Dear Sir/Madam

BRENTWOOD LOCAL PLAN - PRE-SUBMISSION (REGULATION 19)

Thank you for the consultation on the Brentwood pre-submission local plan. Having reviewed the document, we find the plan sound. We have provided comments in regards to Responding to Climate Change, Water Efficiency, Water Quality, Ecology, Flood Risk, Sustainable Drainage and Contaminated Land where we feel the plan can be enhanced.

Responding to Climate Change

Policy BE01 - Future proofing - the local plan recognises the Borough is located within an area of Serious Water Stress with susceptibility to multi-season droughts, which coupled with climate change and continued growth places further importance on water resources. We would like to see consideration for proactive strategies for increasing water efficiency and conservation of water within new developments promoted in the plan.

Water Efficiency

Policy BE03: Carbon Reduction, Renewable energy and Water Efficiency - due to water pressures in the region and specifically the Borough of Brentwood, we consider it is particularly important that water efficiency measures are incorporated into development schemes and welcome their inclusion within the local plan.

Increased water efficiency for all new developments potentially enables more growth with the same water resources. Developers can highlight positive corporate social responsibility messages and the use of technology to help sell their homes. For the homeowner, lower water usage also reduces water and energy bills.

We endorse the use of water efficiency measures especially in new developments. Use of technology that ensures efficient use of natural resources could support the environmental benefits of future proposals and could help attract investment to the area. Therefore, water efficient technology, fixture and fittings should be considered as part of all new developments.

Policies should consider the use of water efficient systems and fittings such as dualflush toilets; water butts; water-saving taps and showers; and appliances with the highest water efficiency rating as a minimum.
Greywater recycling and rainwater harvesting should also be considered. We welcome the use of SUDS on the site, however, the ultimate destination of surface water drainage and its possible effects on the Water Framework Directive status of receiving waters should be considered.
Any submitted scheme should include detailed information (capacities, consumption rates, etc) on proposed water saving measures. Applicants should be encourage to follow guidance: http://www.water-efficient-buildings.org.uk/ ;
And http://www.savewatersavemoney.co.uk/ which provides further guidance.

Residential developments

All new residential developments are required to achieve a water consumption limit of a maximum of 125 litres per person per day as set out within the Building

Regulations (Amendment) 2015. However, we recommend that in areas of serious water stress as identified by the ourselves, a higher standard of a maximum of 110litres per person per day is applied and we are pleased to see this reflected within this local plan.

Commercial/Industrial developments
We note that for new non-residential development -the BREEAM standard of 'Very Good' has been set as a minimum for Water efficiency.
Given Brentwood is in a serious water stressed area, we would like to see a more ambitious target in line with future proofing developments against climate change and increasing demand for an seriously stressed resource, such as water.
Therefore, for new non-residential developments of 1000 square metres gross floor area or more we feel the BREEAM 'excellent' standards for water consumption should be applied.

Water Quality

SP01 has an extensive list of requirements and mentions avoiding pollution 'such as light, noise pollution, vibration, odour, smoke, ash, dust and grit' but does not mention wastewater and risk to the environment from this.

Point D (Development will be supported .....) could be strengthened by adding an additional bullet point to
say:
can be shown there is availability of sufficient wastewater treatment capacity in order to protect the water environment

Policy DE03: Water efficiency mentions the need for a 'water sustainability assessment'. This section also mentions wastewater and additionally a drainage strategy should be provided to demonstrate there is capacity in the sewage treatment infrastructure or how capacity will be provided in line with development.

We support policies BE18 (Green and Blue Infrastructure) and NE06 (Flood risk). Which include statements about protecting watercourses, and on capacity and phasing of wastewater treatment facilities.

Ecology

Policy BE18 - Following our previous comments on the wording around 'Poor or Moderate [WFD] Status' under section 5.152, we are happy with the wording in this revised document, stating that it is the current grade of the watercourses that are either Poor or Moderate and not that they are the only grade that will be considered.

Policy NE01 - We support the inclusion of multifunctional green and blue infrastucture. In particular we welcome the reference to the numerous benefits derived from natural spaces.

