Comment
Draft Local Plan - Supplementary Consultation
Representation ID: 10326
Received: 02/05/2019
Respondent: Environment Agency
A Main River (Purnells Brook, tributary of the River Blythe) bisects the site, however our 'Flood Map for Planning' only shows the flood risk from watercourses with a catchment area greater than 3km2, mapping of the risk from the watercourse has not been undertaken and as such this is the only reason the site is shown to lie in low risk Flood Zone 1. We strongly recommend that hydraulic modelling of the watercourse is undertaken as part of a Level 2 SFRA to inform of the developable area and capacity of this potential allocation. As a Main River, a minimum 8m easement should be provided from each bank in order to allow for essential channel maintenance. This will serve the dual purpose of protecting and maintaining green and blue infrastructure. Should you chose not to undertake modelling as part of a Level 2 SFRA, we will require modelling to be undertaken as part of a site-specific Flood Risk Assessment in support of a planning application, and development will need to be located outside Flood Zone 2 and 3, and the 100 year plus climate change flood extent. Any numbers allocated for this site will need to have sufficient flexibility to ensure they can respond to unassessed flood risk issues so that the allocation is not compromised by inability to deliver the required scale of development whilst also meeting flood risk requirements.
Thank you for referring the above consultation which we received on 30 January 2019. We apologise we have been unable to respond prior to now, and hope that you are still able to take our comments into account as the plan develops.
We have reviewed the above consultation document which is dated January 2019 and note the inclusion of additional sites for consideration for allocation.
We welcome the inclusion of Flood Risk as a potential 'Hard' issue in the site selection criteria as identified on page 18 and 19. We further recommend that Water Quality is added to the footnote in this section, with particular referenced to River Blythe's SSSI status. Further to this page 29 looks at what is required for the Blythe in the future and protection and enhancement of water quality should be included. Please see attached letter for our advice with regards to your site allocations, which incorporates comments previously provided, and adds additional comments in relation to your new sites. These comments should be used in preference to those previously provided as they have been updated