Environment AgencyISSUE 17

Environment Agency representations to Inspector Draft Programme dated 11 March 2013.

Author: Michael Holm, Sustainable Places Advisor – Wessex Area

Dated 05 April 2013

ISSUE 17

Environmental Quality and Sustainable Development

Question –

17.4 Is the Council’s approach to the alleviation of flood risk and to water management sufficiently robust? Is sufficient weight attached to the need to protect water resources?

Environment Agency representation:

Flood Risk

The principles of Climate Change Policy EQ1 should prevent inappropriate development being located in the Flood Risk areas through the application of National Planning Policy Frameworks Sequential Test.

We do wish to highlight that the wording of the Exception Test section of Policy EQ1 is considered to be inconsistent with National Planning Policy Framework (NPPF). This section infers that development may be allowed to proceed without passing the Sequential Test. It is our considered opinion that this reference is actually trying to reinforce NPPF where development has successfully demonstrated that there are no reasonably available sites at a lower flood risk area (i.e. passes the Sequential Test through evidence) then the Exception Test is required for some development types.

Therefore, we would recommend that a minor amendment be made to ensure that it is consistent with Table 3 of the Technical Guidance Note to the NPPF.

  • Where appropriate, the Exception Test can be applied if it is not possible to pass the Sequential Test, if this is consistent with wider sustainability objectives;

We consider that there should be an engineering solution to the management of surface water within the strategic allocations to prevent increasing flood risk to the downstream catchment. This will need to be demonstrated within either strategic, or site specific, flood risk assessments in accordance with Policy EQ1 and EQ5.

Water Resources

We support the reference to Water Efficiency in Policy EQ1 and this is reinforced by the target set to meet the Code for Sustainable Homes in this policy.