Comment

Preferred Site Allocations 2018

Representation ID: 18300

Received: 12/03/2018

Respondent: Essex County Council

Representation Summary:

Infrastructure Planning - Water

Full text:

Infrastructure Planning - Water -

BBC should note that both the Strategic Flood Risk Assessment (SFRA) and Water Cycle Studies (WCS) for Brentwood are now out of date.

There have been a significant number of changes in relation to flood risk, including revised climate change allowances and updates to the surface water mapping since Brentwood last updated their SFRA. As a minimum ECC recommends the production of an addendum to the SFRA to consider the impact these changes would have on the proposed sites within the Draft Plan. This should be followed up by a more detailed review of the document that can be used as an additional assessment when dealing with development that is submitted outside the local plan processes. Similarly ECC recommends that a review of the WCS is undertaken to ensure that issues relating to water supply and demand as well as the processing of waste water are fully considered as part of the Local Plan process.

ECC advise that the Surface Water Management Plans (SWMPs) are being reviewed and an addendum to the SWMPs will be published shortly. The review of the SWMP has taken place following updates to the criteria used to assess properties at risk of flooding. Key changes to the SWMP include revised Critical Drainage Areas (CDAs) and some changes to flood extents.

An impact analysis of the proposed new CDA boundaries on the preferred site allocations proposed in the current consultation has been undertaken, which indicates that, of the 47 sites (housing and employment) 14 are not within a CDA, and 1 site is only within an old CDA. 14 sites are within both the old and new CDA's, and there are 18 of the sites which now fall within the new CDA's. Details are set out below:

* Childerditch Industrial Estate (ref. 112A) - Not In CDA
* William Hunter Way car park, Brentwood (ref. 102) - In New Only
* Land at Alexander Lane, Shenfield (ref. 87) - In Both
* Wates Way Industrial Estate, Ongar Road, Brentwood (ref. 3) - In New Only
* Horndon Industrial Estate, Station Road, West Horndon (ref. 21) - In Both
* Westbury Road Car Park, Westbury Road, Brentwood (ref. 39) - In New Only
* Chatham Way/Crown Street Car Park, Brentwood (ref. 40 ) - In New Only
* Land at Hunter House, Western Road, Brentwood (ref. 41) - In New Only
* Council Depot, The Drive, Warley (ref. 81) - In New Only
* Land west of Warley Hill, Pastoral Way, Warley (ref. 83) - In New Only
* Land adjacent to Tipps Cross Community Hall, Blackmore Road, Tipps Cross (ref.085B) - Not In CDA
* Brentwood railway station car park (ref. 2) - In Both
* Sow & Grow Nursery, Ongar Road, Pilgrims Hatch (ref. 10) - In New Only
* Land adjacent to Ingatestone by-pass (part bounded by Roman Road, south of flyover) (ref.079A) - In Both
* Land south of Redrose Lane, north of Woollard Way, Blackmore (ref. 77) - Not In CDA
* Land south of Redrose Lane, north of Orchard Piece, Blackmore (ref. 76) - Not In CDA
* West Horndon Industrial Estate, Childerditch Lane, West Horndon (ref. 20) - In Both
* Land at Honeypot Lane, Brentwood (ref. 22) - In New Only
* Land off Doddinghurst Road, either side of A12, Brentwood (ref. 023A) - In New Only
* Land east of Nags Head Lane, Brentwood (ref. 32) - In New Only
* Officer's Meadow, land off Alexander Lane, Shenfield (ref. 34) - In Both
* Land at Priests Lane (west), Brentwood (ref. 44) - In Both
* Land adjacent to Carmel, Mascalls Lane, Warley (ref. 27) - In New Only
* Land adjacent to Ingatestone by-pass (part bounded by Roman Road) (ref. 079C) - In Both
* Ingatestone Garden Centre, Roman Road, Ingatestone (ref. 128) - In New Only
* Land East of Horndon Industrial Estate (ref. 152) - In New Only
* Land North of A1023 Chelmsford Road, Shenfield (ref. 158) - In Both
* Land at Priests Lane (east) adjacent Bishops Walk, Brentwood (ref.178) - In Both
* Land at Crescent Drive, Brentwood (ref. 186) - In Both
* Land south of East Horndon Hall (ref. 187) - Not In CDA
* Childerditch Industrial Estate (ref. 112D) - Not In CDA
* Brizes Corner Field, Blackmore Road, Kelvedon Hatch (ref. 194) - Not In CDA
* Site adjacent to Ingatestone Garden Centre (former A12 works site) (ref. 106) - In New Only
* Land to the north of Alexander Lane, Shenfield (ref. 235) - In Both
* Land east of Chelmsford Road, Shenfield (ref. 263) - In Both
* Oak Hurst, Chelmsford Road, Shenfield (ref. 276) - In New Only
* Chestnut Field, Backmore Road, Hook End (ref. 294) - Not In CDA
* The Eagle and Child Public House, Chelmsford Road, Shenfield (ref. 311) - In Both
* Ford Warley - Northern Site (ref. 117B) - In New Only
* Ford Warley - Southern Site (ref. 117A) - Not In CDA
* Land off Stocks Lane, Kelvedon Hatch (ref. 075B) - Not In CDA
* Childerditch Industrial Estate (ref. 112E) - Not In CDA
* Brentwood Enterprise Park (M25 Works Site at A127/M25 junction 29) (ref. 101A) - Not In CDA
* Land off Doddinghurst Road, either side of A12, Brentwood (ref. 023B) - In New Only
* Codham Hall Farm (ref. 101C) - Not In CDA
* Codham Hall Farm (ref. 101D) - Not In CDA
* Dunton Hills Garden Village (ref. 200) - In Old Only

As a result ECC recommends that any changes arising from the SWMP review will need to be taken into account and inform the preparation of the pre-submission plan.

ECC recommends site specific policies relating to each of the sites that are now within CDA areas. Some suggested working is set out below:

The site is located within a Critical Drainage Area (CDA). This development may have the potential to impact on the CDA in respect of surface water flooding. As a result of this the site is likely to require an individually designed mitigation scheme to address this issue.

ECC advises that it is not clear whether the flood extents within the original SWMP documents have been used for determining surface water flood risk on the preferred site allocations or whether BBC have used the Environment Agency's Risk of Flooding from Surface Water Flood map. If the original SWMP extents have been used then further analysis will be necessary to understand the impact that this will have on the proposed housing and employment allocations.

ECC as Lead Local Flood Authority has provided comments throughout the Draft Local Plan process to ensure the delivery of Sustainable Drainage Systems to provide water quality, amenity and ecological benefits. ECC seeks further discussions with BBC to ensure its Local Plan policies comply with ECC requirements.

The adopted ECC Sustainable Urban Drainage Systems (SuDs) Design Guide should form part of the Plan making process, both in terms of policy formation and supporting evidence base work.