Issue 5

Area i

This former Brickworks site has the potential for contamination that may affect controlled waters. If this site is redeveloped then, ccording to Paragraph 2.43 of Annex 2 of PPS23, as a minimum, a desktop study should be completed. This study must include the identification of previous site uses, potential contaminants that might reasonably be expected given those uses and other relevant information. Using this information, a diagrammatical representation (Conceptual Model) for the site must be produced to illustrate all the potential contaminant sources, pathways and receptors in order to fully assess the risk posed to the site.

If the desktop study identifies that contamination may be a problem, a full site investigation should be completed and submitted along with a risk assessment and remediation Method Statements.

Disturbance of contaminated land can severely increase its polluting potential as contaminants may be washed on to other land or into surface and groundwater. The Agency acts to reduce possible pollution to land and water quality by advising on site contamination investigations.

Where land is affected by contamination, development can provide an opportunity to address the problem for the benefit of the wider community and bring the land back into beneficial use (PPS 23 para 17).

The potential for pollution affecting the use of land, e.g. for other development, is capable of being a material consideration in deciding whether to grant planning permission (PPS 23 para 2).

Area ii (b)

The Northern portion of this site, adjacent to the boundary, falls with Flood Zones 2 and 3.

The proposal to allocate this land as open space and for rugby pitches complies with the policies of PPS25. Development of this type fits within the Water compatible vulnerability classification within table D2 of PPS25.

Area ii (c)

We support the use of this land as a 'Green Lung'. All opportunities should be taken to enhance the biodiversity value of the land, in line with PPS9.

Part of this site falls within Flood Zones 2 & 3. In line with PPS25, built development would not be appropriate in this area, therefore we support the proposal to set aside this land for public open space and green links.

Area iii

The majority of this area falls within Flood Zones 2 & 3. I note that you intend to include this land within the airport boundary as land for MRO (Maintenance, repair and overhaul) purposes. It is unclear whether this will result in development of this site or not.

When allocating land within the flood risk areas, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.

In order to be 'Sound', the allocation needs to be justified, based on a 'robust and credible evidence base' or 'the most appropriate when considered against the reasonable alternatives' (PPS12 para 4.51 - 4.53). It needs to be clear that the approach is the most appropriate given the alternatives and it needs to be clear how and why decisions have been made (in line with paras 2.8 & 2.9 of Examining Development Plan Documents: Soundness Guidance, PINS July 2008).

If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.


Area iv

Small parts to the south of this area, adjacent to Eastwood Brook, are within Flood Zones 2 & 3.

When allocating land within the flood risk areas, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.

In order to be 'Sound', the allocation needs to be justified, based on a 'robust and credible evidence base' or 'the most appropriate when considered against the reasonable alternatives' (PPS12 para 4.51 - 4.53). It needs to be clear that the approach is the most appropriate given the alternatives and it needs to be clear how and why decisions have been made (in line with paras 2.8 & 2.9 of Examining Development Plan Documents: Soundness Guidance, PINS July 2008).

If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.

Where possible opportunities for redevelopment should be undertaken in the remaining part of the site that falls within flood zone 1.

Area vi

Small parts to the south of this area, adjacent to Eastwood Brook, are within Flood Zones 2 & 3.

When allocating land within the flood risk areas, the sequential test of PPS25 must be applied. In order for the allocation to be appropriate, this test should demonstrate that there are no reasonably available sites in lower flood risk zones for this type of development.

If the allocation is carried forward to the final submission document without evidence that the sequential test has been applied, we would question the soundness of the allocation.

In order to be 'Sound', the allocation needs to be justified, based on a 'robust and credible evidence base' or 'the most appropriate when considered against the reasonable alternatives' (PPS12 para 4.51 - 4.53). It needs to be clear that the approach is the most appropriate given the alternatives and it needs to be clear how and why decisions have been made (in line with paras 2.8 & 2.9 of Examining Development Plan Documents: Soundness Guidance, PINS July 2008).

If development can be deemed to be appropriate, then a detailed Flood Risk Assessment (FRA) must demonstrate that the risk of flooding can be managed and the development will be safe.

Where possible opportunities for redevelopment should be undertaken in the remaining part of the site that falls within flood zone 1.

Area xi

The northern part of this site falls within Flood Zone 2. The remainder of the site is Flood Zone 1 and appropriate for the allocation of a new park and ride facility.

Any new development must be designed with adequate pollution control measures to prevent potential pollution events arising. The use of Sustainable Drainage Systems (SuDS) can manage surface water runoff to reduce the risk of flooding and also create areas of open/green space that contribute to increased habitat and biodiversity, creating green links between sites.