Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 13696

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

As stated in our previous consultation response, we recommended that point 8(viii) is amended to specifically provide guidance on how buffers between mineral extraction and rivers should be managed.

Object

Representation ID: 13697

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

As acknowledged within our 2017 response given your proposed minerals allocations and areas of search, this is most likely applicable to the River Blythe. We welcome the addition of text in supporting paragraph 368 to specifically relate to a 30m buffer. We recommend this is incorporated into the policy itself.

Object

Representation ID: 13698

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Safeguarding of sensitive sites from waste uses should be reflected in this policy, as well as P12.
Reference to Contaminated Land in this policy appears out of place.
The protection and remediation of Controlled Waters is more of a water quality issue, so suggest it is included in P10 or P12.

Object

Representation ID: 13699

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Contaminated Land -
In addition to comments for P10 and P14, EA also recommend the following is added in relation to contamination (under either P10 or P12) explaining where developers should look for information to support their application, as there appears to be very little in the way of supporting text in terms of this subject.

Object

Representation ID: 13700

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We recommend that it is added into this policy that sites are laid out so that properties face onto rivers, streams and other waterbodies in order to prevent littering, pollution and to foster a sense of community ownership of the water environment.

Support

Representation ID: 13701

Received: 12/12/2020

Respondent: Environment Agency

We are pleased to have been able to review your Level 2 SFRA (October 2020).
Consider that the Level 2 SFRA adequately considers the risk posed to and from these sites, and that the recommendations from this assessment have been carried forward into the plan, namely to provide flood risk reduction wherever possible and not locate any built development within Flood Zone 2 and 3.
We defer any other flood risk comments on the other sites within the Level 2 SFRA to your internal drainage team as the Lead Local Flood Authority with a remit including surface water flooding and that flood risk from Ordinary Watercourses. We are pleased to see that the LLFA has already been engaged in the drafting of this assessment.

Support

Representation ID: 13702

Received: 12/12/2020

Respondent: Environment Agency

We are pleased to have been able to review your Level 2 SFRA (October 2020).
Consider that the Level 2 SFRA adequately considers the risk posed to and from these sites, and that the recommendations from this assessment have been carried forward into the plan, namely to provide flood risk reduction wherever possible and not locate any built development within Flood Zone 2 and 3.
We defer any other flood risk comments on the other sites within the Level 2 SFRA to your internal drainage team as the Lead Local Flood Authority with a remit including surface water flooding and that flood risk from Ordinary Watercourses. We are pleased to see that the LLFA has already been engaged in the drafting of this assessment.

Support

Representation ID: 13703

Received: 12/12/2020

Respondent: Environment Agency

We are pleased to have been able to review your Level 2 SFRA (October 2020).
Consider that the Level 2 SFRA adequately considers the risk posed to and from these sites, and that the recommendations from this assessment have been carried forward into the plan, namely to provide flood risk reduction wherever possible and not locate any built development within Flood Zone 2 and 3.
We defer any other flood risk comments on the other sites within the Level 2 SFRA to your internal drainage team as the Lead Local Flood Authority with a remit including surface water flooding and that flood risk from Ordinary Watercourses. We are pleased to see that the LLFA has already been engaged in the drafting of this assessment.

Support

Representation ID: 13704

Received: 12/12/2020

Respondent: Environment Agency

EA are already closely engaged with the elements of the HS2 proposals controlled via specific Government Bills and associated legislation, and as such are satisfied that matters in relation to the tracks and the river diversion will have satisfactory controls via this route.
In terms of the development within the scope of the Local Plan, we welcome the policy proposals in relation to flood risk and water quality.
Urge the Local Plan to carry through aspiration of BREEAM Excellent rating for the HS2 station, and extend to wider area. A key part of the station’s BREEAM measures is sustainable transport, with non-car travel solutions such as a cycle route over the M42 being integral to the success of the station.
Note and welcome the policy commitment to promote ‘sustainable movement patterns to enable site wide and beyond connectivity’, but not been explicitly referenced within the plan. Therefore must be included within The Hub Framework Plan and Arden Cross Masterplan to be effective.

Object

Representation ID: 13705

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

This is NOT an objection to the principle of the site, but a recommendation to fully consider the environmental permitting regulations.
BC6: Lavender Hall Farm, Balsall Common – the land is currently used as a permitted landfill site, and as such, redevelopment of the land will need to ensure effective surrender of their operational permit prior to redevelopment. Site design and redevelopment will need to consider the underlying landfill.