Publication Plan April 2024

Comment

Representation ID: 6263

Received: 30/05/2024

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: 6264

Received: 30/05/2024

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: 6265

Received: 30/05/2024

Respondent: Environment Agency

We welcome the addition of a Level 2 SFRA. The Level 2 SFRA shows that the critical 1 in 100 year plus climate change flood extent encroaches (albeit largely into public open space) on sites 119a, 284, 139, Land North of Penkridge, SA1 and SA4. The SFRA confirms that for the majority of these sites the encroachment is only minor.

All these sites will therefore require a site specific FRA which shows development laid out as to avoid the floodplain and finished floor levels 600mm above the 1 in 100 plus climate change flood level. This should be detailed within the allocation requirements. In addition, the quantum of development should be reviewed to ensure that it can fit onto the area outside the 1 in 100 plus climate change flood event, with particular note of 119a which shows about a third of the site affected by flooding.

Although referenced within the Sustainability Appraisal it is unclear where the evidence sits to clearly demonstrate how the proposed site allocations have had the Sequential Test applied as is required by Paragraphs 161 and 162 of the NPPF. We recommend however given the proximity of the fluvial floodplain, residual risk should be mitigated for by it being required that finished floor levels are set at or in excess of 600mm above the 1in 100 year plus climate change for that specific location.
• Site Ref 617
• Site Ref 646a
• Site Ref 646b

Comment

Representation ID: 6266

Received: 30/05/2024

Respondent: Environment Agency

Site 016 - this site is proposed close to SB Waste Management (Huntington) The site is a relatively small scale transfer station. Amenity issues are likely to be raised by any developments adjacent to the site.

Comment

Representation ID: 6267

Received: 30/05/2024

Respondent: Environment Agency

We welcome the addition of a Level 2 SFRA. The Level 2 SFRA shows that the critical 1 in 100 year plus climate change flood extent encroaches (albeit largely into public open space) on sites 119a, 284, 139, Land North of Penkridge, SA1 and SA4. The SFRA confirms that for the majority of these sites the encroachment is only minor.

All these sites will therefore require a site specific FRA which shows development laid out as to avoid the floodplain and finished floor levels 600mm above the 1 in 100 plus climate change flood level. This should be detailed within the allocation requirements. In addition, the quantum of development should be reviewed to ensure that it can fit onto the area outside the 1 in 100 plus climate change flood event, with particular note of 119a which shows about a third of the site affected by flooding.

Although referenced within the Sustainability Appraisal it is unclear where the evidence sits to clearly demonstrate how the proposed site allocations have had the Sequential Test applied as is required by Paragraphs 161 and 162 of the NPPF. We recommend however given the proximity of the fluvial floodplain, residual risk should be mitigated for by it being required that finished floor levels are set at or in excess of 600mm above the 1in 100 year plus climate change for that specific location.
• Site Ref 617
• Site Ref 646a.
• Site Ref 646b

Comment

Representation ID: 6268

Received: 30/05/2024

Respondent: Environment Agency

Sun Valley Foods Billbrook, located on the Balliol Business Park is regulated by the Environment Agency. The site is currently surrounded by agricultural land and industrial development but the proposals under site Ref 519 would bring the large housing development approximately 75m from the facility. Food production operates 24/7 which includes the use of ovens and fryers to cook the food and chiller units to freeze the product before it leaves site in refrigerated trailers. The facility also has effluent treatment, external storage of waste product and of course incoming and outgoing vehicle movements with audible alarms, therefore there is a possibility that amenity issues could be experienced. Bilbrook HWRC, a small well run site currently owned by Amey Highways is also nearby. There does remain potential for this to be a problem if residential receptors are brought closer to the site than at present.

We recommend your planning policies ensure that appropriate assessment and mitigation can be carried out by the agent of change (ie residential allocations). Where any mitigation is not practical, properties should not perhaps be built close to the site perimeter. We recommend strategic policy SA1 references the risks associated with their proximity to such facilities, and the need for assessment and/or mitigation measures in order to inform and steer the masterplanning process.

Comment

Representation ID: 6269

Received: 30/05/2024

Respondent: Environment Agency

We welcome the addition of a Level 2 SFRA. The Level 2 SFRA shows that the critical 1 in 100 year plus climate change flood extent encroaches (albeit largely into public open space) on sites 119a, 284, 139, Land North of Penkridge, SA1 and SA4. The SFRA confirms that for the majority of these sites the encroachment is only minor.

All these sites will therefore require a site specific FRA which shows development laid out as to avoid the floodplain and finished floor levels 600mm above the 1 in 100 plus climate change flood level. This should be detailed within the allocation requirements. In addition, the quantum of development should be reviewed to ensure that it can fit onto the area outside the 1 in 100 plus climate change flood event, with particular note of 119a which shows about a third of the site affected by flooding.

Although referenced within the Sustainability Appraisal it is unclear where the evidence sits to clearly demonstrate how the proposed site allocations have had the Sequential Test applied as is required by Paragraphs 161 and 162 of the NPPF. We recommend however given the proximity of the fluvial floodplain, residual risk should be mitigated for by it being required that finished floor levels are set at or in excess of 600mm above the 1in 100 year plus climate change for that specific location.
• Site Ref 617
• Site Ref 646a.
• Site Ref 646b

Comment

Representation ID: 6270

Received: 30/05/2024

Respondent: Environment Agency

Lower Drayton Farm Anaerobic Digestion facility is permitted and regulated by the Environment Agency. The proposals put forward under site ref 420, 584 and 010 will bring housing development adjacent to the permitted area and potentially expose new residents to amenity issues such as odour and noise either from the permitted facility or waste haulage vehicles entering and exiting the site. We still have concerns about the indicative concept plan which includes a community park and other potential development site/sport pitches adjacent to the AD site. Development in these areas could place unreasonable restrictions or expectations on this existing facility as a result of development permitted after they were established.

We recommend your planning policies ensure that appropriate assessment and mitigation can be carried out by the agent of change (ie residential allocations). Where any mitigation is not practical, properties should not perhaps be built close to the site perimeter. We recommend strategic policy SA4 references the risks associated with their proximity to such facilities, and the need for assessment and/or mitigation measures in order to inform and steer the masterplanning process.

Comment

Representation ID: 6271

Received: 30/05/2024

Respondent: Environment Agency

The Phase 1 Scoping Water Cycle Study, undertaken by JBA in February 2020 has not been updated since our previous comments in relation to this plan which highlighted where assessments were out of date. What discussions the Council has had with the water companies regarding timescales for development and how Severn Trent Water and South Staffs Water will meet the new demand arising from development in the South Staffs area? As no Detailed WCS published, we trust that this matter has been discussed between your Authority and Severn Trent Water to ensure the implications of the proposed growth on this resource has been fully explored.