SW35/H - All Saints Road

Comment

Representation ID: 28929

Received: 24/03/2021

Respondent: Environment Agency

Site is identified to be either wholly, or most of, in the current/draft 3b OR 3a(i) - Majority of site is within the 2019 Draft 3b extent as such should not be considered for allocation untill the SFRA is updated

This is a key aspect of conversation as part of the pending SFRA update as such no allocations should be made in these areas unless considered water compatible or essential infrastructure. Where this is the case the development must demonstrate no increase in risk to others, no loss of Functional Floodplain and suitable mitigation measures for use and the lifetime of the development.

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

For development 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.

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. Some SuDs principles such as storage ponds should not be solely relied upon within areas at risk of fluvial flooding as they may not be operational during a flood.