Draft Local Plan-Part 2 Site Allocations

Comment

Representation ID: 22192

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Wymondham area site allocations
Site allocations around Wymondham (GNLP2168, GNLP0525R, GNLP3013, GNLP0006, GNLP0515, GNLP1055) are all in the headwaters of the River Tiffey and its tributaries, the land allocations are adjacent to the streams. The Tiffey is a chalk stream NERC s41 habitat of conservation importance. We are currently working on several projects to improve the River Tiffey to good WFD status e.g. fish passage and habitat restoration. The developments must not compromise this. There must be a buffer between developed land (including gardens) and the river of 20 metres. A WFD compliance assessment must be undertaken to assess the impacts on the water environment, including but not limited to water quality of run off. We would welcome partnership working opportunities from any development to improve riparian habitats via Broadland Catchment Partnership (NPPF 174).

Comment

Representation ID: 22193

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Wymondham area site allocations
Site allocations around Wymondham (GNLP2168, GNLP0525R, GNLP3013, GNLP0006, GNLP0515, GNLP1055) are all in the headwaters of the River Tiffey and its tributaries, the land allocations are adjacent to the streams. The Tiffey is a chalk stream NERC s41 habitat of conservation importance. We are currently working on several projects to improve the River Tiffey to good WFD status e.g. fish passage and habitat restoration. The developments must not compromise this. There must be a buffer between developed land (including gardens) and the river of 20 metres. A WFD compliance assessment must be undertaken to assess the impacts on the water environment, including but not limited to water quality of run off. We would welcome partnership working opportunities from any development to improve riparian habitats via Broadland Catchment Partnership (NPPF 174).

GNLP0515
It appears that the site boundary has been drawn to exclude the current and future flood zones just to the west of the site, and therefore the sequential approach has been correctly applied. There may be a small section of flood zones within the south western edge of the site boundary. Built development should be excluded from these flood zones to maintain flood storage capacity, and the sequential approach applied to locate all development within flood zone 1.

Comment

Representation ID: 22194

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Wymondham area site allocations
Site allocations around Wymondham (GNLP2168, GNLP0525R, GNLP3013, GNLP0006, GNLP0515, GNLP1055) are all in the headwaters of the River Tiffey and its tributaries, the land allocations are adjacent to the streams. The Tiffey is a chalk stream NERC s41 habitat of conservation importance. We are currently working on several projects to improve the River Tiffey to good WFD status e.g. fish passage and habitat restoration. The developments must not compromise this. There must be a buffer between developed land (including gardens) and the river of 20 metres. A WFD compliance assessment must be undertaken to assess the impacts on the water environment, including but not limited to water quality of run off. We would welcome partnership working opportunities from any development to improve riparian habitats via Broadland Catchment Partnership (NPPF 174).

Comment

Representation ID: 22195

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Wymondham area site allocations
Site allocations around Wymondham (GNLP2168, GNLP0525R, GNLP3013, GNLP0006, GNLP0515, GNLP1055) are all in the headwaters of the River Tiffey and its tributaries, the land allocations are adjacent to the streams. The Tiffey is a chalk stream NERC s41 habitat of conservation importance. We are currently working on several projects to improve the River Tiffey to good WFD status e.g. fish passage and habitat restoration. The developments must not compromise this. There must be a buffer between developed land (including gardens) and the river of 20 metres. A WFD compliance assessment must be undertaken to assess the impacts on the water environment, including but not limited to water quality of run off. We would welcome partnership working opportunities from any development to improve riparian habitats via Broadland Catchment Partnership (NPPF 174).

GNLP1055
There are a couple of ordinary watercourses running through the site with small flood zones associated with them. The flood zones are JFlow so are not accurately modelled. The development must be sequentially sited to avoid developing within these small strips of flood zones adjacent to the watercourses, and the flood zones must be left open for flood storage. If any development was to be located within these flood zones then the river will need to be accurately modelled to determine the precise flood outlines and flood levels. The development will then need to be designed to be safe and not increase flood risk elsewhere, as detailed previously. This should also be mentioned within the site allocation.

