Chapter 2 Spatial Portrait

Transcription

1 15 November 2013 Dear Julie Fylde Local Plan to 2030 Part 1 Preferred Options Thank you for the opportunity to meet with you on 9 October in respect of the above mentioned document. As discussed at the meeting, our suggested further detailed comments are set out below. Chapter 2 Spatial Portrait Lytham and St Annes Key Characteristics 1) We suggest paragraph 2.19 includes some minor additional wording which further explains the fact that a number of watercourses in the area discharge to the combined sewerage system. This is unusual and helps explain the circumstances of the area and the need to ensure that the discharge of surface water from development sites is fully considered in advance of determination of applications for planning permission to ensure the most sustainable approach to surface water management is investigated and secured. Implications for the local plan 2) Paragraph 2.24 refers to the need to phase development throughout the plan period to allow for the provision of infrastructure. It specifically refers to such as increased capacity of the combined sewer system. Whilst it may be necessary to co-ordinate the delivery of development with increased capacity of our infrastructure, we understand there are other factors which have driven any phasing of development within the development plan. In this context we think it would be most appropriate to delete the reference to the combined sewer system at this point of the plan. Blackpool Periphery Key Characteristics 3) We suggest paragraph 2.46 is amended to state: There are surface water issues in the vicinity of junction 4 of the M55, which mean that development in this area will need to carefully consider the approach to surface water management. The most sustainable form of managing the surface water from the site will be expected to be investigated and confirmed as part of any planning application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run off rate.

2 The preference will be for no surface water to discharge to the public sewer, directly or indirectly, if more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. Chapter 4 Strategic Objectives Introduction 4) Should Authority Monitoring Report state Annual Monitoring Report at paragraph 4.2? Chapter 6: The Spatial Development Framework Policy SD1 The Spatial Development Framework Justification 5) Paragraph 6.32 states: Whilst the Blackpool Periphery has some wastewater issues (meaning development will need to be phased towards the end of the plan period) there is good access to the primary services in the Blackpool sub-regional centre. Although Warton currently performs the role of a Local Service Centre, utilising the potential for development on previously developed land at BAE Systems, the establishment of the Enterprise Zone, the prospect of improved road access to a new junction 2 of the M55 and the proximity to wastewater treatment facilities, means that this is a sustainable location for new development. As stated above, we understand there are other factors which have contributed to the phasing of development within the development plan. In this context we think it would be most appropriate to delete the specific reference to the wastewater issues being a specific factor which is referenced in policy as determining the need to phase development in this location towards the end of the plan period. As for all development in the borough, it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate on greenfield sites and surface water betterment on brownfield sites. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of development with the delivery of infrastructure. What you said 6) Paragraph 6.40 considers what was said in response to option 5. It states Option 5 (focus on Blackpool Periphery, along with Lytham St Annes) had the potential to take pressure off rural areas. However, the point was made that the area has drainage problems and infrastructure and services would need to be addressed in a timely and co-ordinated manner for this option to be deliverable. We note the specific reference to drainage problems. As is clear from the above comments, please be aware that various parts of the borough have a drainage challenge. The need to co-ordinate the delivery of development with drainage infrastructure would need to be considered having regarding to the detail of the circumstances of each development proposal. For example, the redevelopment of a brownfield site could result in an improved drainage situation through surface water betterment.

3 Chapter 7: Strategic Locations for Development Policy SL1 Lytham and St Annes Strategic Location for Development Infrastructure requirements 7) Paragraph 7.8 states: Infrastructure capacity for wastewater and water supply is limited for the following sites: Land at Queensway; Land West of North Houses Lane; and Land North of Moss Hall Lane. Infrastructure capacity for water supply is limited for the Former EDS site, Heyhouses Lane. There is, therefore, a requirement for investment to meet demand and/or to reduce consumption elsewhere in order to deliver these sites. Given that planning permission already exists for the development of the EDS site and Land at Queensway, we do not think it is necessary to refer to the issues in respect of these sites. We suggest the following amendment. For Land West of North Houses Lane; and Land North of Moss Hall Lane, it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. West of North Houses Lane, St Annes (site H2) 8) We suggest paragraph 7.22 is amended as follows: The site cannot be developed until after the implementation of the M55 to St Annes link road, which is scheduled for completion in It will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. North of Moss Hall Lane, St Annes (site H3) 9) We suggest paragraph 7.25 should be amended as follows: The site cannot be developed until after the implementation of the M55 to St Annes link road, which is scheduled for completion in It will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure.

