Allocations Submission Document

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Support

Allocations Submission Document

Policy NEL1 - South of London Road, Rayleigh

Representation ID: 28727

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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.

Full text:

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.

Support

Allocations Submission Document

Policy NEL2 - West of the A1245, Rayleigh

Representation ID: 28728

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

General support but we are offering advice onthe appropriateness of using private treatment for some waste land uses.

Full text:

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.

Support

Allocations Submission Document

Policy NEL3 - South of Great Wakering

Representation ID: 28729

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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.

Full text:

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.

Support

Allocations Submission Document

Policy EDU1 - North of London Road, Rayleigh

Representation ID: 28730

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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

Full text:

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

Support

Allocations Submission Document

Policy EDU2 - West Rochford

Representation ID: 28731

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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

Full text:

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

Support

Allocations Submission Document

Policy OSL1 - Existing Open Space

Representation ID: 28732

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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

Full text:

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

Support

Allocations Submission Document

Policy OSL2 - New Open Space

Representation ID: 28733

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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

Full text:

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

Support

Allocations Submission Document

Characteristics Map

Representation ID: 28734

Received: 24/01/2013

Respondent: Environment Agency

Representation Summary:

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

Full text:

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

Support

Allocations Submission Document

Policy BFR3 - Stambridge Mills, Rochford

Representation ID: 28805

Received: 25/01/2013

Respondent: Environment Agency

Representation Summary:

There is a potential risk about the delivery of the site which we are bringing to the inspectors attention. We are also suggesting a minor amendment to the reference made in para 2.55 to the Sequential Test.

Full text:

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.

Object

Allocations Submission Document

IDM - Brownfield Residential Land Allocations

Representation ID: 28807

Received: 25/01/2013

Respondent: Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Changes required to policies BRF1, BRF3 and SER 9

Full text:

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.

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