Comment
Draft Local Plan
Representation ID: 16093
Received: 11/05/2016
Respondent: Essex County Council
Criterion a) - allowable brownfield discharge rates are confusing. Reference to discharge at current brownfield rates should be deleted.
Criterion b) - a drainage strategy should be submitted for any site over 0.1 ha
Criterion c) - current best practice now requires developers to use an index based approach when managing water quality rather than requiring a specific number of treatment. This section of the policy should be updated and should refer developers to chapter 26 of the updated CIRIA SuDS Manual for more information about this approach.
In addition, ECC would expect only the first 4-5mm of any storm event to be managed within the site. A requirement of 10mm may be considered too onerous for many developers to achieve especially onsite where infiltration potential is very low.
See attached