Comment

Representation ID: 22196

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Wymondham area site allocations
Site allocations around Wymondham (GNLP2168, GNLP0525R, GNLP3013, GNLP0006, GNLP0515, GNLP1055) are all in the headwaters of the River Tiffey and its tributaries, the land allocations are adjacent to the streams. The Tiffey is a chalk stream NERC s41 habitat of conservation importance. We are currently working on several projects to improve the River Tiffey to good WFD status e.g. fish passage and habitat restoration. The developments must not compromise this. There must be a buffer between developed land (including gardens) and the river of 20 metres. A WFD compliance assessment must be undertaken to assess the impacts on the water environment, including but not limited to water quality of run off. We would welcome partnership working opportunities from any development to improve riparian habitats via Broadland Catchment Partnership (NPPF 174).

GNLP2168
This site allocation lies mainly in Flood Zone 1, with a corridor of Flood Zones 2 and 3 towards the south-western boundary of the site, along the Bays River. The flood zone in this location is JFlow so is not accurately modelled. The development must be sequentially sited to avoid developing within this small strip of flood zone, and the flood zone left open as flood storage. If any development is to be located within this flood zone then the river will need to be accurately modelled to determine the precise flood outlines and flood levels. The development will then need to be designed to be safe and not increase flood risk elsewhere, as detailed above. This should also be mentioned within the site allocation.

Comment

Representation ID: 22197

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

Wymondham area site allocations
Site allocations around Wymondham (GNLP2168, GNLP0525R, GNLP3013, GNLP0006, GNLP0515, GNLP1055) are all in the headwaters of the River Tiffey and its tributaries, the land allocations are adjacent to the streams. The Tiffey is a chalk stream NERC s41 habitat of conservation importance. We are currently working on several projects to improve the River Tiffey to good WFD status e.g. fish passage and habitat restoration. The developments must not compromise this. There must be a buffer between developed land (including gardens) and the river of 20 metres. A WFD compliance assessment must be undertaken to assess the impacts on the water environment, including but not limited to water quality of run off. We would welcome partnership working opportunities from any development to improve riparian habitats via Broadland Catchment Partnership (NPPF 174).

Comment

Representation ID: 22198

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

The River Bure, a chalk stream which is a S41 NERC habitat (NPPF 170 & 174), flows through the land allocated to the North East of Aylsham (GNLP0336), the development must not be on the flood plain as this will inhibit the natural functioning of the river and compromise the ability to reach Good WFD status. It is also an important wildlife corridor. We must ensure that any run off is the best water quality possible through use of appropriate SuDS etc. Natural habitats adjacent to the river and within the flood plain must be conserved and opportunities to enhance those habitats should be sought. We are working in partnership with the National Trust on the Upper Bure Riverlands project to restore river habitats in this area (https://www.nationaltrust.org.uk/features/riverlands-how-we-keep-our-rivers-flowing) and there is scope to carry out this kind of partnership work near Aylsham too.

Comment

Representation ID: 22200

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

There are many sites within Norwich which are adjacent to the River Wensum (GNLP2137, GNLP0409R, GNLP0360, GNLP0377, GNLP0401, GNLP0068, GNLP3053), firstly we need to ensure that SuDS within the development are sufficient to protect the water quality of the River Wensum and secondly any opportunities to improve riparian habitat to mitigate against the impacts of the development would help us to secure improvements necessary to meet good WFD status and help ensure that the development does not cause any deterioration.

