Regulation 18 Draft Local Plan

Support

Representation ID: 1905

Received: 25/04/2024

Respondent: Environment Agency

We support the production of a new Climate Change Study to inform Policy RE1 ahead of it being finalised. In regards of flood risk, renewable energy developments can be located in areas of flood risk due to the ability to raise the infrastructure out of the flood zone, however, early consultation with the Environment Agency is recommended to ensure appropriate flood risk mitigation is considered.

Object

Representation ID: 1906

Received: 25/04/2024

Respondent: Environment Agency

We recommend that Policy SP3 is strengthened by referring to the protection of the water environment to ensure further development in areas with infrastructure capacity issues do not harm the environment. Therefore, we suggest the following is added to Policy SP3; “In all settlements defined in Policy SP2, residential development, which is in accordance with all other relevant Local Plan policies, will be supported provided that: [insert - it does not cause harm to the water environment]”.
We identified settlements with Water Recycling Centre (WRC) capacity issues in response to the Regulation 18 Issues and Options consultation 2020; Marston,
Deepings and Little Bytham. In Chapter 6, Little Bytham and Marston have been identified in Policy SP2 as Smaller Villages where small scale development will be supported. As these settlements continue to have WRC capacity issues additional comments have been provided. AWS would therefore need to be consulted on any proposed housing and development. The Plan should ensure that there is appropriate liaison with AWS to ensure that sufficient measures are in place to meet water demand for new development.

Object

Representation ID: 1907

Received: 25/04/2024

Respondent: Environment Agency

Policy H1 outlines a list of proposed site allocations for residential development. These site allocations will need to have passed the sequential test. An assessment of the site’s constraints along with rankings and recommendations should also be included. Paragraph 10.26 states "South Kesteven has commissioned a new Strategic Flood Risk Assessment (SFRA) in line with the NPPF requirements and in consultation with the Environment Agency and this will be the starting point for consideration of the sequential and the exception tests". The site allocations outlined in Policy H1 should be included in this.

Object

Representation ID: 1908

Received: 25/04/2024

Respondent: Environment Agency

Site allocation SKPR-281 (Stamford North) is in Flood Zone 2 and 3. The indicative number of units for this housing allocation is 1350. We expect that some of these houses would be located within Flood Zone 2. We would not support site allocation SKPR-281 without further evidence to demonstrate that properties would be sequentially located and that climate change allowances would be considered for any development that comes forward as a result of the allocation.

Support

Representation ID: 1909

Received: 25/04/2024

Respondent: Environment Agency

We are satisfied that reference to flood risk can be removed from Policy H5 and H6 as Policy EN5 adequately covers flood risk and can be applied to all development types. The NPPG requires that proposals for holiday or short-let caravans and camping sites are accompanied by a Flood Warning and Evacuation Plan, undertaken and agreed in consultation with the Local Planning Authority’s Emergency Planning Officer. We would recommend an overarching Flood Warning and Evacuation Plan for South Kesteven District Council that can be applied to these sites.

Support

Representation ID: 1910

Received: 25/04/2024

Respondent: Environment Agency

We are satisfied that reference to flood risk can be removed from Policy H5 and H6 as Policy EN5 adequately covers flood risk and can be applied to all development types. The NPPG requires that proposals for holiday or short-let caravans and camping sites are accompanied by a Flood Warning and Evacuation Plan, undertaken and agreed in consultation with the Local Planning Authority’s Emergency Planning Officer. We would recommend an overarching Flood Warning and Evacuation Plan for South Kesteven District Council that can be applied to these sites.

Object

Representation ID: 1911

Received: 25/04/2024

Respondent: Environment Agency

Whilst we support the inclusion of new Policy EN4 it could be made clearer that going above the minimum measurable target of 10% would be preferable, the wording of paragraph 3 could suggest that major development would be the best place to aim for higher BNG more in the region of 20%.

Object

Representation ID: 1912

Received: 25/04/2024

Respondent: Environment Agency

Section 10.34 states that the Environment Agency are responsible for the management of groundwater resources, however it is the local authority that would be responsible for managing the risk of flooding to groundwater. We have a strategic overview for all sources of flooding. Further guidance on our responsibility on groundwater resource can be found herehttps://assets.publishing.service.gov.uk/media/5ab38864e5274a3dc898e29b/Envirnment-Agency-approach-to-groundwater-protection.pdf

Object

Representation ID: 1913

Received: 25/04/2024

Respondent: Environment Agency

Proposes revised wording of Policy EN5 for greater clarity.

Whilst we are waiting for the SFRA to be completed, development in areas of flood risk must be designed to ensure they are safe for their lifetime (this is mentioned in
supporting text, but not in Policy EN5). Development should be steered away from Flood Zones 2 and 3 where possible and maintain access to ‘main river’ water courses. Good, sustainable design which can adapt to climate change must consider flood risk and ensuring development will stay safe for its lifetime and not increase flood risk elsewhere. Any development taking place with 8 metres of the bank of a main river, or 16 metres if it is a tidal main river may require a permit under the Environmental Permitting Regulations 2016. Further information can be found at Flood risk activities: environmental permits - GOV.UK (www.gov.uk).

Support

Representation ID: 1914

Received: 25/04/2024

Respondent: Environment Agency

Development should aim to identify flood risk mitigation measures in line with those required for new build development of the same type, as far as this is practicable and should be in accordance with national flood risk standing advice if the development falls within Flood Zone 2 or 3. We advise against the use of flood doors or demountables unless development can be restricted to replace these/the mechanisms with like for like. This is the ensure that flood doors are not replaced with standard doors.