Allocations Submission Document

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;
- That any habitat loss associated with the exiting ponds on site and watercourse will need to be mitigated against.

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.

However the policy currently advises that capacity in the foul water network will need modelling at the planning application stage. As with site GT1 which lies adjacent to the site, our records indicate that the area is not served by a main sewer. It may therefore be appropriate to consider private treatment options. The applicant would however need to gain either an Environmental Permit or an exemption from us for this activity under the Environmental Permitting Regulations 2010 for the discharge of water.

You should also be mindful that trade effluent is often not suitable for discharge to a small package sewage treatment plant or septic tank with soakaway. If a connection to the public foul sewer is not available then consideration would need to be given as to how this effluent was managed. The Policy mentions that some existing businesses from Rawreath Industrial Estate could be relocated to this site. Some of these sites produce trade effluents that may not be suitable for private disposal so alternative locations may have to be considered.

If you are considering a connection to the mains system we would support this approach and would consequently anticipate that site GT1 would also connect to this system.

Further Environmental Permits would need to be obtained for any proposed waste operations.

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;
- Green buffers should be provided which have an ecological value.

We are pleased to note the school will be located outside of the flood zone.

We are pleased to note the school will be located outside of the flood zone.

We support the inclusion of this policy which protects existing open space.

We support the promotion of new open space which will hopefully be designed and maintained to ensure it has multiple environmental benefits.

We are pleased that figure 45 identifies the flood zones and national/ international designations in the District.

We have an outstanding holding objection for a planning application at this site, referenced 11/00494/FUL, on flood risk grounds.

To date the developer has been unable to submit information which demonstrates the flood defence works, required to make the development safe from flooding for its lifetime, can be delivered and maintained in perpetuity. We have discussed a couple of options with the developer but none have yet been demonstrated as viable. The first scheme required the adjacent landowners consent to construct the defence on their land, which could not be agreed, and the second proposal has issues with the juxta-position of the watercourse and footway adjacent to Mill Lane.

There may well be alternative schemes that the developer can consider but they have yet to be presented to us. Further given the strategic importance of this site to the Council, they could use their Compulsory Purchase Powers to make the first option work. We also have Permissive Powers and Compulsory Purchase Powers for defences but these are not indented to facilitate new defences for new development, especially where other bodies have the same powers.

There is therefore a risk that the site is not deliverable as evidence has yet to be provided that a viable scheme can be provided. We do not however consider this to be a matter which falls directly within our statutory remit but it is a matter which we wish to bring to the inspectors attention.

In addition please note that paragraph 2.55 advises the Sequential Test needs to be passed for any future development of the site. We remind you that you considered and passed this Test for your Core Strategy. In accordance with paragraph 104 of the NPPF this Test does not need to be applied again. We therefore suggest you remove this reference by way of a minor amendment.

Finally we wish it to be noted that we support the concept statement acknowledging:
- SuDS need to be provided and a drainage strategy submitted;
- That you have acknowledged upgrades to the foul water infrastructure network maybe required;
- That a management plan will be required given the proximity of the site to national and international designations.

As detailed in our representations to Policies BRF1 and SER9, there is a certain level of uncertainly about the capacity of Southend Waste Water Treatment Works to accept all the growth planned in its catchments. With this in mind it should be acknowledged as a potential risk and the situation monitored over the plan period.

For Policy BFR3 (Stambridge Mills) the table states 'Flood Risk Assessments of the site have been produced which demonstrate that flood risk can be mitigated through improvements to defences'. It continues to say the Council will work with the developer and us to ensure appropriate flood mitigation measures can be delivered. As set out in our representations to Policy BFR3, this has yet to be demonstrated.