Draft Interim Policy Statement for Housing Development

Section 6.2 -
Point 6 - We would recommend that the opportunity is taken here to be more aspirational and encourage developments now to deliver biodiversity net gain and improvements in the Strategic Wildlife Corridors that have been identified as part of the proposals for the Local Plan Review. This would send a clear message of the Council’s intentions to deliver biodiversity net gain. By setting this aspiration at the outset gives the best opportunity for developers to achieve by planning the design of their site at the outset.

Point 7 – We would wish to see further detail here with regard to wastewater treatment. Whilst reference is made to the current Local Plan policy on wastewater treatment this has also since been supplemented by the Surface Water and Foul Drainage SPD which should be referenced and also the Council endorsed joint EA/SWS statement for Apuldram catchment. We would recommend that there is more specific reference to these constraints as overcoming these issues can slow down development.

Point 8 – We support the requirements for high standards of construction and that the statement asserts to aspirations beyond the requirements set out in policies of the current Local Plan.

Point 11 – This section is comprehensive to ensure that flood risk is fully considered at a site specific level with a lot of detail included in the first sentence. However, the opportunity could be taken to set out locations where development would not be supported due to high flood risk and impacts of climate change on the flood zones as being considered through the Local Plan review. The section does not distinguish between sources of flood risk and whilst it is important all sources are fully considered on a site there will be areas with tidal or fluvial risk where the depths and velocities of flood risk are more hazardous than surface or groundwater flood risk. We note that reference to EA Climate Change allowances is made in relation to an FRA, however, we would recommend that this is extended to refer applicants to your Strategic Flood Risk Assessment where all sources of flood risk are considered as well as then highlighting the need to look at the most recent Climate Change allowances which may supercede some of the SFRA information.