Additional wording to requirement 12 b:

“Any new additional culverts must be kept to an absolute minimum with alternative approaches explored first, such as natural flood management measures. Any new culvert must be designed in such a way so as to limit their impact on the watercourse, such as by allowing for a suitable depth of substrate to reflect the natural watercourse bed and including mammal ledges as appropriate.”

We note that Phase 1 of the site is connecting to Tangmere Wastewater Treatment Works (WwTW) due to the constraints on the Apuldram WwTW. Subsequent phases of the site are reliant on additional capacity at Tangmere WwTW. The Local Authority must be satisfied at the time of any planning application for future phases that such wastewater capacity exists, and appropriate phasing must be secured via conditions to ensure that occupants are not reliant on package treatment plants or removal of wastewater by tanks. Requirements 14 and 15 deal with this to a certain extent.

We are concerned about requirement 12 b which says “Provide mitigation for any loss of watercourse habitat resulting from culverting for highway provision in the development.” We would strongly discourage adding more culverts to watercourses as they are likely to have adverse impacts on flood risk, ecology, human health and safety and amenity whilst increasing maintenance costs and hindering future options to restore the watercourse. The latest Planning Practice Guidance for Flood risk and coastal change says that proposals to introduce new culverting are likely to run contrary to natural flood management objectives and the objectives of River Basin Management Plans (paragraph 067). Therefore, We would recommend the following addition to that requirement:

“Any new additional culverts must be kept to an absolute minimum with alternative approaches explored first, such as natural flood management measures. Any new culvert must be designed in such a way so as to limit their impact on the watercourse, such as by allowing for a suitable depth of substrate to reflect the natural watercourse bed and including mammal ledges as appropriate.”