Agenda item


            The Chief Executive submitted for the Committee’s approval the Council’s draft response to the Living With Water in Belfast consultation document, which would inform the overall Strategic Drainage Infrastructure Plan for Belfast. Representatives of the Living With Water Programme had attended the Committee meeting in October to review the consultation document and had presented it to each of the four Area Working Groups in early January. The Council’s draft response had been informed by the discussion at those meetings.


            She pointed out that the following deputation from the Department for Infrastructure and NI Water was in attendance in order to provide a presentation on the issues raised within the Council’s response and wider capacity issues within Belfast:


·        Ms. L. MacHugh, Acting Deputy Secretary, Department for Infrastructure;


·        Ms. S. Venning, Chief Executive, NI Water;


·        Mr. S. Richardson, Living With Water Programme Director, Department for Infrastructure; and


·        Mr. P. Brow, Head of Living With Water, NI Water.


            The Committee was informed that the current Minister for Infrastructure was fully committed to the Living With Water Programme, as a means of delivering a new, strategic, long-term approach to drainage and wastewater management to protect from flooding, provide a cleaner and greener environment and ensure that Belfast was open for business and investment.


            It was reported that the Living With Water in Belfast consultation period had closed on 29th January and that twenty-seven responses had been received to date, the majority of which had been supportive of the proposals set out within the document. A number of organisations, including the Council, had been granted additional time in which to submit their response. The next steps in the process were outlined and it was anticipated that Executive approval of the final plan would be secured in May/June.


            In terms of funding, it was estimated currently that £1.4 billion would be needed to deliver all elements of the integrated drainage proposals over the next twelve years and the point was made that capital funding for NI Water had not, for some time, kept pace with Northern Ireland’s needs.


            The Committee was provided also with details on the findings of the annual review of the capacity of waste water treatment works for Belfast for 2020 and on a risk mitigation plan which had been implemented in October, 2020. The presentation concluded by referring to a waste water system capacity constraints map for Belfast and outlining the measures which NI Water had put in place to mitigate those constraints.


            The deputation was thanked by the Chairperson, following which the Committee noted the information which had been provided and approved the following response to the Living With Water in Belfast consultation:


Strategic Drainage Infrastructure Plan –

Consultation Response


General Comments


Belfast City Council welcomes the opportunity to respond to this strategic consultation.  Long term investment in drainage and waste water infrastructure is required to meet the ambition for growth of the City and to alleviate the impacts of climate change.


We support the adoption of an approach to the provision of drainage and wastewater infrastructure which promotes holistic and integrated solutions that achieve multiple benefits at reduced cost and disruption. Whilst it is recognised that significant investment will be required in more traditional ‘hard engineered’ infrastructure we welcome the acknowledged contribution that other sustainable measures such as Green and Blue Infrastructure and Sustainable Drainage Systems (SuDS) can deliver. This sustainable approach is supported by both the Local Development Plan (LDP) as set out in the Draft Plan Strategy vision, aims, objectives and policies as well as in the council’s Green and Blue Infrastructure Plan.


With regard to the draft SDIP strategic context we welcome that it acknowledges (para 2.19, pg 23) that LWW and investment plans must contribute to the delivery of the Local Development Plan and Belfast Agenda as well as the council’s Green and Blue Infrastructure Plan, Open Space Strategy and Resilience Strategy.


It is noted that the document (para 4.16-4.17, page 51) makes reference to the growth aspirations as set out in the Belfast Agenda and indicates that their delivery could be impacted by the lack of capacity in the sewerage network and WwTWs. However, the Council welcomes that the SDIP clearly states that NI Water will honour their existing commitments to provide connections for previously approved applications (para 4.18, pg 51). Whilst the document is not able to define the precise quantum of connections to which this relates, the LDP monitoring data which has been shared with NI Water set out the estimates for dwellings units and commercial floorspace with planning approvals to inform that baseline position. In addition it was highlighted that additional commitments for other uses such as hotels and purpose-built managed student accommodation (PBMSA) needed to be recognised.


The extent of housing need/stress that exists within the City has been known for some time.  Meeting that need is a priority for the City, recognised by a range of stakeholders.  Accordingly NIW should be providing the necessary investment on a priority basis to ensure that that need can be met.


