KY23/H - Walk Mills, The Walk

Object

Representation ID: 28659

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) - Site is in FZ2 and 3. Half the site is impacted by the current 3ai extent and psrt of the site is impacted by the 2019 draft 3b extent. This will be a topic for the SFRA, possibility to become 3b land

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.

Comment

Representation ID: 29268

Received: 24/03/2021

Respondent: Environment Agency

Sites that are adjacent to or include rivers and becks within their boundary must make full consideration of the value of these features for biodiversity and green-blue infrastructure, as well as the wildlife habitat network. The existing biodiversity and green-blue infrastructure along these rivers/becks must be protected, and opportunity should be taken to enhance this Green-Blue Infrastructure including habitat enhancement to achieve 10% net gain in the riverine element of BNG.

As stated previously in relation to the policies, it is particularly important to recognise that rivers and becks cannot be replaced elsewhere, and that continuity of habitat along them is essential to maintaining and improving their ecological condition, and in maximising their contribution to green networks. These sites include (this is not a comprehensive list of all sites with rivers and becks):

KY23/H Walk Mills, The Walk: the site is in a Green Infrastructure corridor along the River Worth and we would expect any development to maintain and improve this GI corridor, including blue infrastructure in line with policies SP9, SP10, EN2. There may be opportunities on site to enhance blue infrastructure and deliver riverine BNG, including consideration of weir alteration to facilitate fish movement.

Object

Representation ID: 29401

Received: 29/03/2021

Respondent: Historic England

Low Bridge and the adjacent Mill to the north of this site are Grade II Listed Buildings. The development of this area could harm elements which contribute to the significance of these designated heritage assets.
Whilst we welcome the inclusion of a reference to the proximity of this designated heritage asset as a Constraint in the sites pro forma, if allocated, the Plan should make it clear that development proposals for this area would need to ensure that those elements which contribute to the significance of this heritage asset are not harmed.
In addition, the Council should consider whether any of the buildings and structures on the site should be classified as nondesignated heritage assets and retained as part of its development.
add the following additional
Development Consideration to the site
pro forma:
‘Development should conserve and, where possible, enhance those elements which contribute to the significance of the designated heritage assets to the north of the site.