Comment

Representation ID: 29203

Received: 24/03/2021

Respondent: Environment Agency

-A, Point 2: …should add “for the lifetime of the development” to this section. This should be made clear that lifetime of development applies in ALL flood risk considerations.
-A, Point 4: We support, but would suggest that further wording is included on seeking betterment where possible.
-A, Point 5: This clause in the policy seems to exclude the essential infrastructure and water compatible development in flood zone 3b. This should be included in some form as the requirements will also apply to these types of development. This should therefore refer to 3b development or have a separate clause to deal with this due to the stringent requirements (such as no loss of 3b). Given the nature of flooding, this will likely be a key conversation topic in the SFRA with the removal of 3a(i). Further development of the policy in regard to flood zone 3b will be required following the completion of the SFRA. This would need to also include dealing with development already within 3b.
-A, Point 6: We support the inclusion of this point within the policy. It is currently quite vague without the SFRA evidence to support it and may need to be reviewed at that point in terms of areas allocated for safeguarding.
-A, Point 7: Further clarity could be provided regarding what is meant by managing and reducing ‘beck corridors’. We support opportunities to seek betterment and these should always be sought. This should be widened beyond just NFM and culvert opening. Please also see further points raised below.
-A, Point 9: This section needs to be clearer that there should be no ‘increase runoff’ from sites so as to support prevention of cumulative impacts of development on flood risk. This is mentioned in the Greenfield sites section but not in brownfield sites section, we would also recommend changing the wording for Greenfield to say ‘no increase’ instead of ‘no change’ as discharge should be reduced where possible.
-A, Point 10: We are unclear on what is meant by a separate system. This should be clarified in the policy wording.
There is currently no mention of residual risk within the policy. This will be another expected change following the SFRA Update. Residual risk should be clarified and included within the policy explicitly.
-We encourage a section to be included regrading developer contributions being sought for flood risk management projects, including natural flood management.
Our other comments for this policy include:
-We support paragraph A 7 and the recognition of the need to enhance value for wildlife and increase biodiversity. We suggest adding the wording “and working with natural processes”, and “helps to achieve Biodiversity Net Gain”.
-We are supportive of the paragraphs 12, 13 relating to Green Infrastructure provision and natural flood management.
-We recommend a change in wording for A 14.
Only support the use of culverting for ordinary water courses, and additional flood defence works that could have adverse impacts on the environment, in exceptional circumstances.
-This paragraph isn’t clear. It implies that the Council would allow or carry out flood defence works that will result in an overall negative impact on the environment. We suggest a clear statement that gives a presumption against culverting of any watercourses, In terms of impacts on the environment from flood defence works, this also needs a clear statement that flood risk projects will achieve an overall net gain for the environment and for biodiversity. This is in line with the EA’s Flood Risk Strategy, and the other Bradford Local Plan policy statements about BNG, and enhancing Green and Blue Infrastructure. Flood Defence works that have an adverse impact on the environment should not take place, and Flood Defence works should follow the mitigation hierarchy set out in section EN2 and figure 4.26.1 (Avoid, Mitigate, Compensate, Offset, Enhance) such that the works result in an overall environmental improvement.
-Flood Defence works that require planning permission will need to demonstrate 10% Biodiversity Net Gain in line with anticipated Environment Bill.
-SuDS should be carried out in line with the groundwater protection position statements found in the document ‘The Environment Agency’s approach to groundwater protection’