Whilst NI Water has indicated (para 4.18, pg 51) that without investment it may have to refuse new connections and that negative planning consultation responses may have to be provided it should be recognised that there is a criteria based assessment process under which new connections can be assessed to take account of past and extant consents. It is therefore considered that there is scope to avoid this scenario and it is vital that this is articulated in the document as a caveat alongside with the recognition that negative responses would absolutely only be as last resort.  Innovation and local solutions should also be pursued where possible.


The phased approach as outlined in the Plan’s strategic programme (pg 140) indicates that Belfast WwTW Phase 0, which is intended to provide an initial increase in capacity to permit positive responses to planning application consultations, is a committed/urgent project. Although delayed this should, by April 2023, allow some parts of the wastewater capacity constrained areas, as illustrated on the map on page 51, to be reassessed. In addition the potential for the majority of constraints to be removed by 2026/27, subject to funding, is also welcomed. This is well within the life of the LDP.


The timeframes suggest that there could potentially be a window within which there will be an increased possibility of negative consultation responses to planning applications. However, following discussions with NI Water and further clarification it is understood that the company are actively working to avoid this scenario through the consideration and development of a range of mitigation measures including:


·        separation of storm and wastewater in new developments (to reduce the ‘load’ generated);


·        increases in on-site storm water storage and SuDS to reduce impact during high levels of rainfall (where pressure on the system is at its highest);


·        recognising and taking account of the existing permitted development and discounting it from proposed new developments;


·        extensive pre-engagement with developers prior to applications being submitted;


·        accepting the potential for like for like development; and



·        utilising conditions/ informatives on consents highlighting that connection is not likely until 2023 or after.


The SDIP must reflect this potential mitigation and the proactive approach that can be brought forward in collaboration with the council as the planning authority. 


The ambition of the comprehensive bid to deliver the Plan is recognised as challenging and it is considered as imperative that there should be clear prioritised investment for the LWWP elements that can be delivered in a phased manner should there be an inability to confirm the full capital allocation. This should clearly address what the priorities are to support the continued growth of the economy and any potential short term constraints – in recognition of the under investment that has occurred during the period of programme planning.


The priority status for the SDIP is supported by the NI Executive in the New Decade, New Approach document (January, 2020) where under the immediate priority of ‘Investing for the future’ (pg 8) it is stated that the Executive will “invest urgently in wastewater infrastructure which is at or nearing capacity in many places across Northern Ireland, including Belfast, limiting growth’. Furthermore, ‘New Decade, New Approach’ goes on to state (pg 52) that under the UK Government financial and economic commitments to Northern Ireland the Executive will benefit from increased capital infrastructure investment as a result of the UK Government’s infrastructure revolution and cites that “Essential sewage investment (LWWP)” as a capital project that will benefit from the funding. This concept of needing to ‘turbo-charge’ our infrastructure is further endorsed by the Ministerial Advisory Panel on Infrastructure in their October 2020 report ‘Turbo-charging Infrastructure to deliver cleaner, greener, sustainable and inclusive growth for all’. 


Furthermore, Belfast must play a specific role as a driver for the regional economy as has been acknowledged in the Regional Development Strategy.  Investment in Belfast is needed to sustain development in the city which will support growth in the region as a whole.  As Northern Ireland’s first and largest city, its development still lags some way behind contemporary European cities.  Accordingly investment in infrastructure needs to be prioritised in order to sustain growth, with a much wider collateral regional benefit.


The Council, therefore, welcomes the commitments as outlined regarding the need for urgent capital investment in water infrastructure however the Council believes that funding allocations to the sewerage system for Belfast should be commensurate with the current problems created by under investment to ensure that the city can play its full role as regional driver for the economy of NI, as set out in the RDS.


The Council recognises that a partnership approach is required to address the drainage infrastructure challenges Belfast is currently experiencing. The Council will therefore continue to work with the Living with Water team, NI Water and key stakeholders to support the development and delivery of the sustainable drainage solutions that will help deliver the shared visions for the city.  We urge the Department to continue this approach through the planning and implementation stages of this programme.  This partnership approach should not only be between NI Water, DfI and BCC, but recognise a number of other key partners in the city who own substantial areas of land that will also be integral to the successful implementation of this programme including the Northern Ireland Housing Executive, the Education Authority, the National Trust.  The Council would also highlight the need to engage with private landowners in looking at options.


