Thames Water is pleased to comment on the proposed changes to the London Plan 2014.

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1 Boris Johnson Mayor of London (London Plan) Greater London Authority City Hall More London The Queen s Walk London SE1 2AA Thames Water Property Services Your ref Our ref Name Phone London Plan Review 8042/123/MM/LondonPlan Mark Mathews mark.mathews@thameswater.co.uk 25 March 2014 The London Plan Consultation on proposed changes, 2014 Dear Sir Thames Water is pleased to comment on the proposed changes to the London Plan Thames Water is the largest water and wastewater services company in the UK, serving over thirteen million customers across the London and Thames Valley area, from Kent and Essex in the east to the edge of Gloucestershire in the west. London, and the eight million customers we serve across the capital, is at the heart of our business and as such we regard the Greater London Authority - both the Mayor and Assembly - as a key partner in addressing the challenges of providing safe, reliable, secure and sustainable water and wastewater services to a dynamic world city. The London Plan, in providing a strategy for the future sustainable development of London, is central to setting policies for delivering growth with the requisite infrastructure. We are currently reviewing Ofwat s consideration of our draft business plan. Our Business Plan will establish the level of investment we can deliver for the period between 2015 and As the policies in the London Plan are finalised, and as we review Ofwat s view of our draft business plan we are keen to continue our ongoing dialogue with the GLA to ensure the policies in the Plan reflect the level of infrastructure investment we will be delivering in the coming years. Thames Water Clearwater Court, Grnd Floor East, Vastern Rd, Reading, Berks RG1 8DB T I Registered in England and Wales No , Registered office Clearwater Court, Vastern Road, Reading, Berks, RG1 8DB London Plan Review 2014.doc

2 Page 2 Overview We welcome the Plan s continued acknowledgement that London has to have the infrastructure it needs to sustain growth. Likewise, we very much welcome the Mayor s intention to work with water companies in making London a global leader amongst cities. We also support the Mayor s commitment to environmental sustainability which, along with a strong focus on social and economic sustainability, similarly forms the fundamental basis of our own approach to sustainability. We acknowledge that the main change to the Plan are: the formal end year being 2036 rather than 2031; revised population projections; with associated significant increases in housing numbers proposed; updated text relating to the Olympics and the formation of LLDC; and incorporating NPPF requirements. Chapter 1 Context and Strategy Chapter 1 Context & Strategy A changing climate. We note that by the 2020 s there are likely to be more Londoners than at any time in the city s history; with growth in population and household generation accelerating much greater than anticipated in the 2011 Plan. We agree that the Mayor should continue to take a plan, monitor and manage approach to accommodating London s growth and we acknowledge that the Mayor proposes to seek to accommodate this growth within the capital s boundaries without intruding strategically on its protected green and open spaces. We support the additional wording proposed to section 1.45 of the Plan which highlights that the Mayor will seek to unlock the barriers to the development that London needs, whilst ensuring it is planned properly and critically for Thames Water, that development is supported by the infrastructure it requires to succeed. We support the overall vision and objective that the Mayor has set. We particularly welcome the renewed emphasis the Mayor has placed on London

3 Page 3 becoming a world leader in improving the environment (paragraph 1.53, bullet point 5). Chapter 3 London s People We note the significant increase in homes proposed across London, at 42,000 net additional homes across London per year as set out in Policy 3.3 of the Plan. We note for example that the London Borough of Brent is subject to a 50% increase in dwellings (from 10,650 dwellings (10 years to 2021) to 15,253 dwellings (10 years to 2025). There are also particular Opportunity Areas where Thames Water considers that the infrastructure network capacity needs to be strategically addressed at the earliest opportunity. For example: at Vauxhall, Nine Elms, Battersea where the proposed number of dwellings is forecast to increase from 10,000 dwellings (10 years to 2021) to 20,000 dwellings (10 years to 2025). at Kensal Canal Side it is proposed to plan for an increase in dwellings from 2,000 dwellings (10 years to 2021) to 3,500 dwellings (10 years to 2025). at Old Oak Common (24,000 dwellings 10 years to 2025) which is not identified in the adopted Plan. In London, development levels proposed for Boroughs, Opportunity Areas and Intensification Areas are likely to fall across more than one of our wastewater treatment catchment areas. For example, with regards to the Upper Lee Valley Opportunity Area, this Area falls within Enfield, Haringey, Waltham Forest and Hackney Boroughs. Enfield is located entirely within the Deephams Sewage Treatment Works (STW) catchment, whilst Hackney is located entirely within the Beckton STW catchment. Haringey and Waltham Forest, however, are split between the Deephams and Beckton catchments. Therefore we cannot establish the likely impact upon our infrastructure without working closely with the individual Boroughs to understand where the strategic developments will be located. Additionally, development in one Borough may have consequences in terms of upgrade requirements and issues of sewer flooding or water pressure issues in other Boroughs. For example, where neighbouring Boroughs are located in the same catchment, development in one Borough may necessitate upgrades to the network in the neighbouring Borough. Therefore the local planning authorities will need to work closely together with each other and Thames Water.

