Core Strategy - Consultation Draft

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54 comments.

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Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/3
  • Status: Accepted
We would disagree that CS3 meets the requirements of PPS25, as it provides little recognition of the flood hierarchy approach, sequential test and sequential approach, or that the Strategic Flood Risk Assessment (SFRA) Level 1 and draft Level 2, have been applied to inform the Areas of Search.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/21
  • Status: Accepted
General note: NSC need to highlight all sources of flood risk as described in the SFRA. NSC need to have better linkage with the Climate Change Policy and consider all sources of flood risk i.e. ground water and surface water. Both of these flood sources are very relevant to WSM.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/26
  • Status: Accepted
Para 3.53 - Needs to be clearer, making reference to Tables D1, D2 and D3 of PPS25. NSC need to inform developers that "Non-Allocated" sites, i.e. windfalls are subject to the Sequential Test. PPS25 Practice Guide recommends that the LPA considers any policies they require to control these developments e.g. change of use where the vulnerability will be higher post development. EA would welcome clarification regarding the nature of change of use NSC would permit in Flood Zones 2 and 3.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/29
  • Status: Accepted
Catchment Abstraction Management Strategies currently class two catchments within this area as 'Over-licensed'. It is essential to consider water efficiency in conjunction with any new developments. Increased abstractions for public water supply and the impacts of climate change will ultimately put extra pressure on surface water and groundwater supplies. Any new developments must ensure that these pressures on the environment are minimised.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/22
  • Status: Accepted
Para 3.41 - Again you assume mitigation and compensation. Has the Sequential Test been passed? The flood risk hierarchy should be followed and the Sequential Test applied to avoid the flood risk areas as stated above. Mitigation should only be considered for Flood Zone 3 & 2 sites once it has been demonstrated there are no alternative sites in FZ1. The Level 2 SFRA should demonstrate that development can be made safe in accordance with PPS25.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/24
  • Status: Accepted
Para 3.50 - Last sentence beginning "For development control...." is incorrect. NSC must refer to the SFRA Level 1 and Level 2 (when completed and approved) for everyday screening of planning applications. We applaud NSC for looking at the future floodplain areas to inform their site allocation process as this is more sustainable. This approach should not be used for windfall/everyday applications but site specific FRA's should establish if they are safe for the lifetime of the development.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/18
  • Status: Accepted
Box does not meet PPS25 objectives. Message from first para implies simply moving towards mitigation? Need to apply the flood risk hierarchy to determine if the risk can be avoided. Second para beginning "Development in..." is incorrect. Refer to the Level 1 SFRA and NOT the EA Flood Maps, and use this document to inform the locations of allocations. Second bullet point starting "development of the same..." must clearly state that existing allocations have been Sequentially Tested.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/27
  • Status: Accepted
Para 3.55 - Last sentence starting with "Developers should have....." Developers need to be able to review the councils SFRA as part of the FRA process.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/19
  • Status: Accepted
Section 1 - No immediate concerns here as NSC are attempting to define the geographical area for the Sequential Test. This again should be informed by the NSC SFRA. Unfortunately, there is no reference to the completed SFRA or its use to inform your spatial planning. By referencing to the SFRA this will inform developers that they need use this planning tool for the Sequential Test.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS3: Environmental Risk Management CS3: Environmental Risk Management

  • Comment ID: 1020673/CSCD/25
  • Status: Accepted
Para 3.52 - The Agency welcomes the reference to "Avoid flood risk". This should also be referred to in the Climate Change Policy.
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