The Council welcomes the close working relationship that it is has developed with the Living With Water Team and the Department in terms of the delivery of key projects under the SDIP including pilot projects which are being brought forward at Ballysillan Paying Fields (extending the river floodplain) and the proposed installation of leaky dams at Belfast Castle and at Forth River as part of the Council’s Peace IV funded Forth Meadow Community project and would like to build on this going forward in the development and delivery of other key projects. 


QUESTION 1: Do you agree that Belfast is facing significant drainage and wastewater management issues?




With Greater Belfast being the largest population and economic driver of Northern Ireland, it is vital that the challenges of flooding, barriers to development and the resulting impact on the community and economy are effectively addressed through long term solutions addressing climate change and much needed sustainable growth.


Climate change and the ambition for growth should be features which are considered in the development of an investment and infrastructure plan that sits parallel with the ambitions set out in the LDP.  The resilience of the city to absorb shocks, whether they be environmental or economic, requires robust and integrated planning.


Appropriate infrastructure is a fundamental enabler of Northern Ireland’s construction industry and any future growth ambitions. NI Water recently noted that 70 per cent of its network is over 50 years old and it has a legacy of underinvestment.


Whilst the injection of the £164m Belfast Sewers Project back in 2010 has had a positive impact on wider system, it is not in keeping with the pace of investment and development in Belfast. Alongside this, the sewerage networks were designed as combined systems with both sewage and surface water flowing through the same pipes. The further separation of systems for dealing with sewage and surface water should be prioritised in terms of infrastructure development for the future as rainwater is currently pumped and treated unnecessarily. Excessive rainfall can overload the system resulting in flooding and pollution. The need for Combined Sewer Overflows are necessary to manage the flow of surface water and sewage appropriately. The provisions are clear within the Water Framework Directive (WFD) and the Urban Waste Water Treatment Directive sets minimum standards for the collection, treatment and discharge of urban waste water and controlling the state of the water environment. Both directives have a responsibility to protect water ecology, biodiversity and seek to protect against flood risk by determining the level and types of capital infrastructural investment that is necessary to alleviate the problem which will in turn have a multiplier effect for economic and environmental benefit.


The Belfast Agenda sets out a vision for Belfast in 2035 with an ambitious aspirations of increasing the population with an additional 66,000 residents to include 33,000 new homes and 46,000 additional jobs and 1.5m square feet of additional Grade A office space. This highlights the importance of appropriate sustainable development to make the city competitive and to connect people to opportunities. Fundamental to creating the conditions for and enabling this inclusive growth, is infrastructure. The Belfast Agenda also recognises that there are gaps in Belfast’s key infrastructure which must be addressed if the city is to grow. The Agenda identifies that infrastructure planning and investment for Belfast needs to be taken forward in a strategic and integrated way and a core goal of the Agenda is to create a partnership and plan for sustainable urban infrastructure.


The infrastructure investment should be targeted to release the greatest economic potential and support inclusive economic development that provides the opportunity to sustainably increase GVA, and the ability of the region to compete internationally. The Council would therefore re-iterate that funding allocations to the sewerage system for Belfast should be commensurate with the current problems created by under investment to ensure that the city can play its full role as regional driver for the economy of NI.


The Belfast Resilience Strategy identifies the central importance of infrastructure to the city’s economic and climate resilience and includes a number of recommendations for reform, in particular the importance of integration of infrastructure, and of systems efficiency. The strategy was developed following detailed analysis of what works in similar cities. A key learning from this analysis is the importance of good infrastructure in attracting capital to ensure sustainable funding models over the short and long term.


It must also be noted that, until the LWWP is fully implemented, existing partnership engagement remains critical to plan, respond and recover from the flooding risks which are faced by the City.  Such linkages include for example Belfast City Council’s Emergency Plan, Belfast Emergency Preparedness Group (Multi-agency Partners) and the Regional Community Resilience Group (Multi-agency Group focused on promoting and supporting resilient communities). 


The risks posed to Belfast from tidal inundation, particularly in the City Centre are sobering – Belfast Tidal Flood Alleviation Scheme with 8.6km of new flood defences seeks to address this, however the scheme is complex with lots of engagement with different land owners required. This is taking longer to deliver than initially envisaged. This is only one scheme, so in order to implement the LWWP and integrated plan huge emphasis must be placed on delivering a collaborative approach by all partner agencies.


QUESTION 2: Do you agree that we need to change the way we manage water flowing through our urban areas?



