Comment

Representation ID: 22180

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Emissions and climate change (page 23)
Paragraph 86 should be expanded to state that opportunities for carbon sequestration through environmental habitat improvements should be sought on-site and offsite either through carbon offsetting or biodiversity net gain.
This section states that climate change mitigation is a cornerstone of the plan. Reducing CO2 per capita is only one aspect of this. The plan should also seek to outline carbon sequestration measures, as well as strategic planning to ensure that there is greater resilience to temperature and rainfall increases. This policy should be underpinned by NLLP compulsory net gain.
Flood Risk (page 24)
The Flood Risk section includes Map 3 showing present day Flood Zones 2 and 3. However, the revised NPPF requires planning applications to include a Flood Risk Assessment if they are in the Future Flood Zones taking into account climate change. It would therefore be beneficial if the climate change enhanced flood outlines, as shown in the Greater Norwich 2017 SFRA, could be included in the flood risk section of the Local Plan. In addition, the title of Map 3 states ‘fluvial flood zones’, however the estuaries are at risk of tidal and fluvial flooding and so the map should be entitled ‘fluvial and tidal flood zones’. Tidal flood zone 3 has an annual probability of 0.5% (1 in 200) so the key on the map which states ‘Flood Zone 3 - 1 in 100’ should also be revised.

We agree that the plan will need to provide ‘strategic level policies to address flood risk in new development’. We recommend that the flood risk policies include details on what would be required to be included within a Flood Risk Assessment (FRA), and define what is safe in different situations, and so provide greater clarity that that provided in the PPG.
The policy should include information on the following:
 Sequential Test
 Exception Test
 Sequential Approach – higher vulnerabilities on lowest risk parts of the site
 Safety requirements for actual and residual risk for different development types – floor levels, resistant/resilient construction, access egress, flood emergency plans
 Offsite flood risk – compensatory storage
The new Greater Norwich SFRA includes some details about the FRA requirements, but it would be good if the requirements could be echoed or expanded upon within the flood risk policy, or the SFRA referred to in the policy.
In particular, it is the responsibility of the LPA and their Emergency Planner to determine when an Emergency Flood Plan can ensure the safety of a development and when the development requires dry floors and/or safe access to enable it to be safe in a flood. It would be advantageous if the Local Plan’s flood risk policy could stipulate these requirements for different development types at residual risk of flooding in a breach, and different development types at actual risk of flooding.
We require new more vulnerable development to have dry floors in the actual risk design fluvial 1% (1 in 100) / tidal 0.5% (1 in 200) annual probability flood event including climate change, and we require all development types to have refuge above the actual risk and residual risk 0.1% annual probability flood event including climate change.
We do not have minimum floor level requirements for less vulnerable development at actual or residual risk, or more vulnerable development at residual risk, instead they are allowed to be managed with Flood Response Plans and flood resistant/resilient construction, to the satisfaction of the LPA and their Emergency Planners. Therefore if the Local Plan could include details as to when this type of management of flooding is acceptable, or when there might be minimum floor level requirements for these type of developments to prevent flooding, then this is something that the flood risk policy should address.
Ecology
Regarding paragraphs 87 to 91 referring to flood risk, we would like to see more natural functioning of the water environment, including natural flood management measures from slowing the flow and retaining water upstream to reconnecting floodplains in the lower reaches of rivers. This will help to restore natural processes and contribute to improving the water environment under the Water Framework Directive.
As we have previously advised, all new developments should implement appropriate Sustainable Urban Drainage Systems (SuDS). We would like to see all new developments retaining as close to 100% of surface water as possible.

Given the importance of wetland habitat to the Greater Norwich area, this measure would help in protecting the water environment. SuDS provision will need to be included as part of the green infrastructure planning.
 Flood attenuation – helping to preventing surface water flooding, and flash flooding in the locality.
 Groundwater recharge – Storing surface water run-off and allowing it to be released slowly will help water to percolate back in to underground aquifers.
 Filtering Pollutants, allowing sediments to settle.
 Ecological benefits through creation of ponds, swales wetland areas and tree planting as part of SUDs schemes. This will create new habitats, and where land was previously industrial or agricultural, bring a quantifiable increase in ecological diversity. These features can also enhance the appearance and appeal of the built environment and have amenity value.
 A reduction in pressure on local sewerage infrastructure which may already be at capacity.
 Provide a source of water for urban activities such as gardening and bring benefits for recreation, education and wellbeing.
 www.susdrain.org/delivering-suds/using-suds/suds-principles/suds-principals
Using surface water as a resource is likely to become increasingly important as pressures on water resources increase in the future. Change in rainfall through climate change, rising population and urbanisation are all driving factors. Capturing and using rainfall within the urban environment can provide environmental benefits as well as increasing amenity value
Environmental Assets (The Natural Environment and Landscape) (page 26)
Paragraph 97 requires amending as Natura 2000 are European protected sites and not international as stated.
In terms of paragraph 100, county wildlife sites have no statutory protection and so needs rewording for example as “sites identified as of local conservation importance”. Local Wildlife rich habitats have no official designation but which are recognised as of biodiversity importance under S41of the Natural Environment and Communities Act. A good example of this in the Greater Norwich area are chalk streams, reedbeds and fens which may not have designations.
This section as a whole could be more progressive and more ambitious to include statements around natural capital, green infrastructure and natural functioning ecosystems.
The plan would benefit from having a specific section for the water environment. A specific section would help ensure all issues are covered. This plan must link to the Anglian River Basin Management Plan and state that developments must carry out Water Framework Directive (WFD) compliance assessments following guidance in Planning Inspectorates advice note 18 and ensure that the development does not cause a deterioration in WFD status of any element. The plan must explain the ‘no deterioration’ objective.
The plan should also refer to the Catchment Based Approach and Broadland Catchment Partnership. The Broadland Catchment Plan could provide opportunities for mitigation and net gain through partnership working.

The water environment section should also reference any significant water management issue which is frequently cited as a reason for not achieving good if it is linked to a development.
Water (page 29)
Water stress is impacting on chalk streams and other water dependent habitats in the Greater Norwich area.
Water Quality and protecting the local water environment must be referenced in this section. The Local Plan needs to acknowledge that growth and development in the area will put pressure on the water environment, especially in respect to meeting the tight environmental legislative targets set to protect bodies of water such as WFD and Habitats Directive. The "water" section should have a couple of sentences discussing this and highlight that the risks posed to the water environment primarily come from increased discharge volumes from wastewater discharges (sewage works/Water Recycling Centres) which will received a significant increase in wastewater from development within the district. The Local Plan is an essential instrument to ensure that additional foul drainage arising from new development does not put local rivers (and existing properties) at unnecessary risk of pollution and/or flooding by sewage and/or wastewater.

It is also essential that this section acknowledges that most of the River Wensum and two of its tributaries are a designated SAC (protected area under the Habitats Directive) and therefore have more stringent conservation (including specific water targets) to meet. The importance of ensuring this protected site is not impacted by growth and development should be highlighted.