Comment

Representation ID: 90

Received: 13/06/2007

Respondent: Environment Agency

This section states that the housing requirement is likely to be met through allocations rather than rely on windfall sites. If windfall sites are permitted it must be ensured that proposed sites are tested against the relative sustainability criteria. In terms of flood risk, all sites must be subject to the PPS25 Sequential Test. This is best applied at the plan stage, which better allows for a consideration of alternatives. Therefore, if windfall sites were likely to be permitted we would recommend that appropriate general locations be identified within the development plan, and it should be demonstrated that the correct procedures in selecting these areas have been applied.

Paragraph 4.5.11 states that the council will prioritise the reuse of previously developed land. We agree with this approach, however brownfield sites may also be contaminated. At the individual site level, where contamination is suspected, it must be ensured that the procedure detailed in PPS23 is complied with.