The document adequately sums up the main issues, concerns and challenges of managing water flowing through urban areas.  The need to do things differently is encouragingly recognised - we believe it is essential to overcome the significant challenges waste water brings to Belfast.  It is imperative that key partners work together to provide a sustainable and integrated approach to drainage, using a catchment-based approach in line with contemporary best practice.


The Council would note that many of the proposed projects within the consultation impact on Council assets. As highlighted the Council is working closely with the Department on a number of pilot projects and will be playing a key role in terms of delivery moving forwards.  For projects to be successful the Council urges that these need to be co-designed with early input from specialists and planned with partners and stakeholders taking account the following important areas:


·        Meaningful engagement with local communities including park users, local residents and stakeholders e.g. sports clubs;


·        Understand current site usage, feasibility and commerciality;


·        Open space typology, functionality and ensuring a balance of local needs;


·        Existing natural environment including current ecosystem services benefits and constraints such as Invasive Alien Species (IAS);



·        Current and future management and maintenance requirements and costs. Depending on proposals this could include the need for new machinery, additional staff resources and management of increased invasive species; and


·        Early ecological input is required to maximise opportunities.  We encourage the implementation of natural flood management (NFM) that protects, restores and mimics the natural functioning of rivers and the coastal ecosystems.


Belfast has a paucity of open water and many rivers and streams have been partially or almost fully culverted.  The use of NFM will enable the restoration and creation of riverine and coastal habitats which are key priorities to address biodiversity loss. 


The LWWP and integrated plan provides a major opportunity to address broader environmental issues but most especially a unique opportunity to contribute to nature recovery in Belfast.


QUESTION 3: Do you agree that during periods of heavy rain, green spaces in urban areas should be used to hold water on a temporary basis to help prevent the flooding of homes and businesses and help prevent sewage spilling into the City’s rivers and Belfast Lough?



Belfast benefits from a wide range of open spaces, covering around a quarter of the city’s total area i.e. approx. 2,390 hectares (ha). Belfast City Council have developed a Belfast Open Spaces Strategy (BOSS) in collaboration with a range of partners and stakeholders, which includes the agreement of a long-term vision, seven guiding strategic principles (SPs), a range of opportunities and headline actions, which complement the integrated solutions proposed within the LWW in Belfast Integrated Plan. Of particular relevance within the BOSS is ‘Strategic Principle 5 – Increase resilience to climate change’ and ‘Strategic Principle 6 – Protect and enhance the natural environment’. Given our concerns regarding the threats posed by climate change and biodiversity loss, we believe that our open spaces can play an important role in increasing the city’s resilience to climate change and we would be keen to work in partnership to create and enhance natural habitats.  As part of Council’s community planning duty, we will continue to work with partners, stakeholders and local communities to develop area based plans and interventions which will include improving the provision, accessibility and quality of our open space network.  Protecting, improving and enhancing our open spaces is vitally important to meet growing demand. 


The document makes reference to mainly Council owned green space along with some other public owned green space e.g. Colin Glen and Stormont.  We feel it is important that all other public and private owned green spaces are also considered.  We would recommend that each proposal is assessed on a case by case basis at a site level, providing solutions for local areas, making sure that physical delivery is carefully designed and planned, taking account of the following key areas:


·        Early Council input to influence and shape the opportunities and proposals across the Council sites identified and a flexible iterative approach in conjunction with users;


·        Meaningful engagement with local communities including park users, local residents and stakeholders e.g. sports clubs;


·        Current site usage, feasibility and commerciality;


·        Open space typology and functionality - ensuring a balance of local needs;


·        Existing natural environment including current ecosystem services benefits and constraints such as Invasive Alien Species (IAS); and


·        Appropriate financial impact assessments carried out to identify and agree current and future management and maintenance arrangements and budgets put in place to support this prior to development. Depending on proposals this could include the need for new machinery, additional staff resources and management of increased invasive species.


In light of the key areas above the Council welcomes the opportunity to work closely to influence and shape the opportunities and proposals outlined across the Council sites identified. We would also stress that physical delivery at the local levels needs to be carefully developed and designed.


The potential savings in substituting hard engineering solutions with green and blue infrastructure development are huge. Although the ‘step change’ to blue and green infrastructure development has begun it will require an integrated and holistic approach from a wide range of public and private partners and stakeholders. Belfast City Council (BCC) launched a Green and Blue Infrastructure Plan (GBIP) for Belfast in 2020 which outlines how vegetated areas (the green) and waterways (the blue) can provide a broad range of economic, social and environmental benefits in and around our more urban areas.


