Response 35987268

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Angling Trust Eastern Region
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Proposal 1: To introduce a tiered approach for including schemes in the WINEP

Question 1a: Do you think the proposed 3TO will achieve a greater focus on outcomes.

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Existing measures to remove abstraction licences have been subjected to strong drawn out legal challenges. This whole process is only to get more challenged with the likelihood of more environment protection intervention measures. Clearly the existing WENIP is driven by the regulatory CAMS process and has not delivered the environmental protection our rivers so need. So to deliver any significant environmental change, it requires stronger drivers within the catchment scale on abstraction. The proposed changes don’t mention this as specific requirements.

Question 1b: How else can we support an ambitious move towards a greater focus on outcomes? For example: enabling water companies to propose a Tier 1 measure in their business plans.

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I believe the efforts being introduced by the focussed regional approach, should enable the long term ambition and needs. With outcomes from WENIP supporting the specific needs in the agreed regional plans. The is also a clear linkage between pollution and its dilution from available surface water.

Proposal 2: To better incorporate long-term planning in the development of the WINEP

Question 2a: Do you agree that introducing a 10+ year planning horizon will help to address the issues identified above?

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It may seem a simplistic approach, but why not have a single regional plan that every stakeholder can work within. We have started this with the regional structural planning, why not use this as the baseline long term agreed plan.

Question 2b: What are the key considerations in implementing a 10+ year planning horizon?

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We have some extremely challenging growth demands across England, this needs a long term strategic approach to infrastructure planning and delivery. These cannot be left to market demands on infrastructure.

Question 2c: What else could be done to better incorporate long-term planning?

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If the regional planning groups prove to be a successful model, consideration must be made that long-term planning and needs for WINEP must align.

Proposal 3: To clearly establish dependencies between the water industry national environment programme and other statutory planning frameworks

Question 3: What are your views of aligning the cycles of the strategic planning frameworks?

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As above, it may seem a simplistic approach, but why not have a single regional plan that every stakeholder can work within or to the same timescales. We have started this with the regional structural planning, why not use this as the baseline long term agreed plan. Clearly some regional planning teams are more advanced than others, but it could be introduced in a phased timescale between PR24 and PR29

Proposal 4: To increase the use of catchment and nature-based solutions

Question 4a: How well does the proposed draft WINEP methodology appropriately encourage consideration of catchment and nature-based solutions?

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Current deployed natural solutions like the one piloted in West Norfolk, are limited in scale and not suitable to industrial scale treatment works. Should further study be undertaken on scalable industrial solutions, linked to agriculture use of semi treated highly nutrient waste water. Which other counties like Israel adopt.

Question 4b: What are your views on the proposed principles for C&NBS?

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As above a sound approach, but needs scalability.

Proposal 5: To take account of wider environmental outcomes when deciding on solutions in the water industry national environment programme

Question 5: Will the draft methodology enable water companies to deliver wider environmental outcomes?

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It may well be the case that not all protected habitats can be secured if we continue wanting to support the growth of both population and growing the food it needs locally. The need for significant water storage reservoirs are a good example of this dilemma across East Anglian, but one 1000 hectare reservoir could save many 10 tens of other protected habitats further afield from over abstraction.

Proposal 6: To increase water company involvement in the water industry national environmental programme development process

Question 6a: What further steps need to be put in place to enable water companies to contribute more to the development of the WINEP for PR24?

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The local government development and regional planning needs to align to the needs of water infrastructure. Examples of this not currently working exists across East Anglian in both Cambridge and Norwich, let alone the Cam Ox Arc potential needs on water.

Question 6b: Do you think the ambition to have a WINEP developed by water companies by PR29 is achievable?

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Please explain the reasons for your answer.
With regulatory support.

Proposal 7: To increase involvement of other organisations and external funding in the water industry national environment programme development process

Question 7a: Will the proposed approach set out in the draft WINEP methodology, including the proposed timetable, be effective in increasing the involvement of other organisations in the WINEP for PR24?

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Please explain the reasons for your answer
As stated previously, the delivery of a set of regional plans by Aug 2022 is the start of a new approach. The structure of such groups with their multiple stakeholder engagement and members, should be a basis of future regional and catchment planning, setting agreed assumptions and demands at the catchment scale. It should have defined 5 yearly targets for future WINEP’s to deliver against.

Question 7b: Do you agree with setting a target for co-funding non-statutory actions?

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Please explain the reasons for your answer
Any public benefit is worthy of co-funding.

Question 7c: If you agree with setting a target, what level should a target this be set at? Please explain why you have suggested this target.

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Targets should be quite specific within the next WINEP period, with more generic measures meeting medium and long term ambitions and needs, aligned the agreed regional plan.