4 Policy SL2 The Blackpool Periphery Strategic Location for Development Infrastructure Requirements 10) We suggest paragraph 7.31 is amended as follows: Given the strategic nature of the development proposed at Whyndyke Farm, Land East of Cropper Road and Blackpool International Airport, it may be necessary to invest in water supply infrastructure. 11) We suggest paragraph 7.32 is amended as follows. In relation to Wyndyke Farm, no surface water should discharge to the public sewerage system. This is in accordance with the recent application submission which has confirmed that surface water will discharge to a watercourse which does not subsequently connect with the combined sewerage system. The discharge to watercourse should be attenuated to greenfield run off rate and incorporate sustainable urban drainage principles. Given the size of this site and the fact that it is likely to be constructed by a number of developers over many years, it will be necessary to ensure a co-ordinated and holistic approach to the delivery of all infrastructure during the whole lifetime of the construction process. It will also be necessary to ensure that there is an appropriate maintenance and management regime for the surface water management measures as part of any development proposal. We also suggest the following additional paragraph in relation to land east of Cropper Road. With regards land east of Cropper Road, it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. Whyndyke Farm (site M2) 12) We suggest paragraph 7.42 is amended as follows. Development of this site will need to be co-ordinated with the road improvements to junction 4 of the M55 Motorway. Land East of Cropper Road (site M1) 13) We suggest paragraph 7.44 is amended as follows. It will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure.

5 Policy SL3 Warton Strategic Location for Development Infrastructure Requirements 14) We suggest paragraph 7.52 is amended as follows: For all these sites it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. Land north of Warton (site H9) 15) We suggest paragraph 7.62 is amended as follows: For this site it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. Land west of Warton (site H8) 16) Paragraph 7.64 states: Due to the scale of development proposed at Warton, it is not anticipated that all the sites could be developed concurrently. One issue is that of traffic congestion. A new link road (the Preston Western Distributor) providing access to a new junction 2 of the M55 will contribute towards alleviating such congestion and this is due to be completed in Also, wastewater infrastructure in the Warton area will need to be upgraded to deliver this site. This indicates that this site should be phased for commencement after the other two sites in the Warton Strategic Location for Development have started and after the new link road has been completed. It is therefore anticipated that development could start on this site in 2021 and be completed by In accordance with our earlier comments, we suggest this paragraph could be amended along the following lines although in this case we are mindful of the references to other infrastructure in the existing paragraph which may need to be taken account of in any amended paragraph. For this site it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation SuDS. This would be to greenfield run-off rate for greenfield areas of the site. For any brownfield areas, there will be an expectation to secure surface water betterment against the existing rate of surface water discharge. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure.

6 Policy S4 Kirkham and Wesham Strategic Location for Development Infrastructure Requirements 17) We suggest paragraphs 7.71 and 7.72 are amended as follows: For these sites, it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. In addition, it may be necessary to invest in water supply infrastructure. Land north of Dowbridge, Kirkham (site H7) 18) We suggest paragraph 7.81 is amended as follows: In terms of wastewater infrastructure, this site is likely to have less impact on infrastructure improvements than other sites in Kirkham and Wesham. However this can only be confirmed once greater detail is known. For this site it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. Land North of Blackpool Road, Kirkham (site M3) 19) We suggest paragraph 7.86 is amended as follows: For this site it will be necessary to secure the most sustainable approach to surface water management and this should be investigated and confirmed as part of any application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be to greenfield run-off rate. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, where more sustainable alternatives are available. Subject to the detail of the drainage proposals and the nature of the mixed uses, it may be necessary to co-ordinate the delivery of the development with the delivery of infrastructure. Chapter 8: General Development Policies Policy GD1 Settlement Boundaries Justification 20) We suggest the 7 th bullet point of paragraph 8.3 should be amended as follows.

