Local Plan 2011-2031 Proposed Submission Draft

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.

We consider this policy is unsound on the grounds of being justified and consistent with national policy. The policy does not adequately reflect on Water Framework Directive (WFD) issues in North Hertfordshire and shows its aspirations for the protection and improvement of its waterbodies overall. The policy to date only makes reference to water quality and water resources aspects of the WFD. We maintain our view that this policy title should be changed to reflect wider WFD issues. We consider that this policy would work better by being separated into two: Water Framework Directive and Wastewater infrastructure. However as this plan is advanced, we suggest that the policy is divided into two sub parts to prevent confusion.

We find this policy unsound because it is not consistent with national policy. The policy does consider sensitive locations (Source Protection Zones) or emphasise the requirements for developers and/or landowners to secure a safe development tackling unacceptable risks from pollution. However with a few simple changes and incorporation of our suggested supporting text we can find this policy sound.

We previously highlighted historic landfill featuring on site EL1 but this has not been referred to in the site specific policy SP19.

Policy SP17: Site HT1
We previously highlighted that a Preliminary Risk Assessment (PRA) would be required but this has not been included.

We previously mentioned that there are two waste sites within approximately 150 and 200 metres respectively of RY9. These sites operate under a permit from the Environment Agency. You should be aware that workers/occupiers may have some impacts from these nearby developments, including noise, litter and traffic. As long as the operators of the sites can show that they are complying with the terms of their permits to mitigate these impacts, we would be unlikely to revoke their permit.

BA10 - Royston Road [Baldock]
We previously highlighted that a Preliminary Risk Assessment (PRA) would be required but this has not been included

We have no concerns with this site being allocated providing our previous recommendations are addressed. We previously mentioned that there was Potential contamination from previous uses (farmland) but the requirement for a Preliminary Risk Assessment has not been included within the policy text. While all the proposed development is in Flood Zone 1, you are aware that there is significant Surface water and fluvial flood risk to the proposed access (Stevenage Road) to the site. With this in mind you should strengthen the policy by specifying the need for a site-specific Flood Risk Assessment (FRA) as we previously mentioned

We agree with the policy outlined for this site. If the applicant is looking to build within flood plain they will need to produce a more detailed model for this part of the watercourse as they will need to provide the 1% (1 in 100 year) AEP flood level and the upper central and higher central climate change allowances for the site to produce an appropriate Flood Risk Assessment.

we support this policy and are satisfied that our previous comments have been incorporated