ipswich.gov.uk
DM4
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 25693
Received: 13/03/2019
Respondent: Anglian Water
Generally supportive of policy although we suggest that the policy be amended to include a positive reference to the provision of SuDS, with connections to public sewer being last resort and specific reference to the risk of sewer flooding.
Anglian Water is generally supportive of Policy DM4 particularly the reference to Sustainable Drainage Systems (SuDS) and incorporation of water efficiency measures as part of new development. forming part of the design of new development.
However we would ask that the policy be amended to include a positive reference to the provision of SuDS by making it clear that it is the preferred method of surface water disposal and specific reference to the risk of sewer flooding as outlined in our response to the previous Local Plan consultation.
In respect of water efficiency/re-use we are actively supporting residential developers to include such as part of our Green Water Programme (https://www.anglianwater.co.uk/developers/green-water.aspx). Such measures are not limited to rainwater harvesting and can also include stormwater recycling systems and water recycling systems.
We would therefore suggest that list of measures referred to in the Policy should be extended to include these measures as well as rainwater harvesting.
It is therefore proposed that Policy DM4 is amended as follows:
'a. it does not increase the overall risk of all forms of flooding in the area or elsewhere through the layout and form of the development and appropriate application of Sustainable Drainage Systems (SuDS;
b. That no surface water connections are made to the foul system and connections to the combined or surface water system is only made in exceptional circumstances where it can be demonstrated that there are no feasible alternatives (this applies to new developments and redevelopments);
c. that adequate sewage treatment capacity and foul drainage already exists or can be provided in time to serve the development;
d. it will be adequately protected from flooding in accordance with adopted standards wherever practicable;
e. it is and will remain safe for people for the lifetime of the development; and
f. it includes water efficiency measures such as water re-use, stormwater or rainwater harvesting, or use of local land drainage water where practicable.'
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 25763
Received: 12/03/2019
Respondent: Natural England
We recommend that Policy DM4 includes a requirement for proposals to demonstrate that the method of surface water disposal will not have any adverse effect on European and nationally designated sites.
See Scanned Representation.
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 25943
Received: 12/03/2019
Respondent: Environment Agency
Policy DM4 - Development and Flood Risk. The SFRA is again mentioned here and needs to be updated to remain useful. Paragraph 9.43 refers to the suitability of different types of developments within the various flood zone classifications. It should be noted that the Flood Zones will have changed and the outline of Flood Zone 3b may need to be updated. Plan 2 - Flood Risk, dated November 2018 maps the flood zone. This is different to our current flood maps. Our flood map for planning was updated on 31 January 2019
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 25944
Received: 12/03/2019
Respondent: Environment Agency
Paragraph 9.44 refers to the Ipswich Level 2 SFRA providing the necessary information to help facilitate the sequential approach as outlined in the NPPF demonstrating the application of the sequential test is essential. We are currently reviewing the Sequential and Exception Test statement and will advise of any further work required.
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 25945
Received: 12/03/2019
Respondent: Environment Agency
We are pleased to see that paragraph 9.4.9 requires the production of site specific FRAs to include detailed flood modelling to ascertain flood risk. However, the paragraph also refers to the SFRA. As previously stated, you may wish to update your SFRA because there is new ENS (Essex Norfolk and Suffolk) Coastal Modelling 2018, to which site specific Flood Risk Assessments would have to refer to in line with paragraph 160 of the NPPF.
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 25946
Received: 12/03/2019
Respondent: Environment Agency
Paragraph 9.4.10 states that "FRAs for proposals in Zones 2 and 3 need to clearly state the frequency of flooding in and around the site and, until the EA's flood defence barrier is implemented, will need to assume existing defences are in place". This sentence is now no longer fully applicable as the tidal barrier is now complete and operational and should be updated accordingly. The paragraph should also consider residual risk.
Object
Preferred Options Core Strategy and Policies Development Plan Document (DPD) Review
Representation ID: 26010
Received: 13/03/2019
Respondent: Suffolk County Council
Clarify that part b) means the countywide flood risk guidance as source of 'adopted standards'. Also clarify that 'wherever practicable' point refers to the application of SuDS standards, rather than the requirement to ensure adequate protection from flood risk.
Support intent of clause (d) and keen to support measures which encourage water efficiency, but unclear how this criteria is intended to operate alongside the requirement in DM1.
A discussion on the best policy mechanism for encouraging re-use of land drainage water recommended.
Amend paragraph 9.4.8 to explain linkage between Plan, SPD and countywide guidance rather than paragraph 8.41.
See Scanned Representation.