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Representation ID: 23787

Received: 22/03/2021

Respondent: Environment Agency (Eastern Region)

Representation Summary:

Whilst we are able to find this allocation sound, there is no mention of the need to preclude development on a large part of GNLP0360 due to being Flood Zone 3b, and there is no mention on the need to not increase flood risk elsewhere and therefore provide flood storage.

Full text:

We are finding this allocation sound although we do have some comments for your review below.

This allocation includes the below 2 statements:

1) Site Allocation: ‘Site specific flood risk assessment must be undertaken prior to development and the design of the development will need to be flood resilient and incorporate appropriate mitigation measures in order to address flood risk from both river and surface water flooding.’
2) Policy 7.1 – ‘achieving high quality, locally distinctive, energy efficient and flood resilient design which addresses identified risks from river and surface water flooding and mitigates against potential sources of noise and air pollution and establishes strong built frontages along the River Wensum and the defining network of streets and spaces with the sites;’

The above statements are good, although there is no mention of the need to preclude development on a large part of GNLP0360 due to being Flood Zone 3b, and there is no mention on the need to not increase flood risk elsewhere and therefore provide flood storage. There is lots of mention of ‘flood resilient construction’ when this tends to mean the buildings can recover from a flood, while we would require buildings to have raised floor levels to prevent them flooding in the first place. It is however possible that perhaps this is just differing terminology and the intention is the same as us.

It is positive that the SFRA Site Summary Table includes lots of detail as to what is required to develop the site, so therefore this information should be covered here.