Consultation Question 47

Support

Representation ID: 27083

Received: 24/03/2021

Respondent: Nabil Basharat

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27136

Received: 24/03/2021

Respondent: Ian Sunderland

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27165

Received: 24/03/2021

Respondent: Marianne Clarke

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27194

Received: 24/03/2021

Respondent: Carole Wheeler

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27223

Received: 24/03/2021

Respondent: Julie Sunderland

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27252

Received: 24/03/2021

Respondent: Gary Scott

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27284

Received: 24/03/2021

Respondent: Ms Jane Schofield

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27313

Received: 24/03/2021

Respondent: Mr Alan Lovell

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27342

Received: 24/03/2021

Respondent: Marjorie Rogan

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27371

Received: 24/03/2021

Respondent: Paul Cryer

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27400

Received: 24/03/2021

Respondent: Wendy Barton

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27429

Received: 24/03/2021

Respondent: Mr Richard Bardsley

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27458

Received: 24/03/2021

Respondent: Paul Warren

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27580

Received: 24/03/2021

Respondent: Danny Thompson

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27705

Received: 24/03/2021

Respondent: Peter Cartwright

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27739

Received: 24/03/2021

Respondent: Mrs Ann Todd

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Comment

Representation ID: 27762

Received: 19/03/2021

Respondent: National Gas Transmissions

Agent: Avison Young

To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets
Guidance on development near National Grid assets
National Grid is able to provide advice and guidance to the Council concerning their networks and encourages high quality and well-planned development in the vicinity of its assets.
Electricity assets
Developers of sites crossed or in close proximity to National Grid assets should be aware that it is National Grid policy to retain existing overhead lines in-situ, though it recognises that there may be exceptional circumstances that would justify the request where, for example, the proposal is of regional or national importance.
National Grid’s ‘Guidelines for Development near pylons and high voltage overhead power lines’ promote the successful development of sites crossed by existing overhead lines and the creation of well-designed places. The guidelines demonstrate that a creative design approach can minimise the impact of overhead lines whilst promoting a quality environment. The guidelines can be downloaded here: https://www.nationalgridet.com/document/130626/download
The statutory safety clearances between overhead lines, the ground, and built structures must not be infringed. Where changes are proposed to ground levels beneath an existing line then it is important that changes in ground levels do not result in safety clearances being infringed. National Grid can, on request, provide to developers detailed line profile drawings that detail the height of conductors, above ordnance datum, at a specific site.
National Grid’s statutory safety clearances are detailed in their ‘Guidelines when working near National Grid Electricity Transmission assets’, which can be downloaded here:www.nationalgridet.com/network-and-assets/working-near-our-assets
Gas assets
High-Pressure Gas Pipelines form an essential part of the national gas transmission system and National Grid’s approach is always to seek to leave their existing transmission pipelines in situ. Contact should be made with the Health and Safety Executive (HSE) in respect of sites affected by High-Pressure Gas Pipelines.
National Grid have land rights for each asset which prevents the erection of permanent/ temporary buildings, or structures, changes to existing ground levels, storage of materials etc. Additionally, written permission will be required before any works commence within the National Grid’s 12.2m building proximity distance, and a deed of consent is required for any crossing of the easement.
National Grid’s ‘Guidelines when working near National Grid Gas assets’ can be downloaded here: www.nationalgridgas.com/land-and-assets/working-near-our-assets

Support

Representation ID: 27812

Received: 24/03/2021

Respondent: Richard Briggs

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27843

Received: 24/03/2021

Respondent: Claire Shouler

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 27907

Received: 23/03/2021

Respondent: Samantha Armitage

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 28206

Received: 24/03/2021

Respondent: Sarah Lucas

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 28296

Received: 24/03/2021

Respondent: Stephen Mould

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Comment

Representation ID: 29111

Received: 24/03/2021

Respondent: Environment Agency

Local Plans should consider the capacity and quality of water supply systems and any impact development may have on the environment, including understanding the supply and demand patterns now and in the future across the LPA area.

We encourage LPAs to ensure emerging Local Plans and major developments identify and plan for the required levels of water efficiency and water supply infrastructure to support growth, taking into account costs and timings/phasing of development.

Local Plans should consider the environmental capacity of the water environment using evidence sources such as the RBMPs. The quality and capacity of the existing wastewater treatment works and sewerage network should also be considered.

Water companies hold information and data to help with this. Additional capacity may be required to serve increased housing numbers. Where this is the case LPAs should work with water companies and us to understand the impact increased development would have on the receiving water environment, and the practicalities of water companies providing necessary upgrades.

Comment

Representation ID: 29113

Received: 24/03/2021

Respondent: Environment Agency

Groundwater and Contaminated Land

The Water Environment (WFD)(E&W) Regulations 2017 and The Groundwater (WFD) (England) Direction 2016 set out objectives for groundwater including aiming for good chemical and quantitative status; reverse upwards trends in pollution; and preventing or limiting the entry of certain substances to waterbodies. Local Planning Authorities (LPAs) must have regard to these objectives and therefore should ensure their decisions help achieve these goals. Dealing with land contamination can help contribute to achieving the objectives of the Water Framework Directive.

