Preferred Options November 2021

Support

Representation ID: 1001

Received: 04/02/2022

Respondent: Environment Agency

Welcome identification of climate change as a key driver.

Object

Representation ID: 1084

Received: 04/02/2022

Respondent: Environment Agency

Afford blue-green corridors high level of protection. Consider need for extra watercourse capacity to address climate change.
Amend Issues and challenges to include reference to enhancing and re-naturalising the water environment.
Development should give space for water via protection and naturalisation of blue/green corridor.
Reword strategic objection 11 to include after net gain - 'and wider holistic environmental improvements'.
Reword strategic objection 12 insert after effects of climate change - 'ensuring new developments are well designed and opportunities for improving sustainability.'

Object

Representation ID: 1085

Received: 04/02/2022

Respondent: Environment Agency

HC19 - Design green spaces to include more semi-natural habitats.
NB1 - Habitat connectivity will be important in relation to climate change. Mention blue/green corridors.
NB6 - Commit to 110 lp/d.
NB7 - Include requirement for safeguarding land for flood risk management.
NB7 - Take account of latest climate change.
NB7 - Support naturalisation of urban watercourses.
NB7 - No development within 8m of culverted watercourses.
NB7 - Direct development to sites with lowest flooding probability.
NB7 - Seek to provide wider betterment.
NB7 - Provide Surface Water Drainage Strategies for all major developments.
HC8 - Exclude sites within Flood Zone 3. Exceptions test for Flood Zone 2.

Object

Representation ID: 1094

Received: 04/02/2022

Respondent: Environment Agency

Potential constraints include potential new sewage treatment facility; discharge to watercourse, not a foregone conclusion that foul water could be easily discharged.

Support

Representation ID: 1095

Received: 04/02/2022

Respondent: Environment Agency

NB1 & NB2 Support minimum delivery of 10% net gain.

Object

Representation ID: 1111

Received: 04/02/2022

Respondent: Environment Agency

Include River Basin Management Plans. Policies should commit to supporting the objectives of these plans.
Water Cycle Study - Abstraction Licensing Strategies have been updated since WCS was published. Water stress section out of date, classification now 'serious water stress'.
Support recommendation in study for standard of 110 lpd, this should be included in policies.

Object

Representation ID: 1112

Received: 04/02/2022

Respondent: Environment Agency

SA1, SA2 & SA4 adjacent to Flood Zones 2&3. Further assessment required to ensure accuracy of boundaries especially taking into account updated climate change allowances.
Safeguarding regulated activities is a potential concern in relation to sites SA1 & SA5.
Sites SA1, SA2 & SA4: include additional requirements in the SPD to include measures to enhance the watercourses on-site by implementing WFD priorities.

Object

Representation ID: 1113

Received: 04/02/2022

Respondent: Environment Agency

Recommend Level 2 SFRA carried out for sites 119, 139, 617, 463/284 & 646.
Safeguarding Regulated Activities potential issue - 519, 420/584/010.

Object

Representation ID: 1124

Received: 04/02/2022

Respondent: Environment Agency

Further reassurance needed that CSO's and storage will be upgraded where necessary to prevent new development causing increase in storm water spill frequency, duration and volume.