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 CS1: Addessing Climate Change and Carbon Reduction CS1: Addessing Climate Change and Carbon Reduction

  • Comment ID: 1020673/CSCD/11
  • Status: Accepted
Principle 10) is unsatisfactory. Mitigation, including resilience, is the last step in the Flood Risk Management Hierarchy provided by the PPS25 Practice Guide (Assess - Avoid - Substitute - Control - Mitigate). Core Strategy should emphasise avoiding flood risk, locating vulnerable development at lowest flood risk and controlling flood risk over the lifetime of development including flood risk as stated by the SFRA's.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Ensuring Safe and Healthy Communities CS25: Children, Young People and Higher Education CS25: Children, Young People and Higher Education

  • Comment ID: 1020673/CSCD/41
  • Status: Accepted
NSC Level 1 and 2 SFRA must influence the location and layout of new education facilities. Where there is a socio-economic reason to justify their location in a flood risk area it must be clearly articulated, through a site specific Flood Risk Assessment (FRA), detailing how they will not increase the risk of flooding to the site and third parties.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS2: Delivering Sustainable Design and Construction CS2: Delivering Sustainable Design and Construction

  • Comment ID: 1020673/CSCD/15
  • Status: Accepted
Point 3 - Whilst it is encouraging to see Code for Sustainable Homes levels 4 and above for residential developments, a phased approach would be more suitable (i.e. by 2015 all new developments greater than 10 dwellings to be Level 4, beyond 2015 all new developments must meet level 5/6). If North Somerset is striving to achieve zero carbon for new homes by 2016, then the policy of Code 4 homes for greater than 10 dwellings will become obsolete by 2016.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Delivering Strong and Inclusive Communities CS13: Scale of New Housing CS13: Scale of New Housing

  • Comment ID: 1020673/CSCD/38
  • Status: Accepted
Para 3.213 - NSC need to progress the proposed flood risk management infrastructure i.e. the super pond on the Uphill catchment and the channel improvement works on the River Banwell. There needs to be certainty that this infrastructure will be progressed in detail to ensure it is technically feasible and the costs are fully understood, in order to avoid Test of Soundness issues in terms of the justification for expanding Weston-super-Mare.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 4: Area Policies CS28: Weston-super-Mare CS28: Weston-super-Mare

  • Comment ID: 1020673/CSCD/42
  • Status: Accepted
This appears to be an overall policy which is then sub-divided into the town centre and the urban extension. Is this Area policy linked back to Policy CS3? NSC should provide reference to the following: - NSC's own Level 1 and 2 SFRA. - PPS25 Sequential Test or the flood hierarchy approach. - The necessary flood risk management infrastructure required to unlock land to enable WSM to expand. This is essential when the Core Strategy is tested against PPS12.
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 2: Visions and Objectives Priority Objectives

  • Comment ID: 1020673/CSCD/8
  • Status: Accepted
Para 2.8 - NSC state that flood risk is a priority, but do not relate to PPS25 in the CS. Flood risk is not specifically mentioned in the Priority Objectives although sustainable housing is. Could flood risk be included or is it assumed it will be considered to achieve sustainable development?
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS1: Addessing Climate Change and Carbon Reduction CS1: Addessing Climate Change and Carbon Reduction

  • Comment ID: 1020673/CSCD/12
  • Status: Accepted
Para 3.10 - NSC refer to "resilience" and not the basic principles of PPS25 by applying the flood risk hierarchy to avoid the risk. Reference has not been made to the purpose of the Level 1 SFRA or the Level 2 SFRA to bring clarity. Why move straight to mitigation? This implies moving straight to high flood risk areas.
Environment Agency 24 Feb 2010

Core Strategy - Consultation Draft Chapter 3: Spatial Policies Living Within Environmental Limits CS2: Delivering Sustainable Design and Construction CS2: Delivering Sustainable Design and Construction

  • Comment ID: 1020673/CSCD/17
  • Status: Accepted
Para 3.28 - The statement 'flexibility will be exercised where viability and deliverability are critical factors' only seems to act as a 'get out clause'. From a water resources point of view, meeting levels 5 and 6 can be met without excessive costs or technology.
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.
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