Identifying the requirement for ecological connections between sites and the restoration of ecosystems, ties in with the biodiversity net gain (BNG) principle. BNG is mentioned in this policy already as is working with Essex Wildlife Trust in 8.21

We are encouraged to see that habitat and species conservation and enhancement of non-statutory sites / species as well as statutory is included. It is also good to see that sites are being considered of local importance, not just national importance. Locally important sites should include Local Wildlife Sites.

Section D accounts for cumulative impacts as well as individual impacts when appraising development. Analysis of impacts on designated sites will be particularly relevant to this approach.

Policy BE01- We note that it mentions natural flood management (NFM) under 'Future Proofing'. As NFM is linked to blue and green infrastructure, it should be included under Policy NE01 as well.

As per our previous comments 'The supporting text in Policy NE01 could be enhanced by acknowledging the role played by natural flood management. Reducing flooding by working with natural process, reconnecting watercourses with floodplains to enhance flood storage in times of need, and taking opportunities to restore watercourses to a naturalised state. This should be considered and incorporated into developments wherever opportunities arise. As well as contributing to reducing flood risk, such schemes can enhance the blue infrastructure and contribute to enhancing biodiversity.'

Flood Risk

Policy NE06 - Point C

d. We feel clarify should be proivided in regards to 'strategic water storage' - Does this relate to compensatory storage.

f. Clarification is required in relation to 'safe areas' - does this mean, safe in regards

to appropriate refuge above the extreme flood level with climate change. If so this should be made explicit.

8.61 We feel the line where a site-specific Flood Risk Assessment (FRA) is required, this should be considered by and approved by the Environment Agency should be amended. The Environment Agency are a statutory consultee, we do not 'approve' the Flood Risk Assessment, we provide expert advice on its content.


Sustainable Drainage

Policy BE08 - We feel the Sustainable Drainage section could be enhanced by the inclusion of the following text in Section B point b (Quality) The design must follow the Environment Agency requirements:

1. Infiltration sustainable drainage systems (SuDS) such as soakaways, unsealed porous pavement systems or infiltration basins shall only be used where it can be demonstrated that they will not pose a risk to the water environment.

2. Infiltration SuDS have the potential to provide mobilise pollutants and must not be constructed in contaminated ground. They would only be acceptable if a site investigation showed the presence of no significant contamination.

3. Only clean water from roofs can be directly discharged to any soakaway or watercourse. Systems for the discharge of surface water from associated hardstanding, roads and impermeable Vehicle parking areas shall incorporate appropriate pollution prevention measures and a suitable number of SuDS treatment train components appropriate to the environmental sensitivity of the receiving waters.

4. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.

5. Deep bore and other deep soakaway systems are not appropriate in areas where groundwater constitutes a significant resource (that is where aquifer yield may support or already supports abstraction).

6. SuDS should be constructed in line with good practice and guidance documents which include the SuDS Manual (CIRIA C753, 2015), Guidance on the Construction of SuDS C768 and the Susdrain website.

7. Further information on the EA requirements with regard to SuDS can be found on the Groundwater protection position statements (2018), in particular Position Statements G1 and G9 - G13 available at:

https://www.gov.uk/government/publications/groundwater-protection-positionstatements
.
Section B point c (Amenity and Biodiversity)

We feel point iii. (Preferred hierarchy) could be amended as follows:

"and if these cannot be met, thirdly, to a surface water sewer, highway drain, or another drainage system and if these cannot be met, to a combined sewer."

The footnote at page 86 refers to the CIRIA manual, the year 2017 should be 2015.

Contaminated Land

Policy NE07 - In section A, point b, the word "local" applied to groundwater might be misleading: it is clear that it's intended for the groundwater underneath the site, but 'local' groundwater does not exist, i.e. contaminated groundwater migrates from a contaminated site and gets transported elsewhere for long distances before getting degraded (if this applies).

We feel you should consider rewording this policy in the following way 'there will be no adverse impact on the wider environment and quantity and quality of controlled waters (surface water and groundwater)'.

We trust this information is useful.

Yours faithfully

Mr. Pat Abbott
Planning Advisor