Comment

Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List

Representation ID: 21689

Received: 25/09/2014

Respondent: Environment Agency

Representation Summary:

We are pleased to note that "Flood Mitigation" is on the Reg.123 list, however we have the following recommendations.

There is the potential for new defence structures being required and in its current form Flood Mitigation would not cover new defence requirements. As such we would recommend amendments to the Regulation 123 List.

Under the heading "Environment" we would ask that the "Leisure, sport, open space and green infrastructure" section of the List is amended to include Environment, with reference to improving water quality, and the requirements of the Water Framework Directive.

Full text:

We have no comments to make on your proposed charging schedule.
With regards to your proposed Regulation 123 list (Appendix 2), we are pleased to note that "Flood Mitigation" is on the list, however we have the following recommendations.
There is the potential for new defence structures being required and in its current form Flood Mitigation would not cover new defence requirements. For example, the Infrastructure Delivery Plan June 2014 (IDP) identifies the potential for new construction of slope toe defence structure. As such we would recommend the following amendments to the text in the Regulation 123 List (List).
"Flood Defence and Mitigation
New flood defence construction.
Maintaining and improve flood and coastal defences"
We also note the exclusion "All other site specific SUDS and on-site flood mitigation improvements as identified in a site specific assessment", which we acknowledge would be a matter for addressing through the planning application process.
We would also like to draw your attention to the other service and issues identified within the IDP under the heading "Environment". Unfortunately the IDP and Regulation 123 do not appear to correlate, headings wise, so it is difficult for the reader to determine whether those matters in the IDP have been included in the List. It would appear not, therefore we would ask that the "Leisure, sport, open space and green infrastructure" section of the List is amended to include Environment, with reference to improving water quality, and the requirements of the Water Framework Directive.