Design and Townscape Guide - Refresh 2009 (Consultation Draft)

Comment

Representation ID: 83

Received: 04/06/2009

Respondent: Environment Agency

Para 14. We agree that Climate change, flood risk, sustainable use of resources and conservation and enhancement of biodiversity are key elements when considering sustainable development within the Borough of Southend.

Support

Representation ID: 84

Received: 04/06/2009

Respondent: Environment Agency

Para 15. We support the commitment to create a network of green spaces across the borough. A network of linked green spaces will help enhancement biodiversity by creating suitable wildlife corridors.

Support

Representation ID: 85

Received: 04/06/2009

Respondent: Environment Agency

Para 16. We support reference to protecting and enhancing the Thames. This should be expanded to acknowledge the wider blue ribbon network such as the Eastwood Brook, Prittlebrook and other watercourses.
For your information we would like to remind you that under the terms of the Water Resources Act 1991 and the Land Drainage Byelaws, the prior written consent of the Agency is required for any proposed works or structures either affecting or within 9 metres of the tidal or fluvial flood defence. Early consultation with the Environment Agency is recommended.

Comment

Representation ID: 86

Received: 04/06/2009

Respondent: Environment Agency

Para 22. New developments should be designed to retain any existing water features such as ponds and ditches. Retention of these features will help to ensure existing habitat is protected and drainage structures are retained to reduce the impact of flooding.

Comment

Representation ID: 87

Received: 04/06/2009

Respondent: Environment Agency

Para 35. We agree that the principle of development along the Seafront has been agreed through the identification of this area within the core Strategy. However, the Sequential Test must still be applied to all development proposed in an area at risk of flooding. Even within the Seafront zone, areas of Flood Zone 1 (low flood risk) exist. Ideally, through the application of the sequential test in this area, development should be located within Flood Zone 1, before zone 3. The sequential approach should also be applied. On a site wide level the most vulnerable uses should be located on the parts of a site with the lowest flood risk.

Comment

Representation ID: 88

Received: 04/06/2009

Respondent: Environment Agency

Para 36. Where the requirements of the sequential test have been met and it can be demonstrated that there are no other less vulnerable sites, then a detailed Flood Risk Assessment will be required. This paragraph should make it clear that the Sequential test applies to all development (Seafront or otherwise), separating out flood risk mitigation and adaption.
Flood Risk Mitigation: The mitigation section should start with the positive making space for water ideas you have listed: flood storage, conveyance, re-creating functional flood plain, setting back defences. Then you can move on to other mitigation measures such as improved drainage systems, flood barriers and bunds.
Flood Risk Adaption: The recommendations on Flood Risk Adaption should be separated out into separate bullet point. This could include your point on flood proofing, but the CLG publication 'Improving the flood performance of new buildings', http://planningportal.gov.uk/uploads/br/flood_performance.pdf addresses much wider principles that should be listed in your document.

Comment

Representation ID: 89

Received: 04/06/2009

Respondent: Environment Agency

We can never remove the risk of flooding entirely. In order to minimise disruption and the cost of flooding, the remaining risk needs to be managed and development designed to be brought back into use as soon, easily and economically as possible. Developments should be designed and constructed to be easily renovated after flooding. Building materials and utilities should not need replacing.
Developers may also wish to incorporate flood resistance measures in order to minimise the damage from flooding.
All proposals for development should identify how flood resilience measures will be implemented.

Comment

Representation ID: 90

Received: 04/06/2009

Respondent: Environment Agency

Some of these design features should be lifted out into the Appendix checklist.
Flood Risk and Southend City Beach Proposals: We made some specific comments on the Southend Renaissance Southend City Beach Stage 2 report, that may be relevant to this section. We welcome the Remodelled Sea Wall improvement works described in the Report and are encouraged and pleased to see that provision has been made for Climate change. It is clear that the Design Report recognises the issue of Flood Risk. Any new design should recognise the climate change criteria shown in Table B.2 of Planning Policy Statement 25 (PPS 25). We welcome the aspiration to set back the defence wall and open up the beach and seafront further. We wish to make you aware of the Environment Agency's Encroachment Policy which could be important if the preferred design relies on constructing a new tidal defence into the beach area, ahead of the existing defence line. We are generally opposed to any encroachment into the estuary.

Comment

Representation ID: 91

Received: 04/06/2009

Respondent: Environment Agency

Section 3. 3.2 Resource minimisation.
Southend Borough Council are currently undertaking a Water Cycle study in conjunction with other South Essex Authorities. The outputs of the study will indicate the degree to which the area is water stressed, indicating measures that should be taken to ensure water efficiency.

Comment

Representation ID: 92

Received: 04/06/2009

Respondent: Environment Agency

Para 152. Development should be located to minimise waste. Co-locating developments to exploit industrial symbiosis can minimise waste and create considerable competitive commercial advantage.
The following points should be added to your Construction Checklist Development should be designed to:
. retain and refurbish rather than rebuild
. be easily adapted to future changing uses
. enable reuse and recycling at least 90% of demolition and construction waste
. minimise over-ordering and damage of materials
. use standard components
. have a recycled content of at least 30%
All development proposals should identify how they meet the above waste minimisation and management objectives.