MM21

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Support

Schedule of Main Modifications and changes to Policies Maps

Representation ID: 24632

Received: 09/09/2019

Respondent: Environment Agency

Representation:

We are also pleased with the amendments in MM21 - Amend Policy BRO2, its supporting text and the Detail Map regarding sewerage capacity arrangements and amendment to the site boundary to reflect a recent planning application delegated to approve, regarding sewage capacity.

Full text:

We have reviewed the information submitted and have the following comments to make:

MM8 - Amendment to paragraph 6.43 to accord more closely with the PPG as to where ecological surveys and reports are required.
We agree with this modification.

MM13 - Additional reinforcement of the sewerage network will be required to serve the development and therefore, the developer will need to work with Southern Water to ensure necessary infrastructure is provided prior to occupation.
We are pleased to note that the new paragraph after 9.60 (and subsequent consequential paragraph number amendments) will be inserted as stated in the MM13 and the additional policy criteria in policy BEX4 (and subsequent consequential criteria number amendments). We are also pleased with the amendments in MM19 - Additional text in policy HAS2 and its supporting text that requires proposals do not impact water quality in the adjacent Park Wood gills and MM21 - Amend Policy BRO2, its supporting text and the Detail Map regarding sewerage capacity arrangements and amendment to the site boundary to reflect a recent planning application delegated to approve,
regarding sewage capacity.

MM14 - To include the requirement for an Appropriate Assessment at planning application stage & MM15 - To include the policy requirement for two stages of SuDS and an Appropriate Assessment at planning application stage.
We are pleased with the amendments made in both of these. Regarding the two stages of SuDS and an Appropriate Assessment at planning application stage.

MM17 - Amendment to the wording of the policy and supporting text to reflect that there are two culverts running through the site.
We are pleased with the 8 metre from the culverts. Although when possible we would suggest de-culverting, to bring rivers to its natural shape and benefit biodiversity in the area.

MM27 - Additional criterion added to Policy RHA1 and its supporting text regarding on the adjacent Natura 2000 Sites.
We are satisfied with the Additional criterion added to Policy RHA1 and its supporting text regarding on the adjacent Natura 2000 Sites. In particular the amendments to paragraphs 11.197 and 11.200.

MM28 - Additional criterion added to Policy RHA2 regarding on the adjacent Natura 2000 Sites, with additional supporting text & MM29 - An additional criterion is added to require an appropriate drainage scheme with any submitted planning application.
We are pleased that our comments were taken into consideration.

Environment, Environmental pollution
Section 6.78 (Page 95) and Section 6.96 Contaminated Land (Page 98) and Policy DEN7: Environment Pollution (Page 99)
We are pleased that our advice "reference to contaminated land should be changed to say "Land Contamination". Contaminated Land has a specific definition under the Environment Act 1990 Part IIA Regulations." Was taken into account and included in the local plan.

Part A: Development Policies
2. Resource management, Water Efficiency
Policy DRM1: Water Efficiency (Page 20)
We couldn't find any reference to our previous comments regarding this policy:
We are disappointed not to see requirements for water efficiency measures for commercial developments. We would expect to commercial developments required to meet BREEAM "excellent" or "very good" as a minimum. Other councils including Rother's neighbour Folkestone and Hythe have policies requiring such suggested standards. We would query why the LPA has seen fit not to mention BREEAM standards.

These comments were first made when responding to your consultation Examiners main Matters, Issues and Questions document, Matter 4 - Development Policies and the question regarding Resource Management.