Local Plan 2036: Issues and Options Stage

Comment ID 20338913//38
Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Potential new policy areas Q48. Do you have any views on our intended approach to flood risk? View all on this section
Respondent Aston View all by this respondent
Response Date 11 Jan 2019
Comment

The Environment Agency are currently constrained and unable to object to the redevelopment of brownfield land within urban areas provided the flood risk is no worse than previously existed. This is complete nonsense policy. In the ecological world (dealt with under the Environmental Impact Assessment Regulations) we adopt the precautionary approach and play it safe to ensure we don't create irreversible damage of effects on the natural world.

It is absolutely essential that any forward plan system fully respects up to date Environment Agency flood risk advice (including effects of climate change). We should under no circumstances continue to build in locations at risk of flood. In all cases, new development should be located in Flood Zone 1 (lowest possible risk) and that decision should prompt us to review any necessary localised changes to the Green Belt where such changes would not undermine the primary purposes of the introduction of the GB (See Appendix A - Green Belt Report).

To not apply a precautionary approach to the location of housing and such long term development would be negligent in the extreme. Land and housing provided now must be sustainable and fit for purpose in the long term.

At Portishead, development has remediated old industrial land and relies upon tidal defences. The consequences of flooding were less significant when the land was industrial but are more significant now that the land has residential use and in particular where an area of land has recently been consented for elderly sheltered accommodation. Such uses are sensitive to flood and it is essential we no longer continue such patterns of irresponsible land use.

 

Summary
EA is unable to object to brownfield redevelopment in urban areas provide flood risk is no worse - this is nonsense. Must not build in flood risk locations - need a precautionary approach. At Portishead development of old industrial land relies on flood defences - this is irresponsible land use.
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