Publication

We are raising a generic comment for all Wymondham site allocations:
The latest version of the Water Cycle Study shows that Wymondham WRC will be over capacity post growth. This needs highlighting here. As stated, the latest findings and recommendations from the WCS should be incorporated and reflected in the Local Plans and Site Allocations.

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.

GNLP0409R

The text does not acknowledge that the site is in future Flood Zone 3a but flood risk issues should be able to be addressed on a site specific basis.

The text does not acknowledge that the site is in future Flood Zone 3a but flood risk issues should be able to be addressed on a site specific basis.

We fully support this allocation as it requires the development to be sited in Flood Zone 1 as we previously requested, and is not allowing less vulnerable in the flood zone as stated in the SFRA.

The supporting text includes our previous comments and therefore we are satisfied with this site allocation.

We therefore fully support this allocation.

The paragraph needs to refer to water quality, environmental legislation such as water quality and revert this back to the potential impacts of developments flows directed to Water Recycling Centres. The policy should refer to the Water Cycle Study that has been submitted in support of this Local Plan.

Paragraph 257 has been added following our previous response which states “to ensure that development does not have a detrimental impact on the water environment, particularly in relation to water quality and the potential for impacts on the water-based sites protected under the Habitats Regulations Directive, major development will be dependent on the waste water infrastructure being capable of accommodating and treating the additional flows from development or being able to be made so”. We assume this is in relation to water/foul water but needs to be clearer and say that.

Whilst the addition of paragraph 257 is positive, this could still be improved by incorporating the text previously suggested as highlighted below:
“Taking account of the above evidence, the policy therefore commits the Greater Norwich authorities to ensuring for the timely delivery of improvements to wastewater infrastructure by AW in line with development time scales, ensuring there is sufficient capacity ahead of occupation of properties".

There is no mention of wastewater infrastructure directly in the policy. This should be highlighted as it is the key bit of infrastructure that poses the most risk to the water environment. A sound local plan will also need to highlight the need to phase development with infrastructure upgrades, which this policy does not do.

It is important to note that the plan has not addressed water quality sufficiently anywhere. The plan has not referred to key legislation such as the Water Framework Directive (WFD). Without necessary safeguards in the Local Plan, the sewerage undertaker could be placed in a position where they will be breaching permit as they are obliged to accept flows. This could create an exceedance in environmental legislation such as the Water Framework Directive.

Please note that our response to this policy should be read in conjunction with our representation to paragraph 145. We have raised our unsound representation in this policy itself as this would be the most appropriate location for these comments to be addressed.