4 Page 4 For Thames Water this will mean significant additional infrastructure investment in the years to come, particularly in relation to our network capacity. To ensure the timely delver of infrastructure upgrades this will require close collaboration between all key stakeholders. Thames Water will continue to work closely with developers, Boroughs, other utilities and the GLA, to deliver London s water and wastewater infrastructure requirements. Thames Water has limited powers under the Water Industry Act 1991 to prevent connection to its network ahead of infrastructure upgrades. Therefore, Thames Water relies heavily on the planning system to ensure infrastructure upgrades are provided ahead of development either through phasing and Local Plan policies, or the use of Grampian style conditions attached to planning permissions. This position is supported in the National Planning Practice Guidance Developers will need to specifically consider the net increase in water and wastewater demand to serve the developments and also any impact the developments may have off site further down the network, if no/low water pressure and internal/external sewage flooding of property is to be avoided. This reinforces the requirements of Policy 5.14 Water Quality and Sewerage Infrastructure, which highlight the need for appropriate and adequate sewerage infrastructure capacity in London. Chapter 5 London s response to climate change We support the aspiration of the Mayor for London to be a world leader in improving the environment, as set out in Paragraph 5.1 of the Plan. We also support the Mayor s energy ambition that London s energy infrastructure, particularly its energy network, is resilient and able to accommodate projected growth and decentralised energy. We therefore welcome the proposed new policies on energy and gas infrastructure in the Plan (Policy 5.4A). Thames Water is maximising its ability to be resilient to energy demands, not least by generating as much renewable energy as possible. For example we have installed new sludge digestion plants (known as thermal hydrolysis plants) at our sewage works in east London. Where appropriate we have also installed solar panels and wind turbines on our operational sites. We have also been working with the GLA and some of the London Boroughs on looking at innovative ways to create additional renewable energy from our infrastructure, for example through floating solar panels on our reservoirs, from co digesting sewage sludge with other forms of waste and from capturing heat from our sewers and reservoirs.

5 Page 5 We intend to continue to reduce our carbon footprint and expand our renewable energy generation in the next 5 years and beyond. Policy 5.2 Minimising carbon dioxide emissions The proposed additional paragraph (5.22a) relating to demand side management to minimise carbon dioxide emissions is welcome. However it would be helpful if the paragraph could be clear that demand side management includes reference to the timing of energy consumption during the day. The expanded text should also provide examples of how developments could be encouraged to incorporate demand side management of energy usage.. Policy 5.4A Electricity and Gas Supply We are supportive of the inclusion of this policy in the London Plan and the associated requirement for the Mayor, developers, energy companies and other stakeholders to work collaboratively together to ensure that future electricity and gas needs are met. Policy 5.8 Innovative energy technologies. We remain supportive of the references to maximising the uptake of advanced conversion technologies such as anaerobic digestion. We continue to explore the opportunities of co-digestion at our London sewage treatment works which could provide additional renewable energy generation benefits to London. Policy 5.10 Urban greening We note that the sub text to this policy could be updated. Policy refers to the ambitious programme to plant 1000 street trees by March An update on whether this objective has been achieved would be welcome. Policy 5.11 Green Roof and development site environs Although there are no proposed changes to this policy we continue to support the incorporation of green roofs and green walls on new developments as they can help to reduce surface water runoff and provide enhanced onsite biodiversity. In the Olympic Park we incorporated green roofs into two of our new water pumping stations. We are also incorporating a green roof to our new Barrow Hill reservoir located in Primrose Hill Park.

6 Page 6 Policy 5.12 Flood Risk Management We welcome the reference to reservoir flooding alongside sewer flooding in the sub text to the policy. It is important that when new development is being proposed to be sited close to a reservoir that the risk of reservoir flooding is assessed. Policy 5.13 Sustainable drainage We acknowledge the changes proposed to the sub text to this policy. We continue to support the approach of multi-agency collaboration to achieve sustainable drainage and the hierarchical approach to managing London s surface water and combined foul and surface water drainage. Policy 5.13 is of critical importance in helping to achieve sustainable drainage in new developments. However there are limitations of SuDs, particularly in the Greater London conurbation where the drainage systems are complex and the potential for flooding very great. Our Counters Creek strategic sewerage infrastructure scheme, which will remove a significant number of properties who are at potential risk of flooding in the Counters Creek catchment, includes as part of the scheme the installation of SuDs to a number of streets in West London. SuDs and green infrastructure have an important role to play for smaller defined areas where issues such as localised sewer flooding is a problem. Our SuDs projects will look at how effective SuDS can be in reducing storm water peak flows, and this will act as a platform for possible future investment in retrofitting SuDs in London. Policy 5.14 Water quality and sewerage infrastructure In principle we support Policy 5.14 which generally reflects our consultation responses on previous London Plan consultations. In particular we support the references to improving water quality in London (strategic section of policy), that there should be appropriate and adequate sewerage infrastructure capacity in London (strategic and planning decisions sections), the support for the upgrade of our infrastructure (planning decisions

