Stakeholder
Support/ Object/ Comment/Recom mend change/etc.
Comment Parish Council Consideration (in blue)
Amendment Number
2. Works to upgrade Kingsland WwTW may well take place in either AMP7 (2020-2025) or AMP8 (20252030) although this cannot be guaranteed at this point in time. 3. Kingsland WwTWs discharges into the River Lugg. It is understood that the current discharge levels for Kingsland WwTW is above the 1mg/LP that it is possible to achieve but well above the 0.1 mg/LP that will be sought in order to achieve Natural England's target to meet the Habitat Regulation's requirements for the River Wye SAC into which the River Lugg flows. Consequently, despite the small current capacity at Kingsland WwTWs there is a potential failure to meet the SAC requirements at the moment. As a consequence, it may be argued that Herefordshire Council would need to carry out an 'Appropriate Assessment' to determine whether any further development would have a 'significant effect' on the River Wye SAC. I also understand that Herefordshire Council and others have produced a Nutrient Management Plan (NMP) that aims to address this issue and therefore part of any 'Appropriate Assessment' might be to determine whether the aims of the NMP might be compromised by any planning decision now. 4. It is anticipated that the upgrade to Kingsland WwTW should be able to meet the required phosphate standard/target although the technologies necessary have yet to be trialled. 5. Again it would be for Herefordshire Council to determine whether any new dwellings added to the foul drainage system may have a 'significant effect' under the Habitats Regulations as a consequence of either/both the Neighbourhood Development Plan and/or any planning application given the current limited outstanding capacity. 6. Developers can contribute towards the upgrade of the WwTWs but you are unable to advise what level of contribution would be required even should works be able to be brought forward both within an appropriate timescale and sufficient for the SAC purposes. It is therefore difficult to assess whether any scheme would be viable and therefore deliverable within the plan period. 7. Any development served by Onsite Waste Water Treatment Works would need to be agreed with the Environment Agency and Herefordshire Council. One or both would need to consider whether this would increase diffuse pollution in the Lugg catchment and consequently scope the need for an 'Appropriate Assessment' and carry one out if there was any uncertainty. This would need to take into account other proposals in order to consider the 'in combination' effect and might include effect on the ability to deliver the NMP. It is considered that the provisions in Policy KNDP9 should provide appropriate safeguards although amendments to the supporting statements (paragraphs 4.10 and 4.12) are proposed. S.13
In addition to the representation to Policy KNDP14 covered under S.2 above, the following comments were made:
Kingsland Neighbourhood Development Plan – Consultation Statement (November 2015)
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