Sites for Gypsies and Travellers

Preferred Options Consultation - Land at Stratford Road, Warwick

Thank you for consulting the Environment Agency in relation to the above preferred options consultation which we received on 31 October 2014.

The Environment Agency requires further information in relation to flood risk before we are able to recommend the inclusion of the above site be included in the site allocations that are safeguarded for Gypsies and Travellers.

Flood Risk
The preferred site shown in Map 1 of the Sites for Gypsies and Travellers Preferred Options Consultation Land at Stratford Road, Warwick Document Dated October 2014 is within Flood Zone 3.

The detailed modelling we have of this area is the River Avon 2009 Model, which demonstrates that there is no risk of flooding to the site from the River Avon. The model shows the site which is on the right bank of the watercourse is 3m higher than the left bank.

However there is no reference provided for the technical report referred to on page 5 of this consultation document.

This site is has recently been introduced to the consultation process, and fell outside of the detailed consultation we provided on the 44 sites previously submitted we ask that any information regarding the flood risk to this site is re-submitted.

Additionally the wording in your consultation document is not clear on the perceived risk of flooding to the site from the brook. There should be an investigation to assess the level of flood risk that the brook poses to the development site. It is possible that this could pose an unacceptable risk of flooding to the site and this must be assessed at the earliest possible opportunity.

Protection of Controlled Waters
Reference to the 1:50,000 scale geological map Sheet 184 (Warwick) indicates that the site is located on Triassic Mercia Mudstone which is designated a 'Secondary B Aquifer' by the Environment Agency. Superficial River Terrace Deposits of are indicated for the site which are designated as a 'Secondary (A) Aquifer'. The River Avon is located adjacent to the site.

We are not aware of contamination issues relating to this site however this does not preclude the possibility of contamination existing due to current or former site uses. Government Policy, as detailed in the National Planning Policy Framework (paragraph 120), states that "where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner".

Should the site currently or formerly have been subject to land-use(s) which have the potential to have caused contamination of the underlying soils and groundwater then any Planning Application must be supported by a Preliminary Risk Assessment to demonstrate that the risks posed to 'Controlled Waters' by any contamination are understood by the applicant and can be safely managed.

We will object when a Planning Application is submitted without a Preliminary Risk Assessment and we believe there is potential for contamination and a possible risk to 'Controlled Waters' receptors.

Site investigation, risk assessment and remediation may subsequently be required depending upon the findings of the Preliminary Risk Assessment.

We actively encourage the use of SuDS at new developments, however proposals for the drainage of surface or roof water into the ground will need to take into account the findings of the Preliminary Risk Assessment and any subsequent site investigation. If contamination is present and surface water is to be drained to ground then the contamination risk assessment will need to consider the additional infiltration from the surface and roof water system(s).

The discharge of treated sewage effluent into surface water or to ground may require an Environmental Permit from us. The granting of planning permission does not guarantee the granting of an Environmental Permit - a permit will only be granted where the risk to the environment is acceptable. At the time of applying for relevant authorisation the applicant will have to justify why connection to the public foul sewer is not possible.

Our guidance document 'EPR H1 technical annex to annex (j) Horizontal Guidance H1 - Annex J 4 Groundwater risk assessment for treated effluent discharges to infiltration systems' comments that "It is recommended that chemical toilet waste is not discharged to a package treatment plant, as the chemicals may poison the treatment system and cause pollution." Consequently should it be proposed to discharge foul effluent generated by this development to ground, a separate contained system will be required to take chemical toilet waste.




In conclusion
We look forward to further engaging with you in relation to the flood risk issues for the above site allocation.

We trust that you will find these comments useful. Should you have any questions please do not hesitate to contact me on the number provided below.