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Representation 3054 on Preferred Options Local Plan by Environment Agency (Mr Martin Barrell)

Support / Object: COMMENT
Document Link: Preferred Options Local Plan - Strategic Issues and Policies, Infrastructure and Connectivity, SP4: Infrastructure and Connectivity
Representation: Policy SP4 - Infrastructure and Connectivity
Whilst we acknowledge that this policy currently focuses principally on transport and broadband, we would highlight that there is no similar overarching policy that addresses other 'environmental' infrastructure requirements. For example, there is no reference to the need to provide further waste water or flood risk infrastructure to help accommodate the proposed growth. We suggest that the need for similar overarching policy references are considered.

Original submission

Part 1
1 North Essex Authorities
Paragraph 1.19 - No reference is made in this section to the Strategic Flood risk Assessment (SFRA) update as a key evidence base document. As highlighted further on in this response, the SFRA will have an essential role in ensuring that the flood risk Sequential and Exception test have been appropriately applied to the Local plan. The Water Cycle Study is referred to, but is not available in the webpage of accessible evidence base documents. Paragraph 1.22 suggests that all of this evidence base is publically available, but this does not currently appear to be the case.

Policy SP4 - Infrastructure and Connectivity
Whilst we acknowledge that this policy currently focuses principally on transport and broadband, we would highlight that there is no similar overarching policy that addresses other 'environmental' infrastructure requirements. For example, there is no reference to the need to provide further waste water or flood risk infrastructure to help accommodate the proposed growth. We suggest that the need for similar overarching policy references are considered.

Policy SP5 - Place Shaping Principles
We support the inclusion of this policy, and would take this opportunity to highlight the positive role that a comprehensive design approach (in the form of development frameworks and master-plans) can have in helping to deliver well designed and multifunctional green infrastructure. Public open space and green infrastructure can serve to provide benefits such as sustainable drainage, amenity and ecological habitat improvements. It would be useful for reference to such multiple benefits to be included in the bullet points.
The inclusion of areas of ditches and watercourses within areas of public open space (as opposed to putting these within or bounding property curtilages), will help to ensure that these features are retained. This will ensure that the benefits that they can provide, in terms of managing surface water, enhancing ecology and amenity etc., can continue to be realised through ongoing management into the future. There also is likely to be lesser potential for watercourse related problems if the site layout allows for these features to be incorporated within land areas that are to be maintained by management companies or community trusts or organisations, rather than being the responsibility of individual property owners.

Policy SP7 - Development and Delivery of New Garden Communities in Essex
We welcome Policy SP7 and the aspiration for the new Garden Communities to be climate resilient and water neutral, for there to be net gains in biodiversity and high standards of innovation, water efficiency and waste management. We look forward to engaging on these issues further as the design of these communities' progresses.
We particularly support point iv) of this policy, which states that 'Sequencing of development and infrastructure provision (both on-site and off-site) to ensure that the latter is provided in tandem with or ahead of the development it supports.' The addition of 30-40,000 new homes in total will influence the quality and capacity of existing waste water treatment works and we would expect to be consulted further in future planning phases to discuss potential impacts on the water environment and any potential upgrades to existing infrastructure. In particular, early consultation with ourselves and Anglian Water is strongly recommended regarding the foul water treatment arrangements of the three new garden communities. It is likely that they will need either complete new works, or substantial upgrades to existing works.
We are disappointed, however, that there is no specific text to support the use of Sustainable Drainage Systems and the multifunctional use of green space to provide areas for recreation and flood risk management. We do, however, note that the provision of sustainable drainage systems is mentioned in Policies SP8, SP9 and SP10.

Policy SP8 - East Colchester / West Tendring new garden community
Policy SP9 - West of Colchester / East Braintree new garden community
Policy SP10 - West of Braintree new garden community
We are very supportive of these policies, which are specific to each proposed New Garden Community.
We are also pleased to see that a high proportion of green infrastructure is planned for the East Colchester/West Tendring New Garden Community, with a country park planned around Salary Brook. We would advise that the outer boundary of the new country park should be commensurate with the outer boundary of Flood Zone 2 to
assist the Council in its duty to demonstrate compliance with the required flood risk sequential approach.
When producing a masterplan for the development of this area, both Councils should consider flood risk from all sources, using the Strategic Flood Risk Assessments (SFRA), the Flood Map for Planning, and surface water flood risk maps from the Surface Water Management Plan (SWMP) and/or our published Risk of Surface Water Flooding maps as useful evidence base documents.
We support the specific references to the provision of sustainable surface water drainage measures. As above, we would highlight the potential multiple functions of such systems which can form part of public open space or other green-grid infrastructure, and provide biodiversity benefits if well designed.
In respect of foul drainage capacity, the minimum provision scheduled for the east and west new settlements up to 2033 can be accommodated within the current capacity of Colchester WRC. As has correctly been identified, upgrades and a new permit will at some point be required to serve the entire planned development. However, this is a much better option, both environmentally and in terms of permit restrictions, than trying to direct the waste water from these developments to smaller works. New discharges from smaller works will be subject to permits with extremely tight discharge limits, which would be very difficult and expensive to achieve. Upgrades to Colchester WRC are much more achievable and we are therefore supportive of this approach.

Attached Files for this Submission


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