Comment

Representation ID: 15529

Received: 10/05/2016

Respondent: Environment Agency

In reference to paragraph 10.46 of the plan, even where a site is constrained due to its urban nature or for other reasons, environmental gains can still be achieved through de-culverting, creation and management of ecological buffer strips, or new wetland areas. Even these smaller gains can help to reduce pollution and help to reconnect people to nature.

Comment

Representation ID: 15530

Received: 10/05/2016

Respondent: Environment Agency

We would recommend that more detail is included in the Local Plan with regards to the rivers within the borough, their ecological status and potential opportunities for improving these through drivers such as the Water Framework Directive (WFD) and Eel Regulations. Several of the water bodies are all currently at less than good ecological status (e.g. Wid) and need to be a good status or potential status by 2027 in order to meet the requirements of the WFD. Any development proposals need to be compliant with the WFD in ensuring no deterioration and where possible seek enhancements.

Comment

Representation ID: 15531

Received: 10/05/2016

Respondent: Environment Agency

The plan is very land centric and only mentions water bodies or waterways in passing. We would like to see further detail regarding the rivers within the Borough and specifically the headwaters of the Rivers Wid and Mardyke for our area. Given the improvements suggested above, we consider that this could be addressed through a completely separate policy, which should address water quality, the requirements of the WFD and RBMP objectives. We would like to see a new policy on the protection, enhancement and buffering of watercourses to help in the achievement of WFD objectives. This should include the provision of ecological buffer strips and corridors, native tree planting and the new wetland areas to help manage flood risk and reduce diffuse pollution whilst connecting people to nature. This could also include de-culverting, removal of redundant structures, alien species removal where appropriate. The need for this is supported in paragraph 21.1.4 of the Interim Sustainability Appraisal.

Comment

Representation ID: 15532

Received: 10/05/2016

Respondent: Environment Agency

We support this policy but consider it would benefit from a reference to applying a sequential approach within sites, as well as them passing the requirements of the Sequential Test. This will ensure that more vulnerable development is directed to lower risk areas of a site, especially on mixed use development sites. It also can direct open space to higher risk areas, allowing an integrated approach to open space, recreation and flood risk management. More emphasis should be placed on enhancing existing flood management systems rather than focussing purely on managing flood risk to and from new development. We would encourage you to liaise with Essex County Council as Lead Local Flood Authority to identify potential opportunities to reduce and manage surface water flooding.
This policy could be improved by having some supporting text that further explains what is meant by resistant and resilient design means.
It could also benefit from mentioning (if not within a new policy) the need to ensure that development does not prevent flood risk management now or in the future. This is particularly important to us, as we often access to watercourses for example to exercise our permissive powers. In addition, space should be safeguarded for future defence raising.

Comment

Representation ID: 15533

Received: 10/05/2016

Respondent: Environment Agency

Within the Climate Change Mitigation topic, an objective could be included on ensuring that people and wildlife can adapt better to climate change. For example, using blue and green infrastructure to protect green corridors and help to reduce the urban heat island effect.

Comment

Representation ID: 15535

Received: 10/05/2016

Respondent: Environment Agency

Most of the allocations lie in Flood Zone 1, apart from site 200 Dunton Hills Graden Village and we have already provided comments on flood risk to this site through a separate consultation. These must be considered.

Comment

Representation ID: 15536

Received: 10/05/2016

Respondent: Environment Agency

Sites 042, 034, 087 and 235 are adjacent to a tributary of the River Wid, which is designated a Main River. We do not currently hold modelled data for this watercourse and these sites therefore appear to be in Flood Zone 1 on our Flood Map. However, there is likely to be some fluvial flood risk associated with this watercourse. Any development proposed here will need to be supported by a flood risk assessment that is informed by fluvial modelling of this watercourse. Any works in, over under or within 8m of the River Wid will need an Environmental Permit from us under the Environmental Permitting Regulations (2010).

Comment

Representation ID: 15538

Received: 10/05/2016

Respondent: Environment Agency

Sites 042, 034, 087 and 235 are adjacent to a tributary of the River Wid, which is designated a Main River. We do not currently hold modelled data for this watercourse and these sites therefore appear to be in Flood Zone 1 on our Flood Map. However, there is likely to be some fluvial flood risk associated with this watercourse. Any development proposed here will need to be supported by a flood risk assessment that is informed by fluvial modelling of this watercourse. Any works in, over under or within 8m of the River Wid will need an Environmental Permit from us under the Environmental Permitting Regulations (2010).

Comment

Representation ID: 15539

Received: 10/05/2016

Respondent: Environment Agency

Allocation 022 Land at Honeypot Lane is bisected by a large ordinary/non main river watercourse. Full consultation should occur with Essex County Council as LLFA.