Policy NB7: Managing flood risk, Sustainable urban drainage systems & water quality

Comment

Representation ID: 4080

Received: 12/12/2022

Respondent: North Worcestershire Water Management

South Staffordshire may want to include a reference to specific climate change allowances in designing SuDS, to reflect national climate change allowance guidance. Similar policies in Wyre Forest also include requirements for future development in residential schemes to be taken into account. Neither factor is currently reflected in non-statutory 2015 technical SuDS guidance. South Staffordshire may want to give further detail as to how compliance with NB7 requirement to protect the water environment from surface water runoff will be assessed.

Object

Representation ID: 4193

Received: 21/12/2022

Respondent: Mr John Marsh

Legally compliant? No

Sound? No

Duty to co-operate? No

See attachment

Comment

Representation ID: 4741

Received: 21/12/2022

Respondent: Environment Agency

We are satisfied that all matters in relation to the protection of water quality have been addressed, including SuDs, consideration of sewer capacity and their impact on the environment and phasing of developments. We welcome the submission of additional updated information relating to foul drainage sewer capacity contained within Appendix B of the IDP: Severn Trent Water Sewer Capacity Assessment – September 2022.

We note the push for SuDS use within Policy NB7, but recommend it may be pertinent to add in a specific reference within the policy body to ensure discharges are not made into the combined sewer system, within particular consideration or where surface water capacity is flagged within this report as Amber. It should be clear within the policy and its supporting text that early engagement with Severn Trent Water Ltd is imperative to ensuring a sustainably drained development.

Comment

Representation ID: 4749

Received: 21/12/2022

Respondent: Environment Agency

We do recommend however that the following changes (previously advised) are made to the policy to strengthen it and bring it in line with the recommendations sections 10.3 and 10.2 of the 2019 Level 1 SFRA. The policy should state additional wording around:
- naturalising urban watercourses and open up underground culverts
- preventing development from taking place over or within 8m of culverted watercourses
- minimising flood risk on the site
- providing wider betterment in site specific flood risk assessments

It is imperative that references to 300mm above sea level are changed to 600mm.

Comment

Representation ID: 5603

Received: 23/12/2023

Respondent: Severn Trent Water

New development should utilise Sustainable Drainage Systems (SuDS) delivered in a management train and not as an 'end of pipe basin'. Surface water runoff rate should be no greater than the equivalent greenfield runoff rate.

New development should discharge surface water inline with the drainage hierarchy.

Support the districts alignment to Staffordshire County Council Sustainable Drainage Systems (SuDS) Handbook.

An entirely new policy is encouraged that covers the role that new developments have to play in protecting water resources.