to you and we look forward in hearing from you in the
near future.
Yours sincerely