Comment

Representation ID: 19901

Received: 26/03/2018

Respondent: Environment Agency

It is encouraging to see the emphasis on protecting green belt land and the promotion of green infrastructure in the Local Plan. We 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. Any development proposals need to be compliant with the WFD in ensuring no deterioration and where possible seek enhancements.

Comment

Representation ID: 19902

Received: 26/03/2018

Respondent: Environment Agency

The Local Plan is very land centric and only mentions water bodies or waterways in passing. It is disappointing to see no specific mention of rivers and waterways in the biodiversity section of the SA. We would like to see further detail regarding the rivers and specifically the headwaters of the Rivers Wid and Mardyke. This could be addressed through a completely separate policy, addressing water quality and WFD and RBMP objectives. A new policy on provision of ecological buffer strips and corridors, native tree planting and the new wetland areas to help manage flood risk and reduce diffuse pollution.

Comment

Representation ID: 19903

Received: 26/03/2018

Respondent: Environment Agency

Although we note that flooding has been considered in the SA, there is nothing within
the Preferred Site Allocations draft Local Plan in regards to flood risk. We would
prefer to see an approach included in the Local Plan to manage and communicate
the risks and consequences of flooding arising from all sources of flood risk.

Comment

Representation ID: 19904

Received: 26/03/2018

Respondent: Environment Agency

Suggested text to be included for sites referenced 263 and 276 have small areas in Flood Zones 2 and 3, and part of the site referenced 200 is located in Flood Zone 3. Applicants should be aware of the modelled watercourses in the area as proposed developments may be required to model nearby watercourses to determine local flood risk. All development proposals within the flood zone (which includes Flood Zones 2 and 3), or elsewhere on sites of 1 hectare or more must be accompanied by a Flood Risk Assessment (FRA).

Comment

Representation ID: 19905

Received: 26/03/2018

Respondent: Environment Agency

Suggested text to be included for sites referenced 263 and 276 have small areas in Flood Zones 2 and 3, and part of the site referenced 200 is located in Flood Zone 3. Applicants should be aware of the modelled watercourses in the area as proposed developments may be required to model nearby watercourses to determine local flood risk. All development proposals within the flood zone (which includes Flood Zones 2 and 3), or elsewhere on sites of 1 hectare or more must be accompanied by a Flood Risk Assessment (FRA).

Comment

Representation ID: 19906

Received: 26/03/2018

Respondent: Environment Agency

Suggested text to be included for sites referenced 263 and 276 have small areas in Flood Zones 2 and 3, and part of the site referenced 200 is located in Flood Zone 3. Applicants should be aware of the modelled watercourses in the area as proposed developments may be required to model nearby watercourses to determine local flood risk. All development proposals within the flood zone (which includes Flood Zones 2 and 3), or elsewhere on sites of 1 hectare or more must be accompanied by a Flood Risk Assessment (FRA).

Comment

Representation ID: 19907

Received: 26/03/2018

Respondent: Environment Agency

The watercourse through the middle of the site proposed for the Dunton Hills Garden
Village has not been modelled, and therefore the risk of flooding to the site is currently unknown. Modelling would be required to accurately establish the risk to any proposed development and ensure that the site is designed to reflect the current and future flood risk. Built development should be located away from areas of future flood risk. Further information in respect of modelling is provided below under the heading 'JFLOW'

Comment

Representation ID: 19908

Received: 26/03/2018

Respondent: Environment Agency

General flood risk advice: The sequential approach should be applied within specific sites in order to direct development to the areas of lowest flood risk. If the whole site is at high risk, an FRA should assess the flood characteristics across the site and direct development towards those areas where the risk is lowest. We strongly advise that proposals for "more vulnerable" development, as defined in Table 2 of the Flood Risk and Climate Change section of the PPG. We are likely to raise an objection where this is not achieved in line with Paragraph 060 of the NPPF's PPG.

Comment

Representation ID: 19909

Received: 26/03/2018

Respondent: Environment Agency

Our guidance 'Flood risk assessments: climate change allowances' should be used
to inform the spatial distribution of growth and the requirements of FRA's for
individual applications.

Comment

Representation ID: 19910

Received: 26/03/2018

Respondent: Environment Agency

The preferred site allocations referenced 263, 276 & 200 may require a permit for
work within 8 metres of a defence structure/culvert. We would however, prefer that
any works around a main river must allow space for maintenance of our assets. This
would also provide multiple benefits including an ecological buffer strip and corridors