Comment

Draft Black Country Plan

Representation ID: 23167

Received: 11/10/2021

Respondent: Environment Agency

Representation Summary:

11) Flood Risk Groundwater Source Protection Zones: Although we welcome the inclusion of this point, this should not sit within flood risk policy CC5 as it is not do with flood risk. In light of our comments in relation to the water cycle study, foul drainage and river basin management planning we recommend an additional policy is added which addresses the protection of water quality and the wider water environment, sitting aside from flood risk, climate change and biodiversity-specific issues. This policy requirement would sit better within such a policy body.

Our groundwater protection guidance documents state that in SPZ1 and SPZ2, the Environment Agency will only agree to proposals for infrastructure developments of non-national significance where they do not have the potential to cause pollution or harmful disturbance to groundwater flow or where these risks can be reduced to an acceptable level via Environmental Permitting Regulations if applicable.

Where a new infrastructure development presents a significant risk to groundwater, the Environment Agency may require a programme of groundwater monitoring to be designed, agreed, installed and undertaken to give early warning of any developing groundwater pollution and/or interference to groundwater flow. This programme may include off-site locations if necessary to identify pollution and to allow monitoring in the event that the site becomes inaccessible. Where appropriate, the Environment Agency will use its powers to require this at existing sites.