The majority of the May Gurney and Deal Ground Site (GNLP0360) is within the flood plain of the River Yare, any development of the floodplain would compromise the natural functioning of the river and the WFD no deterioration objective. There should be a significant buffer between the development and the flood plain. We are working with Norwich City Council on the Yare Valley Parkway green infrastructure corridor, to ensure that the River Yare around the south of Norwich is as good as it can be and to enhance the conservation value of the nature sites along the corridor. Any sensitive development of sections of this land parcel outside of the flood plain should also restore natural habitats within the flood plain.
As stated above, the majority of the site lies in Flood Zones 2 and 3, both now and with the addition of climate change. A significant majority of Flood Zone 3 is shown on our modelling to actually be 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’. Residential and commercial development, classed as ‘more vulnerable’ and ‘less vulnerable’ development respectively, is not permitted in Flood Zone 3b so the majority of the site will need to be left undeveloped.
As with all development in Flood Zones, the more vulnerable development, and ideally the less vulnerable development too, will need to be designed with floor levels raised 0.3m above the flood levels for the future 1% (1 in 100) annual probability flood event with 35% and ideally 65% allowances for climate change. Refuge will also need to be provided above the 0.1% (1 in 1000) annual probability 25% climate change flood levels. Compensatory flood storage will also need to be provided for any built development or land raising within the 1% (1 in 100) annual probability flood outline with 35% climate change to ensure no increase in flood risk elsewhere. This will require lowering of higher land in Flood Zone 1 to provide the compensatory flood storage.
We note that there is an extant outline permission on the site, which met these requirements, although climate change allowances have since changed so the required floor levels may be different. This should be addressed as part of the reserved matters applications.

Comment

Representation ID: 22201

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

There are many sites within Norwich which are adjacent to the River Wensum (GNLP2137, GNLP0409R, GNLP0360, GNLP0377, GNLP0401, GNLP0068, GNLP3053), firstly we need to ensure that SuDS within the development are sufficient to protect the water quality of the River Wensum and secondly any opportunities to improve riparian habitat to mitigate against the impacts of the development would help us to secure improvements necessary to meet good WFD status and help ensure that the development does not cause any deterioration.

This site allocation lies mainly in Flood Zone 1 currently, with very small areas of Flood Zones 2 and 3 adjacent to the river. Once climate change is applied to the flood outlines, Flood Zones 2 and 3 extend further into the site. The development must be sequentially sited in future Flood Zone 1 where possible.
If development is required to be sited within these future Flood Zone 3 (1% annual probability with 35% climate change) and Flood Zone 2 (0.1% annual probability with 35% climate change) flood outlines then the more vulnerable development, and ideally the less vulnerable development too, will need to be designed with floor levels raised 0.3m above the flood levels for the future 1% (1 in 100) annual probability flood event with 35% and ideally 65% allowances for climate change. Refuge will also need to be provided above the 0.1% (1 in 1000) annual probability 25% climate change flood levels. Compensatory flood storage will also need to be provided for any built development or land raising within the 1% (1 in 100) annual probability flood outline with 35% climate change.
The requirement to take account of the future flood risk on the site, and design the development to be safe and not increase flood risk elsewhere, as required in the NPPF, should be mentioned within the site allocation.

Comment

Representation ID: 22202

Received: 16/03/2020

Respondent: Environment Agency (Eastern Region)

There are many sites within Norwich which are adjacent to the River Wensum (GNLP2137, GNLP0409R, GNLP0360, GNLP0377, GNLP0401, GNLP0068, GNLP3053), firstly we need to ensure that SuDS within the development are sufficient to protect the water quality of the River Wensum and secondly any opportunities to improve riparian habitat to mitigate against the impacts of the development would help us to secure improvements necessary to meet good WFD status and help ensure that the development does not cause any deterioration.

GNLP3053
The vast majority of the site is Flood Zone 1. There is a very small area to the north east of the site, adjacent to the river which is Flood Zone 3 now and in the future. Therefore the sequential approach must be applied to avoid built development within this small area of flood zone to allow it to continue to provide flood storage.
The proposed bridge will need to be designed to be above the 1% flood level including 35% climate change to ensure that it does not obstruct flood flows or increase flood risk elsewhere. A Flood Risk Activity Permit must be obtained for the proposed bridge and any works within 8m of the main river Yare.