7 In addition the following matters will be taken into consideration: Whether the proposals present the most sustainable form of managing surface water from the site. This will be expected to be investigated and confirmed as part of any planning application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, if more sustainable alternatives are available. Policy GD4 Large Developed Sites in the Countryside Context 21) We suggest paragraph 8.14 should be amended as follows. There are a number of large developed sites in the countryside or Green Belt areas within Fylde, such as Weeton Camp and Kirkham Prison. Whether they are redundant or in continuing use, the complete or partial redevelopment of these sites may provide opportunities for environmental improvements and local employment in the rural areas. The Council encourages such proposals, subject to the provisions of Policy GD4 and other relevant policies in the Local Plan. Applicants should be aware that redevelopment proposals in these locations can place different pressure on infrastructure. It will be necessary to consider the impact of any redevelopment proposal on infrastructure as part of an application submission. It may be necessary to co-ordinate the delivery of development with the delivery of infrastructure. Chapter 9: The Fylde Economy Policy EC2 Managing Development of Employment Land 22) We suggest the addition of a further criterion to Policy EC2. The Council will take account of the following factors when assessing all development proposals for employment uses: h) the impact on foul and surface water drainage infrastructure especially the need to secure the most sustainable approach to surface water drainage. Chapter 10 Provision of Homes in Fylde Policy H1 Density, Mix and Design of New Residential Development 23) In this policy, we would encourage the council to promote improvements in water efficiency through the design of all development. This reduces pressure on the supply of water and reduces the impact on wastewater infrastructure. United Utilities encourages new housing development to achieve the water efficiency target set out in Level 3 of the Code for Sustainable Homes. The cumulative impact of reducing pressure on wastewater infrastructure leads to more sustainable development and assists in improving bathing waters. Under the heading of Design, we encourage the following amendment to Policy H1. Design of new residential development will be assessed against paragraphs of the NPPF, Policy ENV 6: Good Design in New Development and Building for Life 12.

8 Justification As a minimum, all new housing developments should meet the Homes and Communities Agency Design and Quality Standards which are currently in force. All new homes will be expected to achieve the water efficiency target set out within Level 3 of the Code for Sustainable Homes. 24) In line with the above point, it is appropriate to expand on the justification text with the insertion of the following additional paragraph. The inclusion of water efficiency measures in new homes reduces pressure on the supply of water and pressure on wastewater infrastructure. This is more sustainable and, in the Fylde Coast, helps to most appropriately manage the impact of new development on bathing waters. Chapter 12: Infrastructure, Service Provision and Transport Policy INF 1 Service Accessibility and Infrastructure 25) We suggest Policy INF 1 is amended as follows. New development will be required to provide essential site service and communications infrastructure and demonstrate that it will support infrastructure requirements as set out in the Infrastructure Delivery Plan. In order for Fylde to protect and create sustainable communities, proposals for development should: e) In considering development proposals, it may be necessary to co-ordinate the timescales for delivery of development with the timescales for the delivery of infrastructure. For large development sites, which may be constructed over a number of years and by various developers, it will be necessary to ensure a co-ordinated and holistic approach to the delivery of infrastructure, especially drainage infrastructure through the requirement for site wide strategies which establish principles to be adhered to during the construction process. Policy INF 2 Developer Contributions 26) We suggest the council could consider amending Policy INF 2 as follows: The types of infrastructure that developments may be required to provide contributions towards include, but are not limited to: b) Flood prevention and sustainable drainage measures (both on site and borough wide, including the retrofitting of SuDS) (see policy CL1); Chapter 13 Sustaining the Environment & Addressing Climate Change Policy CL1 Flood Alleviation and Water Efficiency 27) We suggest Policy CL1 is amended to state. Planning decisions should follow the sequential, risk-based approach to the location of development, as required under paragraph 100 of the NPPF.

9 All new development is required to minimise flood risk impacts on the environment and mitigate against the likely effects of Climate Change on present and future generations. This will be achieved by: a) Ensuring that new development incorporates the most sustainable form of managing surface water. This will be expected to be investigated and confirmed as part of any planning application submission. It will be necessary to attenuate any discharge of surface water through the incorporation of SuDS. This would be greenfield run off rate on greenfield sites. On brownfield sites surface water betterment will be expected. The preference will be for no surface water to discharge to the public sewer, directly or indirectly, if more sustainable alternatives are available. The priority options for the management of surface water are set out in detail in the infrastructure delivery plan. b) Supporting the retrofitting of SuDS in locations that generate surface water run-off. c) Improving water efficiency standards by minimising the use of potable mains water in new development and incorporating measures to recycle and conserve water resources. d) Ensuring that new development is directed away from areas at high risk of flooding and incorporating appropriate mitigation against flooding in areas of lower risk. e) Ensuring that watercourses, which are important habitats for water voles and other species, are protected from encroachment and adverse impacts and that water quality is maintained and improved. Justification f) Seeking to maximise the potential of Green Infrastructure within developments to contribute to flood relief. g) Ensuring that new development does not adversely affect the quality of groundwater. Developer contributions will be required for the provision and maintenance of SuDS, where this is not provided as part of the development. Contributions will be made through Section 106 agreements or the Community Infrastructure Levy, as set out in Policy INF2. Developer contributions will be required for the repair or replacement of the coastal flood defences and the maintenance of the dunes system. Contributions will be made through the Community Infrastructure Levy. Managing Surface Water 28) After paragraph 13.17, we suggest the council could consider including the following paragraph: It is a clear priority of the council that development should not discharge to public sewerage system, directly or indirectly, where alternatives are available. In some circumstances, however, discharge to public sewer, directly or indirectly, may be the only option. In those circumstances, a contribution may be requested to retrofit / divert surface water elsewhere in the borough to negate the impact of

