Comment

Representation ID: 5856

Received: 17/02/2015

Respondent: Environment Agency

Where a development proposal will result in the loss of a significant greenfield site, the developer should aim to minimise the use of resources and the production of waste and in doing so ensure the development incorporates principles of sustainable construction and design. The developer should submit a Code for Sustainable Homes assessment (CSH), or any successor assessment procedure, together with a Sustainability Assessment, and build to a rating level beyond Code 3, which is regarded as minimum only.

Comment

Representation ID: 5857

Received: 17/02/2015

Respondent: Environment Agency

We recommend the following issues are considered at the determination stage:
Overall sustainability, resource efficiency, net gains from nature, sustainable energy use.

Comment

Representation ID: 5858

Received: 17/02/2015

Respondent: Environment Agency

Increased water efficiency will directly reduce consumer water and energy bills and reduce carbon dioxide emissions. Measures such as spray taps, water efficient showers and appliances, low flush toilets and outdoor water butts can achieve the water efficiency levels specified above. Water meters should also be installed by water companies. In addition, all developments should aspire to incorporate community water harvesting and reuse systems; these are needed to achieve water use of less than 95l/head/day.

Comment

Representation ID: 5859

Received: 17/02/2015

Respondent: Environment Agency

Blue and Green infrastructure are an important component in the adapation to climage change. Green infrastructure can be incorporated within all scales of development. There are many benefits associated with green and blue infrastructure including:
reducing the impact of urban run off
-safeguarding areas for biodiversity
- improving water quality and attenuation
- providing shading to building and outdoor spaces.
We would encourage you to consider opportunities for incorporating green and blue infrastructure within the development.

Comment

Representation ID: 5860

Received: 17/02/2015

Respondent: Environment Agency

Paragraph 100 of the NPPF states that 'Local Plans should be supported by Strategic Flood Risk Assessment (SFRA) and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies.' Due to the passage of time since the Council's SFRA was completed, it may need reviewing and possibly updating for any flood modelling carried out since the work on the SFRA was competed. We are happy to discuss this with the Council.

Comment

Representation ID: 5861

Received: 17/02/2015

Respondent: Environment Agency

We recommend that water quality and RBMP objectives are included in the Sustainability Appraisal to inform the preparation of the Local Plan document.

Comment

Representation ID: 5862

Received: 17/02/2015

Respondent: Environment Agency

If housing numbers are constrained by environmental capacity, we recommend that early reviews of core policies should be built into the plan to take into account 'feasibility' (or other) studies that water companies may submit to secure additional funding from OFWAT. This could help the Council accommodate additional housing numbers in later periods of the plan.

Comment

Representation ID: 5863

Received: 17/02/2015

Respondent: Environment Agency

The Local Plan should include policies to manage the impact of climate change on water quality. This could include:
 increased sewage infrastructure capacity in some locations
 increased need for SuDS and green infrastructure in some locations.
On the theme of climate change we would also recommend policies aimed at:
 energy and water efficiency
 sustainable design and construction.
Additionally we would recommend policies aimed at:
 reducing the risk of pollution from diffuse sources
 reducing the risk to developments from flooding, both onsite and offsite
 reducing the risk of disturbance to rivers.