Local Plans should be produced with an understanding of how local communities use their groundwater and the location of potentially contaminated land. The Sustainability Appraisal (SA) for the Local Plan is an opportunity to incorporate evidence and advice into plan making. The SA should reflect groundwater and contaminated land matters.

Support

Representation ID: 29229

Received: 23/03/2021

Respondent: Rachel Wood

We support the whole of EN9, but would suggest that impact assessments should include both local effects and wider effects, including the effect on neighbouring settlements. We would also like to see rigorous enforcement of resultant regulations.

Support

Representation ID: 29235

Received: 24/03/2021

Respondent: Environment Agency

We support the current content of Policy EN9 – particularly the references to enhancement of water courses natural geomorphology.

Comment

Representation ID: 29237

Received: 24/03/2021

Respondent: Environment Agency

However, we also recommend the inclusion of additional wording (underlined) within the Water Quality section of the policy so that it reads:

“The Council will work with developers and partner organisations to:
 safeguard ground and surface water resources, including protecting Source Protection Zones from contamination;
 ensure no deterioration in the status of water courses or any water bodies occurs;
 ensure that development does not jeopardise any water body from achieving its Water Framework Directive objective of 'good' status; and
 protect and improve water quality.
Proposals for development will only be acceptable where there is no adverse impact on surface water bodies and groundwater resources, in terms of their quantity, quality and the important ecological features they support.
Proposals for development will be supported where they:
 make positive progress towards achieving 'good status or potential' under the Water Framework Directive for surface and groundwater bodies.
 enhance the natural geomorphology of watercourses, including through the opening up of culverts, and the removal of modifications made as part of past industrial uses (e.g. removal or modification of weirs to address fish passage), or and through the restoration of man-made channels.
 manage water demand and improve water efficiency through the use of appropriate measures including rainwater harvesting and grey-water recycling.
 include measures which help to reduce the potential for, or mitigate against water shortages or drought”.

Comment

Representation ID: 29238

Received: 24/03/2021

Respondent: Environment Agency

We also recommend including the following additions regarding watercourse buffer zones and a presumption against new culverts.

Watercourse buffer zones:
All watercourses and their riparian corridors / floodplains provide excellent networks of blue and green infrastructure and should be protected and enhanced to provide multiple benefits (e.g. increased biodiversity, natural flood management, carbon sequestration etc.). There should be un-development buffer zones of at least 10 m along main river and ordinary watercourses. These buffer zones will allow the creation and management of wildlife corridors to protect and enhance green and blue infrastructure.

Culverting:

We would suggest including a presumption against installing new culverts on watercourses.

This is in line with the Environment Agency’s Internal Policy 169_19 Culverting Watercourses which states: “(The Environment Agency) are opposed to the culverting of any watercourse because of the adverse ecological, flood risk, geomorphological, human safety and aesthetic impacts. Watercourses are important linear features of the landscape and should be maintained as continuous corridors to maximise their benefits to society”.

We would also suggest that where new developments are to be located over an existing culvert, the presumption should be that de-culverting and opening up the watercourse should be always be the first option. Opportunities to re-naturalise watercourses should always be considered as part of developments.

Comment

Representation ID: 29240

Received: 24/03/2021

Respondent: Environment Agency

We also support the reference to the WFD and its objectives within Policy EN9. In the post-Brexit climate, we also feel it is important to highlight that the WFD is transposed into law in England and Wales by The Water Environment (Water Framework Directive) (England and Wales) Regulations 2017. We recommend that this information is included within a supporting paragraph to Policy EN9.

References to WFD are welcome, particularly the reference to not jeopardising our ability to reach ‘good’ status which is the ultimate aim of the legislation. We have provided further detail for consideration below these comments under the title ‘Water quality’ and ‘Water Framework Directive’ and have provided an updated WFD map with the current Ecological status of the District’s river water bodies.

Comment

Representation ID: 29241

Received: 24/03/2021

Respondent: Environment Agency

Finally, within the supporting text 4.33.1 – 4.33.4, this should also refer to NPPF paragraphs 170 and 178. The policy should also refer to the relevant EA guidance and promote the use of the National Quality Mark Scheme for Land Contamination Management which involves the use of competent persons to ensure that land contamination risks are appropriately managed. The policy may like to refer to the contaminated land pages on GOV.UK for advice and guidance.
Development proposals on contaminated land, or where previous land use may indicate some level of contamination, must include an assessment of the extent of contamination and any possible risks. An assessment should include;
 Ensuring sites are suitable for the intended use;
 Applying a risk based approach to assessing land contamination;
 An assessment of the risk to surface water and groundwater (controlled waters) receptors from land contamination.
 The requirement for remediation / mitigation to reduce unacceptable risks to the environment, if required