Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 28880

Received: 24/03/2021

Respondent: Environment Agency

Representation Summary:

Site in Flood Zone 1 ONLY
Mitigation should be set above the 1 in 100 plus cc level for the site as suitable for the proposed vulnerability classification (EA standing advice should cover this).

If the site is considered Greenfield then surface water discharge rates post development should be restricted to the pre development Greenfield discharge rate. If the site is considered Brownfield then there should be a 30% reduction in surface water discharges, or restricted to Greenfield rates, there should be no increase in brownfield surface water discharge rates post development. So as to support prevention of cumulative increases to flood risk and should be in line with SuDs design principles.

For developments near ordinary watercourses we would recommend an 8 metre easement strip along the length of the riverbank, or a 45degree angle from the bed in the case of culverts, to be kept clear of permanent structures such as buildings. This is to maintain access to the riverbank for any improvements or maintenance. A Flood Defence Consent may be required for the LLFA for works in/affecting an ordinary watercourse.

For main rivers, we generally require an 8 metre easement strip along the length of the riverbank to be kept clear of permanent structures such as buildings, or a 45degree angle from the bed in the case of culverts. This is to maintain access to the riverbank for any improvements or maintenance. Environmental Flood Risk Activity Permits may be required for development near rivers.

It is possible the sites within close proximity to Flood Zones 3b, 3 and 2 may be subject to future risk identified within the SFRA (to follow) which may affect its allocation or how development should be sequentially laid out on the site.

Consideration must be made to making space for water and providing betterment in terms of flood risk management where ever possible.