Local Plan 2015-2030 Preferred Options for Consultation

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP2: Managing Growth

Representation ID: 860

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We advise that this policy would benefit from the inclusion of the text set out in italics below:

"c. Areas where development should not take place (eg. undeveloped Green Belt, land valuable for food production or at risk of flooding or of high landscape value, or nature conservation areas)."

We consider this to be beneficial to emphasise the importance of minimising impacts on biodiversity as set out in paragraph 109 of the National Planning Policy Framework.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP4: West Horndon Opportunity Area

Representation ID: 861

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We welcome the proposed masterplanning. This should allow flood risk to be considered early on and ensure that development is located in areas at lowest risk of flooding. Some areas of West Horndon are at risk of fluvial flooding from the 'Field House Sewer'. It is recommended that a sequential approach is taken, with development directed to areas of low risk, to accord with the principles of the National Planning Policy Framework.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP14: Sustainable Construction and Energy

Representation ID: 862

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We note that the Council expects all development to achieve a minimum of Code for Sustainable Homes Level 3. The Plan states that the Brentwood Scoping and Outline Water Cycle Study (2011) identifies the Borough as lying within an area of Serious Water Stress. Due to water pressures in the region we consider it is particularly important that water efficiency measures are incorporated into new developments.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP17: Provision of Infrastructure and Community Facilities

Representation ID: 863

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We are supportive of this policy, which requires "all development to meet on and off-site infrastructure requirements" and paragraph 3.78 in the justification of this policy indicates that foul water sewerage is included under the term 'Infrastructure'. However, we recommend that reference is made to the Water Framework Directive in the supporting justification text to ensure that it is taken into account and can be used to justify protection or enhancement of the water environment, where possible.

Full text:

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Support

Local Plan 2015-2030 Preferred Options for Consultation

Policy DM1: General Development Criteria

Representation ID: 864

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We consider this policy would benefit from the addition of the text set out in italics below:

i. Result in no increase in flood risk on site or off site.
This policy seeks to cover general development criteria. We consider it important that flood risk is included to ensure that this policy is consistent with paragraphs 99 and 100 of the National Planning Policy Framework and that it can be considered 'sound'.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy DM17: Wildlife and Nature Conservation

Representation ID: 865

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We are supportive of this policy which seeks to promote enhancement, restoration and, where appropriate, creation of new habitats.

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Support

Local Plan 2015-2030 Preferred Options for Consultation

Policy DM32: Provision of Green Infrastructure

Representation ID: 866

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

We are supportive of this policy and its approach to providing multi-functional green space, which can include benefits for flood risk and biodiversity.

Full text:

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Object

Local Plan 2015-2030 Preferred Options for Consultation

Policy DM35: Flood Risk

Representation ID: 867

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

Supportive of the inclusion of a flood risk policy, but consider amendments [as attached] are necessary to ensure the policy complies with the NPPF.

3rd paragraph of policy should be re-worded [see attached for wording]

Rewording is necessary to ensure that only Essential Infrastructure which can pass the Exception Test, and Water Compatible development, is allowed in Flood Zone 3b (functional flood plain). This change will ensure the policy is consistent with Table 3 of the Technical Guidance to the NPPF and therefore 'sound'.

This policy would also benefit from an addition to the text [see attached]

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Support

Local Plan 2015-2030 Preferred Options for Consultation

Policy DM36: Sustainable Drainage

Representation ID: 868

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

Supportive of this policy to promote use of SuDS following the preferred hierarchy of surface water drainage. Supporting text notes that sewage infrastructure in the north of the Borough is at full capacity, so we support standard 'e. redeveloped brownfield sites should disconnect any surface water drainage from the foul network.'

However, we recommend a more positive description is given to the benefits afforded by the Water Framework Directive in para 4.166. While some water bodies have been heavily modified and may never revert entirely back to their natural state, the Directive still aims that they achieve good ecological potential.

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