Comment

Draft Local Plan

Representation ID: 15532

Received: 10/05/2016

Respondent: Environment Agency

Representation Summary:

We support this policy but consider it would benefit from a reference to applying a sequential approach within sites, as well as them passing the requirements of the Sequential Test. This will ensure that more vulnerable development is directed to lower risk areas of a site, especially on mixed use development sites. It also can direct open space to higher risk areas, allowing an integrated approach to open space, recreation and flood risk management. More emphasis should be placed on enhancing existing flood management systems rather than focussing purely on managing flood risk to and from new development. We would encourage you to liaise with Essex County Council as Lead Local Flood Authority to identify potential opportunities to reduce and manage surface water flooding.
This policy could be improved by having some supporting text that further explains what is meant by resistant and resilient design means.
It could also benefit from mentioning (if not within a new policy) the need to ensure that development does not prevent flood risk management now or in the future. This is particularly important to us, as we often access to watercourses for example to exercise our permissive powers. In addition, space should be safeguarded for future defence raising.

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