Allocations DPD Discussion and Consultation Document

We have the following general advice relating to allocation sites which should be applied where appropriate:

Flood Risk

PPS25 advocates positive, risk-based planning to avoid the impacts of flood risk and its main aim is to "to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk".

Ideally the flood risk posed to a Local Authority area should be appraised through the production of a Strategic Flood Risk Assessment (SFRA) and this requirement is set out in Paragraph 25. We acknowledge that the Thames Gateway SFRA was completed in 2006, however this is not PPS25 compliant and does not extensively cover Rochford district. We therefore have no information pertaining to flood risk in your district other than our own flood maps which are based upon the PPS25 definitions of flood zones and are precautionary in that they do not take into account the presence of flood defences. The PPS25 Practice Guide makes it clear (paragraph 3.52) that the suitability of identified sites for housing should be informed by a SFRA and that areas of flood risk should be avoided. Flood risk mitigation measures cannot be considered to overcome flood risk constraints as part of the Strategic Housing Land Availability Assessment.

Our maps also do not map areas of Flood Zone 3b, the functional floodplain, this is something that should be mapped as part of a SFRA (PPS25 Practice Guide, paragraph 4.89). Due to the lack of fluvial flood defences in your district, and in the absence of a SFRA, we would have to take a precautionary approach and assume that all areas of Flood Zone 3, as delineated on our flood maps, are functional floodplain.

A number of the sites included in this DPD are associated with areas of flood risk. A Sequential Test must therefore be carried out in support of this document. For the larger greenfield sites, we believe that no development other than water compatible uses should be accommodated within the areas of flood zone. This would ensure that the integrity of the river corridors is maintained and would provide many benefits to the health and wellbeing of the new community, as well as reflecting government objectives to make space for water. It should be noted that, if all allocations could be made outside of the flood zones delineated by our maps, there might not be a need to carry out a detailed SFRA. Where development has to be allocated within areas of flood risk (as justified through the Sequential Test and the Sustainability Appraisal), a more detailed SFRA would be required to assess the actual level of flood risk posed to sites, and to inform the Exception Test and Emergency Planning as per PPS25. In this instance, the lack of a SFRA would mean that we would have to find the DPD unsound under all three tests of soundness as set out in PPS12.


Surface Water Drainage

High levels of development on greenfield sites will vastly affect the ability of that area to carry out its normal drainage function. In that respect we would expect sustainable drainage to be employed in those areas. The potential for a strategic system serving the whole allocation should be considered. This would provide multiple benefits such as public open space, habitat creation, opportunities for sustainable transport routes and flood risk control.



Water Resources

The Essex Thames Gateway Water Cycle Study Scoping Study (March 2009) identifies that in terms of water resources, Essex and Suffolk Water are currently operating at a demand-supply deficit during dry years and that, although the approval of the Abberton reservoir scheme will largely alleviate these problems in the future, the deficit will remain until this scheme comes online in 2014. The Scoping Report therefore recommends that, as well as seeking high levels of water efficiency in new and existing developments, new development is phased up to 2014. This issue should be considered in future iterations of the Site Allocations DPD. Failing to capture this issue means that we might have to find the DPD unsound under the first and second tests of soundness as set out in PPS12.


Sewerage Infrastructure and Water Quality

The Essex Thames Gateway Water Cycle Study Scoping Study (March 2009) also highlights that there are some potential capacity issues with both the Rochford wastewater treatment works (WwTW) and the sewerage network associated with it which would need resolving around 2015. There might also be some issues with the quality of discharge from the Rayleigh East WwTW which will require further investigation but could be exacerbated by unphased growth.

In terms of water quality, the three WwTWs serving Rochford District - Rochford, Rayleigh East and Rayleigh West - discharge to tributaries of the Rivers Roach and Crouch which are Shellfish Waters and flow into areas designated under national and international environmental legislation (SSSI, SPA and Ramsar designations). The water quality of these watercourses is generally poor and will need improvement under the Water Framework Directive. Page 48 of the Scoping Study states that further development draining to these three WwTWs has the potential to exacerbate the problem. Again further investigation is required into this issue.

It is therefore very likely that a Water Cycle Study will need to be completed in support of your Site Allocations DPD. Without such a study we would have to find the Site Allocations DPD unsound under the first and second tests of soundness as set out in PPS12.


Ecology

We would expect all proposed development sites to protect, enhance, and wherever possible recreate habitats. All opportunities to provide for ecological gain on site should be taken.


Historic Landfill Sites

Some sites lie within 250m of a former landfill site. On the 22nd of June 2007 we sent your Authority a CD containing historic landfill data which has all the information which we hold on these historic landfill sites and this should be consulted for further information.


Waste Management

The government and construction industry have a target to halve waste to landfill by 2012, the management of waste should therefore be considered as early as possible during the property design phase to ensure that minimal volumes of waste arise during the construction of the development, and the demolition at the end of its life. The design of the development can also influence the ability of residents to be able to recycle their waste and we would suggest that designs incorporate facilities to aid in this, especially in multiple-occupancy buildings. We would also suggest that consideration is given to the provision for recycling within public areas.

These matters should be considered as part of the development brief for the sites being allocated as these new developments will provide an important opportunity to reduce waste at the earliest possible stages of design.

Where the development sites will require the preparation of a Site Waste Management Plan in accordance with the Site Waste Management Plan Regulations 2008, please note that we strongly recommend the use of the BRE's SMARTWaste Plan. Please see http://www.smartwaste.co.uk for further information.


Informative

Under the terms of the Water Resources Act 1991, and local byelaws, the prior written consent of the Environment Agency is required for any proposed works or structures, in, under, over or within 9 metres of the top of the bank of a designated 'main river', or the toe of a designated flood defence.

Erection of flow control structures or any culverting of a watercourse requires the prior written approval of the Environment Agency under s.23 of the Land Drainage Act 1991 or s.109 of the Water Resources Act 1991. The Environment Agency resists culverting on nature conservation and other grounds and consent for such works will not normally be granted except for access crossings.

This site is bounded to the south by Rawreth Brook Main River. There are areas of Flood Zones 2 and 3 associated with this. There are no other constraints on-site.

Please see our general comments.

As for NLR1 except more of the site is within Flood Zone.

Please see our general comments.

The site is bounded to the west by the Carpenters Arms Brook Main River. This option has the least amount of flood zone associated with it and therefore represents the best option with regard to flood risk, subject to those issues raised in our general comments.

Please see our general comments.

As for Options NLR1 and 2. With this option, the flood zone could act to split the development, however it could also represent an opportunity to integrate the main river (Rawreth Brook) into the development through the inclusion of public open space etc.

Please see our general comments.

As for NLR1, NLR2 and NLR4.

Please see our general comments.

There is a small area of Flood Zone 2 associated with the north eastern corner of the proposed site.

Please see our general comments.

As for WR1. Please see our general comments.

This option minimises the flood risk issues. Please see our general comments.

Bounded by Hawkwell Brook Main River to the north. Some Flood Zone 2 and 3 to the north east of the site.

Please see our general comments.