7 Page 7 and LDF preparation sections) and the support for the Thames Tideway Tunnel (planning decisions and LDF preparation sections). Upgrade of sewerage infrastructure We support the changes to Paragraph 5.59 in relation to sewerage capacity, but we consider that the changes could go further. We have a strategic sewerage infrastructure scheme proposed between now and 2020 to remove a significant number of properties who are at potential risk of flooding in the Counters Creek catchment. The scheme is a combination of increased sewer capacity, a new strategic storm relief sewer, the fitting of property flood protection measures and the implementation of SuDs to a number of local streets. This is an important project for London, having cross Borough boundary considerations and we would like to see a specific reference to the project within the Policy. Our suggested policy change is set out below: Policy 5.14 Water quality and sewerage infrastructure (to be inserted before LDF preparation) The Counters Creek sewerage network improvements project which will help alleviate sewer flooding to over 1700 properties in west London should be supported in principle. Thames Tideway Tunnel We agree with the proposed amendments to the supporting text to Policy 5.14 in relation to the Thames Tideway Tunnel project. We request that the text at paragraph 5.59 be further updated to reflect the current status of the project, which is that the examination of the application closed on 12 March 2014 and that a decision on the application is expected from the Secretaries of State by 12 September We note that an Examination in Public of the Further Alterations to the London Plan is expected later this year. In the event that the Development Consent Order is made by the Secretaries of State and that this occurs prior to the examination into the London Plan commencing, we request a pre-examination change to parts D and E of Policy These parts of the policy should be strengthened to require more than in principle support from local authorities. The order will specify

8 Page 8 the locations in which development is proposed and in these locations local authorities should fully support the proposals for the project. Policy 5.15 Water use and supplies The strategic element of the policy sets out a thorough range of measures to help protect and conserve water supplies and resources. We support this comprehensive approach. We also support the planning decision element of the policy which focuses upon water efficiency and new water supply infrastructure. We do note that the policy remains aspirational. For example there is reference to: minimising use of mains water when this should be reducing use of mains water ; minimising the amount of energy consumed in water supply. This should be reducing the amount of energy consumed in water supply ; Designing residential development so that mains water consumption would meet a target of 105 litres or less per head per day. This should read Designing residential development so that mains water consumption could meet a target of 105 litres or less per head per day. In relation to the sub text to the policy we consider that the changes to paragraph 5.61 could be reworded to highlight the national average change in levels of water consumption. Thereby being consistent with the original text and enabling a comparison. The additional paragraph which makes reference to London s future water security is welcome. We agree that new developments should be based on designs that enable customers (i.e. occupiers of the development) to become significantly more water efficient. It is noted that although development which incorporated water efficiency measures can help to achieve a step change in reduction in water usage, it is the behaviour of the customer that is key. The additional sub text refers to a rolling programme for the replacement of London s water mains. In our draft business plan for 2015 to 2020 we are proposing to continue our mains replacement work and seek to reduce leakage by 59million litres per day across our catchment area. The current proposed text refers to wastage and we would prefer that the text refers instead to leakage.

9 Page 9 With regards to the changes to the text on water neutrality in paragraph 5.62, we acknowledge and support the reference to the Mayor working with water companies to promote demand management measures in Water Resource Management Plans and Business Plans. However additional text should be included to highlight how the concept of water neutrality is being examined and refined to relate to new developments in London. Policy 6.14 Freight We note that under the heading 'planning decisions', part B of policy 6.14 has been amended to include additional provisions about promoting 'more innovative freight solutions, reflecting the positive experience of the Olympics and seeking opportunities to minimise congestion impacts'. As currently drafted it is not clear which innovative freight solutions at the Olympics readers are being directed to consider. We believe that this should be clarified. Policy 7.15 Reducing and managing noise, improving and enhancing the acoustic environment and promoting appropriate soundscapes We support the proposed amendments to this policy. Policy 8.1 Implementation We are supportive of the Mayor's commitment to work with parties to ensure the effective development and delivery of infrastructure needed to support sustainable growth in London. We look forward to continuing to work with the Mayor during the design and development of our infrastructure in London, particularly the construction of the Thames Tideway Tunnel project, but also our Counters Creek sewer flood alleviation scheme and the Deephams Sewage Treatments Works upgrade. We hope you will consider our comments and we look forward to working with the Mayor and GLA team in helping to finalise the updated London Plan. Yours sincerely Mark Mathews Mark Mathews Town Planning Manager Thames Water

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