Policy NE7: Reducing flood risk

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Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 87

Received: 19/10/2016

Respondent: Dr Geoff Lawrence

Representation:

Support Policy NE7:
Orchard Way/Broom Grove in Knebworth, floods frequently. Not surprising, given these houses were built on a Chalk Bourne, one that appears on the National Risk Map. Apparently, the problem is exacerbated by the County building the A1 Motorway over the upper reaches of the Bourne without any sluices. Let's hope the regulations re-potential flooding are enforced more rigorously for the development that this Plan proposes!

Full text:

Orchard Way/Broom Grove in Knebworth, floods frequently. Not surprising, given these houses were built on a Chalk Bourne, one that appears on the National Risk Map. Apparently, the problem is exacerbated by the County building the A1 Motorway over the upper reaches of the Bourne without any sluices. Let's hope the regulations re-potential flooding are enforced more rigorously for the development that this Plan proposes!

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1337

Received: 30/11/2016

Respondent: Sustainable Places, Environment Agency

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to NE7: Sequential approach not clear

Full text:

This policy is not currently in line with National Planning Policy Framework (NPPF) or the findings of your Strategic Flood Risk Assessment (SFRA). The sequential approach is not clear in this policy nor the need to locate development outside of medium to high flood risk areas. However, this only requires simple changes to the policy wording to make it sound. In line with your SFRA findings and site specific policies you should strengthen this policy and state that development should be located outside medium to high risk flood areas (flood zone 2 and 3). The sequences outlined in this policy need to be amended to reflect National Guidance: the NPPF and The Planning Practice Guidance: Flood Risk and Coastal Change. It is imperative that you have a robust policy that emphasises the sequential approach to all development in your area.

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1472

Received: 30/11/2016

Respondent: Mrs Donna Muir

Representation:

Support to NE7:
- Fully support he application of the sequential test however this has not been undertaken for site SP2

Full text:

Fully support he application of the sequential test however this has not been undertaken for site SP2

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1703

Received: 30/11/2016

Respondent: Ms Rachel Keen

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation:

There is no reference for the need for the ST to be applied to surface water flood risk or to groundwater flood risk as defined in the NPPF.

Full text:

There is no reference for the need for the ST to be applied to surface water flood risk or to groundwater flood risk as defined in the NPPF.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4015

Received: 28/11/2016

Respondent: Bedfordshire & River Ivel IDB

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to NE7: Policy should be strengthened to include mitigation to attenuate flows, fundamental that flood risk is minimised and functional and effective infrastructure is provided that is maintainable.

Full text:

The Bedfordshire and River Ivel Internal Drainage Board makes the following comments to your proposed Local Plan 2011 -2031 consultation.

The Plan does not adequately address Flood Risk and should be amended to strengthen the requirements of addressing flood risk and development, particularly in the north of the District in Letchworth and Baldock.

Below are some examples of paragraphs which should be redrafted to ensure development does not have a detrimental effect on flooding:

2.29 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

2.78 The paragraph must include infrastructure that is required to accommodate growth as SuDS which are strategic, integrated and maintained. This is critical given the scale of development in Letchworth (900+ houses) and Baldock (2800 + houses).

3.6 The spatial vision of high quality sustainable design and managing flood risk needs to refer to the provision of strategic and integrated SuDS, which include effective and funded SuDS maintenance.

4.73 Policy SP7. This infrastructure should include SuDS and flood risk management, such that a public authority can ensure drainage infrastructure operates as designed in the future.

4.131 Policy SP11. It is inadequate to state that this Plan 'seeks'.... when other policy state 'will'. The Policy should state the Plan will deliver the provision of strategic and integrated SuDS that will be maintained.

4.136 For clarity, WFD seeks to meet good ecological "potential" for heavily modified and artificial water bodies, as well as good ecological "status" for natural water bodies.

4.137 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

SP14. Downstream of Baldock is Stotfold which has experienced flooding from the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

SP15. Downstream of Letchworth is Stotfold which has experienced significant flooding from the Pix Brook and the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

NE7. There is a requirement to reduce the existing flood risk in Stotfold immediately downstream of the urban runoff areas of Letchworth and Baldock, as in SP14 and SP15, this Policy should be strengthened to include mitigation being designed and implemented on development sites to attenuate flows c) and d). It is fundamental that flood risk is minimised and that functional and effective infrastructure is provided that is maintainable in addition to items e).

NE8. This Policy should include strategic, integrated and maintainable SuDS for all sources of flood risk, and not just surface water, particularly given that flood risk exists from the Ivel and Pix Brook. The area is heavily modified with public storm sewers, modified watercourses and large flood attenuation reservoirs (Pix Brook), so any solution for development needs to be appropriate to the scale of development, rather than simply mimic the natural drainage pattern.

NE8 and 11.59. For developments draining in the Ivel and Pix Brook catchment, the Council and developers should also consult the IDB, as well as the Lead Local Flood Authority and the EA.

NE9. For any development in the Bedfordshire and River Ivel IDB district, a developer will be required to comply with the Board's Byelaws including maintaining a minimum 7 m wide undeveloped buffer zone for ordinary watercourses and applying the land drainage consenting regime.

I trust you find the Board's comments clear and informative.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6128

Received: 21/11/2016

Respondent: Rumball Sedgwick

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to NE7: Adds nothing local to policy set out in the NPPF

Full text:

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