Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 854

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - I cannot support the Plan because the Strategic Flood Risk Assessment is incomplete, so I am not satisfied that the proposed allocations and growth areas are safe or will not increase flood risk.

Object

Representation ID: 855

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - I expect the overall spatial strategy, strategic growth and town‑centre regeneration policies, the housing strategy, allocated sites, the Water Cycle Assessment and flood policies to be revised once the SFRA is finalised and coastal‑erosion potential is tested.

Object

Representation ID: 856

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - Policy wording needs improvement – add a bulleted objective on fresh and marine water (Policy 1.51), change “should” to “must” in clauses 3.2, 3.19, H5 and H10, reference green and blue infrastructure throughout, and include protected species, habitats and drainage in the biodiversity clauses; also require a 2025‑2045 monitoring report for Policy 1.63.

Object

Representation ID: 857

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - The draft lacks an Infrastructure Delivery Plan to demonstrate water, sewer and power capacity for the projected growth, and the regeneration areas rely on a combined sewer system that may not support SuDS or ground‑infiltration without further evidence.

Object

Representation ID: 858

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - The flood‑risk policies (ER1‑ER7) are overly convoluted; I recommend separating surface‑water, fluvial and coastal flood policies, clarifying the drainage hierarchy, strengthening the “no increase in flood risk” requirement, mandating that surface‑water runoff not enter the combined sewer, and linking off‑site mitigation clearly to developer contributions.

Object

Representation ID: 859

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - The Water Cycle Study and Sewer Capacity Assessment show that no new surface‑water should be connected to the combined system, yet the Plan allows attenuated connections; off‑site mitigation must be quantified and delivered through nature‑based solutions to protect sewer capacity and water quality.

Object

Representation ID: 860

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - The proposed per‑capita water consumption target of 80 l h⁻¹ d⁻¹ for new dwellings is overly ambitious; the Plan should retain the 110 l h⁻¹ d⁻¹ figure as a minimum and apply the 80 l h⁻¹ d⁻¹ target only where feasible, with a clear offset scheme for developments that cannot meet it.

Object

Representation ID: 861

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - Emerging water‑resource pressures from data‑centre development are not addressed; policies should consider potential conflicts for non‑domestic water use.

Object

Representation ID: 862

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - The Water Cycle Study does not demonstrate that drinking‑water supply infrastructure will have sufficient capacity for the projected housing up to 2045; this gap must be explored and reflected in both the Plan and the Infrastructure Delivery Plan.

Object

Representation ID: 863

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Detailed comments in representation tables to be referenced - The impact of growth on the DART Transitional waterbody and Stoke Gabriel Bathing Water is insufficiently examined; policies must ensure development does not worsen the status of any water‑body, including SSSIs, SACs, MCZs and SWPAs.