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Canlyniadau chwilio Environment Agency

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DS3 Supporting Sustainable Communities

ID sylw: 66451

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Recommend two amendments to chapter 2.8
Within point .a) physical infrastructure the text should be amended to include
'Flood defence structures' within the examples given.
We would recommend that point c) of this policy is expanded to highlight the multiple benefits that green infrastructure can deliver, in your policy the provided examples include parks, open space and playing pitches.
Does not accurately identify range of ecosystem services that green infrastructure provides, including surface water management and improving water quality, through Sustainable Drainage Systems (SuDS), habitat and green routes for biodiversity movement, to support nature conservation/expansion of habitat. Assists with reducing the urban heat island by providing thermal cooling as an adaptation of climate change in addition to providing health and social benefits. It should be considered as integral to all new developments rather than as separate entity such as formal green space for recreational uses.
c) Recommend bullet point be amended to include the following text:
„Ecosystem services including Sustainable Drainage Systems (SuDS), expansion of habitat and as an adaptation to climate change „is added to the end of the sentence.

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DS4 Spatial Strategy

ID sylw: 66452

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Support this policy and welcome the prioritisation of brownfield redevelopment first approach advocated by this policy, however:
Recommend that point f) be amended to include the following text
'or other highly sensitive features in the natural environment (included designated sites for nature conservation) will be avoided'
Recommend insertion of the following statements:
„h) sensitive groundwater resources (i.e. source protection zones) supporting public water supply boreholes are protected'.
i) ensure that development is not at risk of flooding, does not increase flood risk elsewhere and will reduce flood risk overall.‟ DS7 Meeting the Housing Requirement
In chapter 2.23 we note that this approach provides the opportunity to investigate and remediate any contaminated land. Development proposals should be supported by Preliminary Risk Assessment (i.e. Desk study, conceptual model and initial assessment of risk on controlled waters receptors). DS10, DS11& DS15: The EA supports council‟s preference for allocating PD sites. Development proposal should be supported by Preliminary Risk Assessment (i.e. Desk study, conceptual model and initial assessment of risk on controlled waters receptors).
Development proposals should take into consideration the EA's groundwater protection policy (GP3) to ensure that groundwater resources are not impacted as a result of development.

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EC2 Farm Diversification

ID sylw: 66453

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Recognise importance of farming to the rural economy, and need to support diversification into non agricultural activities. However farm diversification can involve range of activities from recreational to energy production that may have negative impact upon the environment. Therefore recommend insertion of the following statements into the policy:
'd) Farmland is important for nature conservation and biodiversity. Enhancements to maintain ecological resilient networks through the countryside should be incorporated to proposals. e) Connectivity of riparian corridors are maintained and protected with buffer margins and tree planting
f) There will be a presumption against development that could lead to the degradation of the Water framework Directive (WFD) status of the waterbody should not be permitted'.

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CT6 Camping and Caravan Sites

ID sylw: 66454

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

EA recognises importance of these sites for holiday use is important to local economy, but this needs to be balanced with the requirements of European Directives and the NPPF.
In line with existing practice guidance for the NPPF we note that Camping and Caravan parks are classified as „highly vulnerable‟ and that planning permission must not be granted for sites located within flood zone 3, and that the exception test must be granted for sites within flood zone 2.
We recommend that a precautionary approach be taken and we recommend the insertion of the following policy wording:
'There is a presumption against locating camping and caravan sites within the flood plan because of their vulnerability within a flood event'
The Environment Agency is concerned about the potential impacts that new camping / caravan sites may have on meeting the requirements of the Water Framework Directive, specifically in relation to the provision of foul waste infrastructure.
During the year there may be significant peaks in use of toileting precautionary approach taken and recommend insertion of the following policy wording:
'There should be a presumption against development of new camping and caravan sites that can not demonstrate adequate provision for the management and discharge foul / waste water'.
Refer you to letter sent to your Authority in relation to the preferred options consultation - Sites for Gypsies and Travellers ref UY/2007/101229/SL-04/PO1 - LO1 dated 09 May 2014. where there us more detailed information about potential allocations, and provides supporting evidence for policy recommendations.