The GBIP recognises that these natural and semi-natural assets are increasingly seen as ‘infrastructure’ and like any type of infrastructure, these assets will only continue to provide us with benefits if we actively plan, invest in and manage them to ensure that they are utilised sustainably. To do this, it sets a vision that by 2035, green and blue infrastructure will be strategically planned to enhance ecosystem services that benefit everyone visiting, living and working in Belfast. This now provides a solid foundation for progressing the Living With Water Programme approach across the plan area. Furthermore, there are obvious community cohesion and wellbeing benefits to be derived from investing in the development and expansion of blue and green infrastructure that serve as greenways and open spaces; a catalyst for increased biodiversity, and more active and sustainable travel.


The Council, working alongside key partners, has already demonstrated the success of taking such an approach in terms of the use of urban green areas to prevent flooding through the exemplar £40m Connswater Community Greenway project in the East of the city.  East Belfast had a history of severe flooding. The 2007 flood was the largest on record with 340 flooded properties within the catchment of the Loop, Knock and Connswater rivers. Consequently, a number of at risk areas were identified where flood alleviation measures were necessary. In 2006 funding was secured from the Big Lottery’s ‘Living Landmarks Programme’ to develop and build a 9km linear park scheme. It became apparent that construction work for the flood works and the park could be combined. Because both proposals involved works along the same river corridors there were many areas of overlap which allowed the project to be designed in such a way that it created both an enhanced urban asset and provided flood alleviation measures. This joined-up approach minimised disruption to local communities and businesses affected by the works and delivered better value for money. It also meant that the scheme provided 1,700 properties within East Belfast with the national standard of flood protection against fluvial and tidal events. 


The Council is already working closely with the LWW on a number of projects across the city including pilot projects at Belfast Castle, Ballysillan Playing Fields and the new Forth Meadow Community Greenway project and would welcome the opportunity to work closely with the LWW Team on identifying other projects in the city which could present opportunities for joint working. 


QUESTION 4: Do you agree with the catchment based approach to address drainage and wastewater management problems?



A more strategic approach to natural management of rainwater is welcomed, and use of a catchment based system enables collaborative partnership working to explore opportunities and address potential problems in a bespoke manner, tailored to each catchment.  More effective rainwater management will reduce the impact on wastewater infrastructure in general, reducing peak pressures thereby reducing the likelihood of release of untreated sewage into Belfast lough.


The implementation of NFM systems will help protect, restore and mimic the natural functioning of river and the coastal ecosystems.  Soil and land management are key areas that should be addressed at the catchment level including enhancing soil structure, soil compaction and supporting sustainable agricultural practices to deliver broader ecosystem services.


We note that the Newtownbreda WwTW is missing from the plan and there are significant residential developments in the Newtownbreda area and Saintfield Road, which are currently under construction.  Although this is not part of Belfasts City Council’s LGD as it forms part of Lisburn and Castlereagh City Council, the outfall of the WwTW is just upstream of the Stranmillis Weir and it serves a major urban area with the Belfast Metropolitan Area.  We ask that consideration is given to including the Newtonbreda WwTW in the programme.


QUESTION 5: Do you agree that we have identified all of the pressures and issues and set the correct objectives for each study area, as set out in chapters 7 – 10?


As noted, the Council is working closely with the Team in relation to the proposed projects within each of the catchment areas and would like to ensure that this close working relationship continues.  In relation to the pressures, issues and objectives the Council would be keen to see the detail including the process and data sets used to identify these. We also found it difficult to comment on specific issues, pressures and objectives due to the limited detail, data and information provided. A summary of some of the issues/ constraints for further consideration within the study area includes the following:


·        Limited reference to invasive alien species (IAS), erosion, aquatic alien invasive species, water quality issues and tidal surge mentioned throughout the study areas;


·        The need for meaningful engagement/ involvement of all partners, stakeholders and users at very early stage of design and also throughout physical delivery;


·        All open spaces have a typology and functionality and offer something for all users – need to balance this very carefully in terms of scale and impact within design proposals;


·        Risk implications for people living near or at waterbodies; and


·        Potential long term financial implications and pressures (i.e. management and maintenance budgets) of the proposals for Council and ultimately the rate payers of Belfast.


