Core Strategy Consultation on Strategy Directions 2008

Object

Representation ID: 19476

Received: 24/02/2009

Respondent: Environment Agency

The Environment Agency concur that any site considered for use by gypsies and travellers adheres to the same assessment as other types of development.
The risk to gypsy and traveller sites may be also increased in vulnerable areas due to the potential for non mains drainage to be used.
Gypsies and Travellers sites on page 98, criterion (vi) should include the avoidance of Source Protection Zones and contaminated land.
Page 98 Criterion (vi) a. should read "Sites on or near refuse tips or contaminated land".
Page 98 Criterion (vi) b, should read "Flood Zones 3a and 3b".
Paragraph 10.22 on page 90 should refer to the high vulnerability of residential mobile homes in areas at risk of flooding.

Object

Representation ID: 19477

Received: 24/02/2009

Respondent: Environment Agency

It is acknowledged that residential mobile homes provide a valuable source of affordable housing, however these types of dwellings are also classed as 'highly vulnerable' in PPS25. Therefore unlike conventional housing residential mobile homes will not be permitted in Flood Zones 3a or 3b, regardless of the Sequential and Exception Test or Flood Zone 2 where the Sequential and Exception Tests cannot be demonstrated. Recommendation 9:
Paragraph 10.22 on page 90 should refer to the high vulnerability of residential mobile homes in areas at risk of flooding.

Object

Representation ID: 19478

Received: 24/02/2009

Respondent: Environment Agency

The Environment Agency request that the Aims and Objectives (Box 27) on page 109 includes the identification and appropriate measures to address any land affected by contamination within the district, in order to leave a legacy of clean land and create a better place and a healthy environment.
Recommendation 10:
Box 27 on page 109 should include a further objective: "(viii) To secure the remediation of land affected by contamination"

Comment

Representation ID: 19479

Received: 24/02/2009

Respondent: Environment Agency

Sustainable Resource Management
Under the proposed policy 'Strategy for Sustainable Resource Management' (Box 31) as a minimum we would support Option 1, but encourage Option 2 which sets higher levels than the minimum sustainability requirements of the Code for Sustainable Homes (CSH). We must also be clear that under our remit we are in support of the water efficiency levels set for each CSH Level in order to protect our precious water resources in the Southern Water and South East Water supply area which is defined by our national water stress maps as an 'area of serious water stress'.

Object

Representation ID: 19484

Received: 24/02/2009

Respondent: Environment Agency

We support the 'Preferred Strategy for Water Supply and Wastewater' in Box 32 .We consider that a particular reference to the environmental water quality would contribute to maintaining or improving the overall status of water bodies in Rother under the EU Water Framework Directive (WFD). We recommend that the wording of Criterion (iv) is amended as below.

Page 118 - Box 32 - Amend wording of criterion (iv) to read: "permit development only if it has no adverse effect on the environmental water quality and potential yields of water resources".

The Strategy could ensure the creation of buffer zones for any development that occurs near watercourses - this would help reduce their contribution of diffuse pollution from urban development.

Object

Representation ID: 19485

Received: 24/02/2009

Respondent: Environment Agency

The Environment Agency request that in order to protect vulnerable groundwater, development should avoid Source Protection Zones (SPZ) especially the most vulnerable SPZ1. In order for this to be ensured, we recommend that an extra criterion is added to The Preferred Strategy for Water Supply and Wastewater in Box 32 on page 118 related to the avoidance of SPZ1
Recommendation 12:
Box 32 on page 118 should include an extra criterion which should read: "(vi) Safeguarding groundwater quality by the avoidance of Source Protection Zone 1 as defined by the Environment Agency".
GWCL Comments

Object

Representation ID: 19486

Received: 24/02/2009

Respondent: Environment Agency

Flood Risk
We support the inclusion of a Flood Risk Policy in the Strategy Directions. We do however, recommend that some minor changes are incorporated. With regard to regeneration in areas of flood risk, we recommend that Paragraph 12.42 is rewritten to reflect the requirement of Criterion a) of the Exception Test. This seeks to ensure that where a site has been sequentially tested and the principle of development has been accepted, it must be demonstrated that the development provides wider sustainability benefits as set out in PPS12

Object

Representation ID: 19487

Received: 24/02/2009

Respondent: Environment Agency

Currently the Strategy links developing outside of flood areas with decline in economic activity in general. It would be the case that for development proposed within Flood Zones 2 or 3 a Sequential Test would need to be satisfied if the principle of development on any particular site were to be accepted. This would ensure that development is directed away from areas at highest risk of flooding. In this case, any development on the site would need to meet the Exception Test which includes the justification of achieving wider sustainability benefits, which would include regeneration and economic development. See Recommendation 13.

Remove Paragraph 12.42 as the justification for developing sites within flood risk areas will be established through the application of PPS25 using the Sequential Test and where appropriate the Exception Test. This will ensure that the relationship between flood risk, economic development and sustainability is properly represented.

Object

Representation ID: 19488

Received: 24/02/2009

Respondent: Environment Agency

It is accepted that where there is an identified need for regeneration, some development within the floodplain may be inevitable. If this can be justified with PPS25 the sites themselves should be sequentially tested; to ensure that higher vulnerability uses are located on parts of the site that are at lower risk of flooding.
Recommendation: Page 119-120. Criteria (d) and (h) from Box 33 should be removed as it repeats the provisions of PPS25 and a further criterion should be added: "Ensure that where the principle of development has been established on a site within an area of flood risk in accordance with PPS25, the layout and distribution of development is informed by any variation in flood risk across the site according to land use vulnerability".

Comment

Representation ID: 19489

Received: 24/02/2009

Respondent: Environment Agency

We consider that the Strategic Flood Risk Assessment should be a document used for the implementation of the Strategy for Environment and therefore included in the list in paragraph 12.45. See Recommendation 15.
Page 120 - Paragraph 12.45 should include a bullet point to read "Strategic Flood Risk Assessment".