Allocations Submission Document

We support the concept statement acknowledging:
- A contaminated land study will be required due to the previous uses of the site;
- SuDS need to be provided and a drainage strategy submitted;
- That upgrades to the foul water infrastructure network may be required. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

We are also pleased that you have suggested the greenspace could be located in the area of the site at risk of flooding. We strongly support this which would address the sequential approach advocated by the NPPF. A Flood Risk Assessment should support any future planning application to ensure all areas of Flood Zone are correctly identified. You may consider it useful to add this requirement to the policy as a minor amendment.

It would be beneficial if the policy could recognise the relationship of the site to the employment area nearby. There are several permitted waste sites on Rawreth Industrial Estate which could have issues associated with them which would cause nuisance to residents, for example noise, dust, odour and pests.

We support the concept statement acknowledging:
- That approximately 3.1ha of the site is within Flood Zone 2 and 3 and that this land should be set aside for public open space. We strongly support this which would address the NPPF requirement for a sequential approach to be applied. A Flood Risk Assessment should support any future planning application to ensure all areas of Flood Zone are correctly identified. You may consider it useful to add this requirement to the policy as a minor amendment;
- SuDS need to be provided and a drainage strategy submitted

We support the concept statement acknowledging:
- That part of the site is within Flood Zone 2 and 3 and that this land should be set aside for public open space. We strongly support this which would address the NPPF requirement for a sequential approach to be applied. A Flood Risk Assessment should support any future planning application to ensure all areas of Flood Zone are correctly identified. You may consider it useful to add this requirement to the policy as a minor amendment;
- SuDS need to be provided and a drainage strategy submitted;
- That capacity in the foul water network will need modelling at the planning application stage due to capacity issues at the pumping station downstream. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

We support the concept statement acknowledging:
- SuDS need to be provided and a drainage strategy submitted;
- A contaminated land study will be required due to the previous uses of the site.

We support the concept statement acknowledging:
- That part of the site is within Flood Zone 2 and 3 and that this land should be set aside for public open space. We strongly support this which would address the NPPF requirement for a sequential approach to be applied. Further we note your Strategic Flood Risk Assessment shows areas of the site are modelled to be Flood Zone 3b (functional floodplain). The technical guide to the NPPF advises that only water compatible and essential infrastructure uses (as set out in Table 2 of this document) would be appropriate in this area. Open space would therefore be suitable but a Flood Risk Assessment should support any future planning application to ensure all areas of Flood Zone are correctly identified. You may consider it useful to add this requirement to the policy as a minor amendment;
- A contaminated land study will be required due to the previous uses of the site.
- SuDS need to be provided and a drainage strategy submitted
- That capacity in the foul water network will need modelling at the planning application stage due to sewer flooding downstream. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

We support the concept statement acknowledging:
- SuDS need to be provided and a drainage strategy submitted;
- That capacity in the foul water network will need modelling at the planning application stage due to sewer flooding downstream. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

We support the concept statement acknowledging:
- SuDS need to be provided and a drainage strategy submitted. We also note you have highlighted a localised surface water flooding problem which will need to be addressed in the strategy;
- That you have acknowledged upgrades to the foul water infrastructure network may be required. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

However the text in paragraph 3.184 advises that upgrades at Rayleigh Waste Water Treatment Works (WWTWs) are likely to be required prior to development. Rayleigh WWTWs has had its flow measurements certified so we consider it possible to confirm adequate capacity for the development. We would however suggest you seek clarification on this matter with Anglian Water Services before amending the policy.

We support the concept statement acknowledging:
- SuDS need to be provided and a drainage strategy submitted;
- That upgrades to the downstream sewers are likely to be required prior to the development. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

We support the concept statement acknowledging:
- SuDS need to be provided and a drainage strategy submitted;
- That capacity in the foul water network will need modelling at the planning application stage due to downstream sewer flooding events. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed;
- That a management plan is required given the proximity of the site to a Local Wildlife Site.

We support the concept statement acknowledging a contaminated land study will be required due to the previous uses of the site.

However the document advises that there maybe constraints in the foul water infrastructure and therefore a septic tank maybe a more appropriate way to dispose of foul waters. According to our records the nearest main sewer is some distance from the site so provided this is correct then it is appropriate to consider private means of disposal. However you should be aware that a septic tank and soakaway may not be suitable on this site as a soakaway could potentially mobilise contaminants in the ground. If this option for foul water disposal was chosen it would need to be shown that contaminants are not present and will not be mobilised. Further percolation tests would need to be conducted to ensure that conditions are suitable for a discharge to ground.

An alternative option may be to install a package sewage treatment plant and discharge treated sewage effluent into an adjacent watercourse. If this option is progressed then suitable access will be required to ensure there is adequate room for tanker access required to de-sludge.

To address this potential issue you may wish to consider making some changes to the wording of this policy as a minor amendment.

Further information can be found at http://publications.environment-agency.gov.uk/pdf/PMHO0706BJGL-E-E.pdf?lang=_e, http://www.environment-agency.gov.uk/static/documents/Business/EMS_for_discharges_of_secondary_treated_sewage_to_surfacewaters.doc and http://www.environment-agency.gov.uk/business/topics/water/117479.aspx.

You should also note that the watercourses running through the site are classed as 'ordinary watercourses' and the applicant maybe required to obtain a Flood Defence Consent from Essex County Council for works by or in the river.