The Council does not have any specific comments in relation to the pressures in the individual study areas but would note as above that the implications of the Newtownbreda WwTW not being included.



Blackstaff Study Area



Connswater and Lagan Embankment


Study Area



North Foreshore Study Area          



Inner Belfast Lough Study Area (WwTW)



QUESTION 6: Do you agree that we have identified all of the opportunities for integrated drainage measures for each study area, as set out in chapters 7 - 10?



The Council agrees, in principle, with the concepts identified for integrated drainage measures for the study areas,  The Council is one of the biggest landowners in the city as outlined above. In addition the Council has one of the largest capital programmes underway across the city.  This therefore places the Council in a unique position in terms of looking at potential opportunities alongside the LWW Team. The Council also notes that potential solutions does not necessarily need to be close to the issue and therefore this presents opportunities across the city. 


The Council would note that many of the opportunities identified within the consultation to overcome the pressures and deliver on the objective propose the use of Council assets.  The Council would however note that many of these are still conceptual and the Council therefore welcomes the opportunity to engage with the Team on these from the outset.  


The Council believes that there are a number of potential other opportunities as outlined below.  We would however highlight that this is not exhaustive and the Council would request that there are continued opportunities to take this under review as other projects are agreed across the city – either Council led or other partner lead projects.  We would recommend that the following key principles are considered prior to the development and delivery of proposals within Council sites;


·        Consultation and engagement with local communities and users at the local level – to ensure buy-in;


·        Early Council input to influence and shape the opportunities and proposals across the Council sites identified and a flexible iterative approach in conjunction with users; and


·        Appropriate financial impact assessments carried out to identify future management and maintenance arrangements agreed and budgets in place to support this prior to development.


In addition, the Council would urge that any new developments should be required to meet certain standards to ensure no flooding issues would arise, similar to green field runoff


Blackstaff Study Area


The Council would welcome the inclusion of a potential SUDs scheme at Distillery Street.  The Council is already working with a range of statutory partners in bringing forwards proposals for an underused piece of land at the bottom of Distillery Street including LWW.  This provides an opportunity to build on the works already underway as part of the Forth Meadow Community Greenway proposals.

Connswater and Lagan Embankment



Study Area



North Foreshore Study Area


Within the North Foreshore study area, the North Foreshore/ Giant’s park isn’t mentioned, which is one of the biggest open spaces in the city, with potential for opportunities i.e. water attenuation and habitat enhancement. The Council would be keen to work in partnership to identify additional opportunities for habitat restoration, access and recreation potential.  The Council would therefore request that the North Foreshore is included and would welcome an opportunity to discuss this in greater detail with the Team.

Inner Belfast Lough Study Area (WwTW)





QUESTION 7: Do you agree that the proposed measures adequately address the pressures and issues and meet the objectives for each study area, as set out in Chapters 7 - 10?

Yes in principle, please see responses to Question 5 and 6 above.


Blackstaff Study Area



Connswater and Lagan Embankment Study Area



North Foreshore Study Area



Inner Belfast Lough Study Area (WwTW)




QUESTION 8: Do you agree that the levels of investment identified within this plan are necessary and should be considered a high priority by the NI Executive?



Whilst the levels of investment are significant in this draft programme, we feel that it is absolutely necessary to address the critical problems with drainage in Belfast.  Belfast City Council believes that a funding model is pivotal to the success of this plan.  Whilst we agree with the general approach and believe it can provide the long term, sustainable solutions needed, nothing can be delivered without a fully funded financial model that is agreed by the NI Executive.  Given the urgency of the situation, this must be agreed from the 2021 financial year. 


Whilst we understand the difficult financial situation, we ask that the Executive recognise the urgency of this matter and commit to fully funding the proposals contained within the programme. The Council would re-iterate that funding allocations to the sewerage system for Belfast should be commensurate with the current problems created by under investment to ensure that the city can play its full role as regional driver for the economy of NI, as set out in the RDS.


In relation to the catchment areas, we would also recommend that a detailed financial impact assessment of each area is carried out as part of the finance and delivery section of the plan. This will identify future management and maintenance arrangements that need to be put in place, as a result of the proposals and appropriate budgets to be established to support this prior to development.  Depending on detailed proposals additional costs for Council will include the need for new machinery, management of IAS, additional staffing and resources and capacity building, to name but a few.  These costs must be considered as part of the overall financial model.