Sites and Policies Plan Consultation Draft

Comment ID 1020673//1
Document Section Sites and Policies Plan Consultation Draft Living within Environmental Limits DM1 View all on this section
Respondent Environment Agency View all by this respondent
Response Date 19 Apr 2013



The flood base mapping that North Somerset Council (NSC) are using to inform planning decisions needs updating. The Environment Agency has more recent coastal modelling showing the current tidal floodplain for undefended and defended scenarios along NSC coastline, but we don’t have climate change outlines.  NSC would need to refer back to their Strategic Flood Risk Assessment’s (SFRA) for this information. However, it is not believed that this will have a massive impact on the proposed sites, but it’s important that the correct baseline data is being used to inform their plans.


In addition, for Clevedon we have recently completed our fluvial modelling of the Land Yeo from Nailsea downstream to the estuary. This now provides a more accurate representation, and the fluvial floodplain through Clevedon has largely been removed.


New fluvial modelling of the Uphill Great Rhyne, Cross Rhyne and the River Banwell has been completed to inform the detailed design of the Councils strategic solutions. It’s important that this baseline mapping is used to update their current fluvial mapping to inform policies and planning applications.


Once approved the new fluvial modelling of the River Avon (City Area Flood Risk Assessment) being undertaken by Bristol City Council will help to assist some of NSC northern boundary sites e.g. the railway proposal at Easton in Gordano.


We would advise that NSC gain the relevant data from this office so that we can agree an update to their SFRA.




The Sites and Policies Plan makes no reference to groundwater or recognises the principles of the Environment Agency’s Groundwater Protection: Principles and Practice (GP3) document.  The document makes no distinction on the risks to both groundwater resources (such as quarries that may intercept the water table etc) and groundwater quality, either from former land use (contamination) or from the proposed operations (e.g. foul drainage / Suds etc). 


GP3 sets out the principals and policies that the Environment Agency uses to assess the potential risks from activities on groundwater resources and quality and developers need to refer to this before deciding whether particular schemes, or the detail of particular schemes are appropriate. Policies exist at a regional scale (Principal and Secondary Aquifers) and local level (Source Protection Zones).


An example of confusion arising from the failure of the document to refer to GP3 is evidenced in DM28 which implies that permeable paving for parking must always be incorporated in to the design.  Permeable paving may not be appropriate if the site is contaminated or if the site is located in a sensitive groundwater area. However, more fundamentally, DM12 (Mendip Hills) makes no reference to the particular sensitivities of groundwater in that district nor seeks to include the protection of groundwater as a specific policy intention. Similarly intentions related to the protection of groundwater are absent from DM15 (although we note that contamination and water resources are a material consideration).


If there is any possibility that any site allocation may be contaminated then a contaminated land investigation should be undertaking. This should confirm and detail remediation if required. 




DM1-Flooding and Drainage


The policy Intentions “to support the Environment Agency approach” is noted, however, we would recommend amending “to follow the planning policy principles set out in the National Planning Policy Framework (NPPF), which are supported by the Environment Agency”.


This policy could be stronger worded if they included the flood risk hierarchy embedded in the Sequential Approach i.e. Assess-Avoid-Substitute-Control-Mitigate.


We welcome the first paragraph on page 16 stating that there will be no exceptions to national policy on flood risk as stated in the NPPF and the NSC Core Strategy. We also recommend referring to the Level 1 and Level 2 SFRA’s showing flood risk areas.