10 discharging surface water to the public sewer. The applicant will also be expected to mitigate the impact of surface water discharge to the public sewer through landscaping schemes and other measures, which will include maximising the use of permeable surfaces and grey water and rainwater harvesting measures. Given the circumstances on the Fylde Coast, you may wish to consider whether it is appropriate to encourage the promoters of any large sites, which are allocated in the emerging development plan, to present high level drainage strategies as part of the development plan preparation process. United Utilities encourages this as good practice so that the most appropriate form of managing surface water can be established as soon as possible. 29) We suggest the fifth sentence of paragraph 3.19 is amended to state: This reinforces the imperative that surface water run-off from new development is managed through SuDS, rather than unattenuated discharges to the Borough s watercourses or public sewer. Water Efficiency 30) In accordance with our comments in respect of Policy H1, we support paragraph However, we also acknowledge the potential financial viability issues at the current time associated with the achievement of Level 6 of the Code for Sustainable Homes. Chapter 14: Preserving and Enhancing the Natural and Built Environment Policy ENV 1 Landscape and Biodiversity 31) We suggest criterion f) of Policy ENV 1 is amended to state: Suitable landscape planting should be incorporated within or, where appropriate, close to new development. Measures should be put in place for the management of such landscaping. Specific consideration should be given to how landscaping schemes will minimise the rate of surface water run off. Policy ENV6 Good Design in New Development 32) Criterion f of Policy ENV 6 states: Ensuring that the amenities of occupiers of the new development will not be adversely affected by neighbouring uses and vice versa. We suggest criterion f) of Policy ENV 6 is amended to state: Ensuring that the amenities of occupiers of the new development will not be adversely affected by neighbouring uses and vice versa. This will be most appropriately managed by locating sensitive uses away from other incompatible uses. We suggest the third paragraph of Policy ENV 6 is amended to state: The effects of climate change should be mitigated by the incorporation of energy and water efficiency in new and existing buildings, grey water and rainwater harvesting, measures to reduce surface water run-off and storage for waste and recyclables.

11 Appendix 2 Development of the Spatial Option and Strategic Sites Assessment Consultation with Infrastructure Providers 33) We suggest paragraph 1 on Page 196 is amended to state: The availability of infrastructure is another key aspect of deliverability. There are infrastructure issues in parts of the Borough, such as the capacity of the wastewater system and capacity of the local road network. The NPPF states that such barriers to investment should be overcome wherever possible, and that the Local Plan should be positively prepared so that the plan meets objectively assessed development and infrastructure requirements. Whilst noting the statutory obligations of some infrastructure providers, the site selection process should still be informed by meaningful discussion to take account of the availability of infrastructure and how the impact of development on infrastructure can be most appropriately managed. 34) We suggest paragraph 3 on Page 196 is amended to state: Wastewater treatment capacity is one issue for Fylde because it has an effect on bathing water quality. The Blackpool Periphery presents the most acute issues, as it is equidistant from the treatment works at Fleetwood and Freckleton and therefore, subject to the detail of the drainage proposals, is most likely to have a greater impact on wastewater infrastructure. 35) On page 198 in relation to H2 Land West of North Houses Lane, St Annes (housing), it states: Due to wastewater capacity issues, the site is phased towards the end of the Plan period. Development could start on this site in 2021 and be completed by We suggest this is amended to state: Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. In the context of the above amendment you may consider it appropriate to amend the delivery timescale. 36) On page 199 in relation to H3 Land North of Moss House Lane, St Annes (housing), it states: Infrastructure issues are the same as for H2, above. Likewise, an Appropriate Assessment will be required. In order to maintain a five year supply of housing land throughout the Plan period, and to enable upgrades to the wastewater network to take place, development on this site could start in 2026 and be completed in We suggest this is amended to state: Infrastructure issues are the same as for H2, above. Likewise, an Appropriate Assessment will be required. Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. In the context of the above amendment you may consider it appropriate to amend the delivery timescale.

