Policy CC6 - Sustainable drainage and surface water management (SuDS)

Support

Representation ID: 12047

Received: 10/10/2021

Respondent: Miss Emma Thompson

none

Comment

Representation ID: 13734

Received: 09/10/2021

Respondent: Mrs Linda Cottrell

In the future I would go so far as to suggest all new houses come with a system of rain water collection.

Object

Representation ID: 20991

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 10.27 - There are circumstances where SuDS are not suitable and where there are circumstances other than viability which prevents greenfield rates being achieved.

Support

Representation ID: 22253

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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Support: WTBBC support that all new developments should incorporate SuDS and all development proposals should provide details of adoption, ongoing maintenance, and management of SuDS.

Comment

Representation ID: 22254

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

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Comment: Whilst WTBBC support that preference will be given to systems that contribute to the conservation and enhancement of biodiversity and green infrastructure in the wider area, a clear link to Policy ENV3 and the delivery of the Draft Black Country Local Nature Recovery Strategy should be made.

Comment

Representation ID: 23093

Received: 11/10/2021

Respondent: Canal & River Trust

Subject to the Trusts' agreement to technical and commercial details, surface water can be sustainably discharged to the canal network. Water levels in the canal network are managed by the Trust using control structures such as weirs and sluices to maintain a suitable depth for navigation by boats, but also to try to avoid water levels becoming too high in periods of heavy rainfall where runoff from hard surfaces can lead to excess water passing into the canals. Given this, 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.

SUDs adjacent to or connecting to canals will need to be maintained to ensure they function as they were designed to and do not cause pollution or excess flows.

In the interests of local flood risk management and the protection of water quality, where a site proposes SUDs, this system should be designed in a way that if it were to fail the canal would not be inundated with water.

Comment

Representation ID: 23528

Received: 11/10/2021

Respondent: Historic England

Development proposals will need to consider the harm to the historic environment and ensuring that any proposals protect the significance of heritage assets, including their setting.

Object

Representation ID: 43886

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.39 Policy CC6 deals with sustainable drainage and surface water management. It states all new development should incorporate SuDS which should be designed in line with the Black Country Local Standards for SuDS.
11.40 Whilst Taylor Wimpey supports the utilisation of SuDS, there are circumstances where SuDS are not feasible, such as ground conditions. In view of this the policy requires amendment to allow for such exceptional circumstances. Furthermore, Taylor Wimpey does not support cross reference to 'design standards'. Any standards should be contained within the Plan for clarity.
11.41 Criterion 3 states for major development surface water flows must be reduced back to an equivalent greenfield rate. It goes on to state that if greenfield run¬off rates are not considered to be feasible for viability reasons, then this must be evidenced by the developer. However, there are circumstances where, for reasons other than viability, such as location or size of development or other site constraints, where greenfield rates could not be achieved unrelated to viability. The Policy should be amended to reflect this.

Support

Representation ID: 44909

Received: 10/10/2021

Respondent: Cannock Chase Council

Support the recognition of potential cross boundary impacts and the approach at
paragraph 17)

Comment

Representation ID: 46201

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Paragraph 169 of the Framework states that ‘Major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate’. The draft text to Policy CC6 states that ‘All new developments should incorporate SuDS and all development proposals should provide details of adoption, ongoing maintenance, and management of SuDS’. The proposed requirement that all new development incorporate SuDS is inconsistent with the Framework and should be amended to meet the test of soundness. The Framework (paragraph 167 (c) ) requirement that development proposed in an area at risk of flooding incorporate sustainable drainage systems is also subject to a caveat ‘…unless there is clear evidence that this would be inappropriate’. This should be reflected in the draft development plan policy.