29. Do you agree with the suggested option?

Support

Representation ID: 477

Received: 03/08/2010

Respondent: Carole Mulroney

Development proposals in high risk areas should always be accompanied by a flood risk assessment

Object

Representation ID: 622

Received: 07/08/2010

Respondent: Herbert Grove Residents

When planning permission is being sought for the development of a property a separate risk assessment should not be necessary if there already one for the same post code.

Comment

Representation ID: 785

Received: 10/08/2010

Respondent: Iceni Projects

Issue DM7 - Flood Risk and Water Management: The proposed approach needs to be revised to accord with the requirements of the Flood and Water Management Act 2010 in terms of SUDS provision and the changes to connectivity arrangements

Support

Representation ID: 935

Received: 19/10/2010

Respondent: Environment Agency

Issue DM7: Question 29
We are in general agreement with the approach set out in this suggested option. It should be noted that, under part 1, sustaining the current level of flood risk into the future does not necessarily mean that defences will be (or are able to be) raised. Effective floodplain management is therefore likely to play a major role into the future - this includes effective development control, for example applying the principles of PPS25 including the Sequential Test and the Exception Test, and also effective emergency planning.

Comment

Representation ID: 999

Received: 20/10/2010

Respondent: Savills

Omission - It is not clear how the findings of TE2100 and CFMP2008 have been reflected both in DMDPD and CAAP, at this section states that "the level of actual risk and the areas actually remaining at risk are therefore likely to be much lower than indicated by these maps, subject to the structural integrity of the defences being maintained."
The submission drafts of the DMDPD and CAAP should include a plan delineating the flood risk areas that have been agreed with the Environment Agency.
Both Plan Documents should set out any constraints on the form of development and / or appropriate uses with the flood risk area, setting out clearly any differences within different areas of risk.

Comment

Representation ID: 1000

Received: 20/10/2010

Respondent: Savills

The commentary states that "any development proposals within areas of flood risk will require a detailed flood risk assessment, appropriate mitigation measures and agreement with the Environment Agency"
This approach and the preferred option, rather than the alternative option, need to be ratified by the Environment Agency prior to the Submission Drafts of the CAAP and DMDPD being published, given the potential conflict with national planning policy on flood risk (PPS 25 and related Practice Guidance).
This requirement to provide an FRA should be integrated into the approach (it currently is not) and form part of the overarching design policies (DM1 and Design and Townscape DPD).

Comment

Representation ID: 1001

Received: 20/10/2010

Respondent: Savills

Given the exceptional circumstances in Southend, we generally support the suggested option, rather than relying on the alternative option and sequential and exceptions tests in PPS25.
However this suggested option and the approach to considering flood risk must have the full support of the Environment Agency, before the submission Draft of the DMDPD and CAAP are published, so that discussion with the EA on a site by site basis during the life of the Plan are considered in this context.