12 37) On page 202 in relation to M1 Land east of Cropper Road (mixed-use), it states; Due to surface water issues, the site is phased towards the end of the Plan period. The housing element of this site could start in 2025 and be completed by We suggest this is amended to state: Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. In the context of the above amendment you may consider it appropriate to amend the delivery timescale. 38) On page 202 in relation to M2 Whyndyke Farm (mixed-use), it states: Although there is a current planning application on this site, there are surface water issues. Therefore it is anticipated that the housing element of this site could start in 2020 and be developed throughout the plan period and beyond. We suggest this is amended to state: Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. In the context of the above amendment you may consider it appropriate to amend the delivery timescale. 39) On page 205 in relation to H7 Land North of Dowbridge, Kirkham (housing), it states: In terms of wastewater infrastructure this site is sequentially preferable to the other sites in Kirkham and Wesham. Development could start in 2016 and be completed by We suggest this is amended to state: The impact on wastewater infrastructure is likely to be more appropriately managed by development of sites on the eastern side of Kirkham and Wesham. The impact on wastewater infrastructure can only be confirmed once greater detail is known. Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. In the context of the above amendment you may consider it appropriate to amend the delivery timescale, however, this may not be necessary given the original timescale for commencing development was assumed to be ) On page 205 in relation to H13 Land North of Mowbreck Lane, Wesham (housing), it states: In terms of wastewater infrastructure, development on this side of Kirkham and Wesham is sequentially preferable to sites on the west side, as it is closer to Clifton Marsh Wastewater Treatment Works. It would be useful to better understand the sequentially preferable reference in respect of this site in comparison with the sites on the west side. It may be more appropriate to state the following:

13 The impact on wastewater infrastructure is likely to be more appropriately managed by development of sites on the eastern side of Kirkham and Wesham. The impact on wastewater infrastructure can only be confirmed once greater detail is known. Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. 41) On page 206 in relation to H14 Land south of Weeton Road, Wesham (housing), it states: Wastewater infrastructure is more costly to implement for sites on the west side of Kirkham and Wesham, as it will need to connect to Clifton Marsh Wastewater Treatment Works at the east of the Borough. On page 206 in relation to H15 Land north of Weeton Road, Wesham (housing), it states: Wastewater infrastructure is more costly to implement for sites on the west side of Kirkham and Wesham, as it will need to connect to Clifton Marsh Wastewater Treatment Works at the east of the Borough. We suggest both sections are amended to state: The impact on wastewater infrastructure is likely to be more appropriately managed by development of sites on the eastern side of Kirkham and Wesham. 42) On page 208 in relation to M3 Land north of Blackpool Road, Kirkham (mixed use), it states: There are significant wastewater issues that need to be addressed for development to take place on this site. Therefore, although there is strong developer interest, it is anticipated that development could only start in 2020 and be completed by We suggest this is amended to state: Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy. In the context of the above amendment you may consider it appropriate to amend the delivery timescale. 43) On page 210 in relation to H8 Land west of Warton (housing) it states: There are wastewater infrastructure issues for this site. On page 210 in relation to H9 Land north of Warton (housing) it states: There are wastewater infrastructure issues for this site. On page 211 in relation to H10 Land east of Warton (housing) it states: There are wastewater infrastructure issues for this site. We suggest the above are all amended to state: Due to wastewater capacity issues, it will be necessary to carefully consider the impact on wastewater infrastructure in accordance with the content of policy.

14 44) On page 211 in relation to H11 Land NE of Warton (housing) it states: There are wastewater infrastructure issues for this site. We suggest this is amended to state: Due to wastewater capacity issues, if this site was allocated, it would be necessary to carefully consider the impact on wastewater infrastructure. 45) With respect the infrastructure delivery plan, we have suggested various amendments to the sections on water and wastewater. Our suggested amended version is enclosed for your review. Please do let me know if you wish to discuss in any further detail. Yours sincerely Andrew Leyssens Planning Manager United Utilities Encs.