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CT7 Warwick Castle and Warwick Racecourse/St Mary's Lands

ID sylw: 66455

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Acknowledge need to allow new development within this area that is sensitive to heritage assets; recommend that the following policy wording is added to the policy:
f) Identify how the proposals will contribute to EU Water Framework Directive and the Severn River Basin Management plan which requires the restoration and enhancements of water bodies to prevent deterioration and promote recovery of waterbodies.
We have the following information about the watercourse status as determined under WFD objectives.
GB109054043800 (Gog Brook from Source to confl with R Avon) is failing WFD with Moderate status (2009)
GB109054044402 R Avon (Wark) conf R Leam to Tramway Br, Stratford is failing WFD with Moderate status (2009)
To meet the requirements of the WFD objectives these waterbodies must reach good ecological status, all new development within this area must contribute to meeting this objective.

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MS2 Major Sites in the Green Belt

ID sylw: 66456

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Note that the major sites include Stoneleigh Park and Stoneleigh Deer Park. The watercourse in this area is failing to meet good status as defined by the WFD, specifically waterbody GB109054043840 R Avon (Warks) - conf R Sowe to conf R Leam is failing WFD with Poor status (2009).
It is imperative that any new development contributes positively to improving quality of this watercourse.
Recommend that the following policy wording is added to the policy:
'Identify how the proposals will contribute to EU Water Framework Directive and the Severn River Basin Management plan which requires the restoration and enhancements of water bodies to prevent deterioration and promote recovery of waterbodies'.

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H1 Directing New Housing

ID sylw: 66457

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

In line with recommendations within Halcrow Water Cycle Study 2010, which recommends that:
„Floodplains should be safeguarded from future development and local authorities must apply the Sequential Test to ensure all new development is directed towards Flood Zone 1 in the first instance.
Opportunities should be taken to reinstate areas of functional floodplain which have been previously developed and Flood Zones 2 and 3 should be left as open space‟
Recommend addition of the following points within the policy wording:
vi) the development is not at risk of flooding and will not increase the risk of flooding elsewhere.
vii) All development proposals should be discussed with STW at the earliest possible opportunity, to understand the constraints for development and potential upgrades required to ensure the provision of adequate foul/ waste water infrastructure.'

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H5 Specialist Housing for Older People

ID sylw: 66458

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Specialist Housing for Older People Residential care home are classified as "more vulnerable" in accordance with Table 2 of NPPF and are therefore considered appropriate in Flood Zones 1, 2 and 3a (Exception test required).
However, as the occupants are less mobile they are particularly vulnerable in a flood event, making evacuation more difficult. With this in mind, we recommend that you consider adding criteria:
'd) the proposed site is located in Flood Zone1.'

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H6 Houses in Multiple Occupation and Student Accommodation

ID sylw: 66459

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

Correctly identified that household waste management is often an issue at HMO‟s and Policy H6 e) requires that adequate provision is made for storage of refuse containers in new HMO‟s and that storage areas do not impact on the amenity of the local area.
While we would support this policy it is also important to ensure that not only is the space provided adequate but it is also appropriate to the functioning of the HMO.
For example there should be appropriate storage space internally at the point of arising as well as externally in order to minimise number of trips required to outside storage areas. The distance that occupants need to travel to access waste storage areas should also be considered as carrying waste beyond a certain distance may cause inconvenience and result in reduced participation in collection arrangements.
Distance between waste storage areas and waste collection points should also be considered. Routing and access for waste collection vehicles will also be important. In addition clear signage should be provided to identify what waste streams can go into each waste receptacle, this will be especially important for transient populations who may not be familiar with the authorities waste collection arrangements.

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H8 New Gypsy and Traveller Sites

ID sylw: 66460

Derbyniwyd: 27/06/2014

Ymatebydd: Environment Agency

Crynodeb o'r Gynrychiolaeth:

In line with existing practice guidance for the NPPF we note that Gypsy and Traveller sites are considered to be „highly vulnerable‟ and that planning permission must not be granted for sites located within flood zone 3, and that the exception test must be granted for sites within flood zone 2.
Recommend a precautionary approach and recommend the insertion of the following policy wording:
f) 'There is a presumption against locating camping and caravan sites within the flood plan because of their vulnerability within a flood event
g) The site will not impact on important designated sites for nature conservation.
h) Riparian Corridors are protected.
i)There should be a presumption against development of new traveller and gypsy sites that can not demonstrate adequate provision for the management and discharge foul / waste water'

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