Comment

Draft Local Plan-Part 2 Site Allocations

Representation ID: 22207

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Representation Summary:

GNLP0415R-E and GNLP0415R-F
Allocations adjacent to the River Yare of a nature reserve and Country Park (GNLP0415R-E, GNLP0415R-F) are welcomed, especially if we can secure riparian habitat improvements for this often overlooked chalk stream. In Marlingford just downstream we have been working to undertake natural flood management works, we could build on this partnership work to restore a better connection with the flood plain, plant trees and slow the flow.

GNLP0415R-A, GNLP0415R-C
There are two sites adjacent to the River Tud another chalk stream (GNLP0415R-A, GNLP0415R-C), we need to ensure that any water discharging from the development is as clean as possible and that SuDS are sufficient, a WFD compliance assessment must be undertaken. The River Tud has a population of white-clawed crayfish, an endangered species. If there is any opportunity to improve the river habitat to compensate for the additional run off then this would be welcomed.

GNLP0415R-E
The south of this site allocation, adjacent to the river lies in Flood Zones 2 and 3. Our detailed modelling shows that much of the area covered by Flood Zone 3 is actually Flood Zone 3b Functional Floodplain, with an annual probability of flooding of 5% (1 in 20) and classed as ‘land where water needs to flow and be stored in times of flood’. As a county park would be classed as ‘water compatible’ development in Table 2 under ‘Amenity open space, nature conservation and biodiversity’ then this would be an acceptable land use within the flood zones, including Flood Zone 3b, providing that it is designed to: ‘remain operational and safe for users in times of flood; result in no net loss of floodplain storage; and not impede water flows and not increase flood risk elsewhere’
Therefore it would be preferable if any associated built development is located within Flood Zone 1, and all development within the flood zones meets the above requirements.
GNLP0415R-F
The north of the site adjacent to the river lies in Flood Zones 2 and 3. Our detailed modelling shows that quite a lot of the area covered by Flood Zone 3 is actually Flood Zone 3b Functional Floodplain, with an annual probability of flooding of 5% (1 in 20) and classed as ‘land where water needs to flow and be stored in times of flood’. As a nature reserve would be classed as ‘water compatible’ development under ‘Amenity open space, nature conservation and biodiversity’ then this would be an acceptable land use within the flood zones, including Flood Zone 3b, providing that it is designed to: ‘remain operational and safe for users in times of flood; result in no net loss of floodplain storage; and not impede water flows and not increase flood risk elsewhere’ Therefore it would be preferable if any associated built development is located within Flood Zone 1, and all development within the flood zones meets the above requirements.

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