Local Plan to 2030 Regulation 19 - Publication June 2016

Comment ID ALP/2277
Document Section Local Plan to 2030 - Publication Draft TOPIC POLICIES SECTION D - THE NATURAL AND BUILT ENVIRONMENT Water and Climate Change Strategic Urban Drainage Systems (SuDs) Content View all on this section
Respondent Persimmon Homes and Taylor Wim… View all by this respondent
Agent Barton Willmore (Lucy Wilford)
Response Date 10 Aug 2016
Do you consider this part of the document is Sound? Yes
On which grounds do you consider the document unsound? (if applicable)
Do you consider the Document is Legally Compliant? Yes
Comment

Policy ENV9: Sustainable Drainage

5.37 The last sentence of the policy should be removed which states that:

‘Developers must notify the Council to discharge any relevant

conditions before commencement of works on site to ensure a

compliant design has been submitted.’

 

5.38 It is incumbent on any person or developer implementing a planning consent to discharge any

drainage conditions attached to a planning consent. It is not appropriate or necessary to repeat

this requirement in policy. Furthermore, it risks conflicting with any existing planning conditions

or site specific circumstances where the drainage conditions do not have to be discharged on

commencement of development.

5.39 Additionally, it is not always possible to ‘dispose’ of water. Criteria i. should be amended to

state:

‘Demonstrated that the first 5mm of any rainfall event can be

accommodated and contained disposed on-site’

5.40 The wording is unnecessarily restrictive and puts up additional barriers to otherwise acceptable

development coming forward.

5.41 Unless the wording is removed, the policy is not ‘Positively Prepared’ or ‘Justified’ and is

therefore ‘Unsound’.

 

What changes do you suggest to make the document legally compliant or sound? Policy ENV9: Sustainable Drainage
5.37 The last sentence of the policy should be removed which states that:
‘Developers must notify the Council to discharge any relevant
conditions before commencement of works on site to ensure a
compliant design has been submitted.’
General Development Control Policies
14691/A5/LW/kf 21 August 2016
5.38 It is incumbent on any person or developer implementing a planning consent to discharge any
drainage conditions attached to a planning consent. It is not appropriate or necessary to repeat
this requirement in policy. Furthermore, it risks conflicting with any existing planning conditions
or site specific circumstances where the drainage conditions do not have to be discharged on
commencement of development.
5.39 Additionally, it is not always possible to ‘dispose’ of water. Criteria i. should be amended to
state:
‘Demonstrated that the first 5mm of any rainfall event can be
accommodated and contained disposed on-site’
5.40 The wording is unnecessarily restrictive and puts up additional barriers to otherwise acceptable
development coming forward.
5.41 Unless the wording is removed, the policy is not ‘Positively Prepared’ or ‘Justified’ and is
therefore ‘Unsound’.
Do you consider it necessary to participate at the oral part of the examination? Yes
Does your representation relate to an omission site (a site that has not been included). For example a site for Housing, Employment, Travellers, or Local Green Spaces. No
Please supply details of the omission site.
Attachments