Object

Representation ID: 11185

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Although we welcome the addition of text that acknowledges ‘On previously developed land where there is contamination known or suspected, any infiltration proposals must be agreed with the Environment Agency', protection of groundwater resources should be given greater weight within this policy. Paragraph 334 recognises the importance of the Water Framework Directive, and the associated status of the rivers Cole and Blythe, but does not include any acknowledgement of the importance of groundwater bodies also covered under this legislation. This should be rectified. Paragraph 336 advises that ‘Developers will be expected to demonstrate that they have thoroughly assessed the impact of their proposals on surface and ground water systems, and incorporated any necessary sewerage and drainage mitigation measures.’ Acknowledgement of the vulnerability of groundwaters to drainage proposals is welcomed, however this should go further with a commitment to protect groundwater quality and quantity more holistically.