Support

Representation ID: 664

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of this policy. We welcome the inclusion of point 2 which states:
Preference will be given to systems that contribute to the conservation and enhancement of biodiversity and green infrastructure in the wider area.

Comment

Representation ID: 719

Received: 22/12/2023

Respondent: Canal and River Trust

Absence of separate justifying text.

We advise that subject to the Trust’s owner agreement to technical and commercial details, surface water can potentially be sustainably discharged to the canal network. Surface water discharge to canals can be a highly effective way of managing local surface water flood risk and may allow development of sites that would otherwise not be viable due to concerns with alternative site drainage options. Should be designed and maintained to ensure they do not pollute or inundate the canal with water.

We request canals be specified as an option for surface water drainage and are listed within Policy DLP46.

Comment

Representation ID: 809

Received: 30/01/2024

Respondent: Historic England

DLP46. A reference within this policy to the potential affects for the historic environment would also be beneficial.

Comment

Representation ID: 872

Received: 09/04/2024

Respondent: Severn Trent

Agent: Severn Trent

Management of surface water is an important feature of new development as the increased coverage of impermeable area on a site can increase the rainwater flowing off the site. The introduction of these flows to the public sewerage system can increase the risk of flooding for existing residents. It is therefore vital that surface water flows are managed sustainably, avoiding connections into the foul or combined sewerage system and where possible directed back into the natural water systems. We recommend that the following policy wording is included in your plan to ensure that surface water discharges are connected in accordance with the drainage hierarchy:

Drainage Hierarchy Policy
New developments shall demonstrate that all surface water discharges have been carried out in accordance with the principles laid out within the drainage hierarchy, whereby a discharge to the public sewerage system is avoided where possible.

Supporting Text:
Planning Practice Guidance Paragraph 80 (Reference ID: 7-080-20150323) states:
“Generally, the aim should be to discharge surface water run off as high up the following hierarchy of drainage options as reasonably practicable:
1. into the ground (infiltration);
2. to a surface water body;
3. to a surface water sewer, highway drain, or another drainage system;
4. to a combined sewer.”

Sustainable Drainage Systems (SuDS) Sustainable Drainage Systems (SuDS) represent the most effective way of managing surface water flows whilst being adaptable to the impact of climate change and providing wider benefits around water quality, biodiversity, and amenity. We therefore recommend that the following policy wording is included within your plan regarding SuDS:

Sustainable Drainage Systems (SuDS) Policy
All major developments shall ensure that Sustainable Drainage Systems (SuDS) for the management of surface water run-off are included, unless proved to be inappropriate. All schemes with the inclusion of SuDS should demonstrate they have considered all four areas of good SuDS design: quantity, quality, amenity and biodiversity. Completed SuDS schemes should be accompanied by a maintenance schedule detailing maintenance boundaries, responsible parties and arrangements to ensure the SuDS are managed in perpetuity.

Supporting Text:
Sustainable Drainage Systems (SuDS) should be designed in accordance with current industry best practice, The SuDS Manual, CIRIA (C753), to ensure that the systems deliver both the surface water quantity and the wider benefits, without significantly increasing costs. Good SuDS design can be key for creating a strong sense of place and pride in the community for where they live, work and visit, making the surface water management features as much a part of the development as the buildings and roads.