Draft Black Country Plan

Comment

Representation ID: 23178

Received: 11/10/2021

Respondent: Environment Agency

Sustainability Appraisal (July 2021)
In line with the comments above in relation to the Water Framework Directive (and associated River Basin Management Plans), water quality and water Cycle Study, we find the SA lacking in its consideration of the water environment baseline data and overarching policy drivers. We recommend this is rectified and associated policies incorporated into the next version of the plan.

Comment

Representation ID: 45933

Received: 11/10/2021

Respondent: Environment Agency

[draft outline Water Cycle Study]

Appendix 1

Comments made in relation to draft outline WCS which require addressing

1.4 – Objectives

• There doesn’t appear to be any mention of impact of the additional growth on the environment as a result of increased discharge volumes from sewage treatment works

3.5.3 – Drainage and Wastewater Management Plans

• Still no mention in the final paragraph of using DWMPs to assess environmental impact

7.3 – Figure 7.3

• I believe the storm tank capacity should read ‘2 hours at maximum flow’ or ’68 litres of storage per head per day’.
• Inlet CSO should be set at ‘Formula A’.

7.3.1 – Introduction

• It may be worth noting that any increase in DWF as a result of population growth is also likely to trigger a tightening of sanitary determinand and nutrient limits.

9 – Water Quality

• Why have the tables seemingly got Objectives by 2015 listed in the various tables? This is out of date information
• It is also misleading that these ‘objectives’ appear to suggest we are not aiming to achieve a classification of ‘Good’

9.4.3 – Gospel End

• Can it be confirmed that the discharge goes to the Merryhill Beck and not Merryhill Brook. Plus, I am not sure it is a direct tributary of the River Severn. I believe it joins the Wom-Penn Bk and then probably the River Smestow?

General Point – The report references capital works and improvements scheduled for Goscote WwTW that should improve WQ but it fails to note that similar improvement schemes are being carried out at numerous other works mentioned in the report (AMP6 schemes due for delivery by April 2020)

9.6 – Water Quality Conclusions

• It should be noted that there is zero leeway for deterioration within a WFD WB
which is already classed as Bad
• It is also equally important to consider the impact of growth in all WBs and not just those classed as Poor or Bad. The WFD requires that there should be no change in class and also should seek to limit deterioration with class to less than
10%.

11.3.4 – SuDS
• It could be noted that SuDS systems also keep surface water out of the sewer network creating capacity in the network for the conveyance of sewage instead of rainwater. In turn, this should improve the performance of storm related assets
on the network such as CSOs

13 – Summary and Overall Conclusions

• The table refers to certain sites having ‘environmental headroom’. I don’t see how this can be stated as I cannot see that any WQ impact assessment has been completed in this report.
• It should also be noted that if a WwTW receives increased flows then the WQ aspect of the permit may need tightening. This could result in the need for very tight, possibly unobtainable, permit limits for WQ.
• WQ Impact assessment – this needs to be changed in accordance with the point raised in 9.6 above.
• I believe the recommendations suggest that SuDs should be employed wherever there is a risk of direct connection to the environment yet elsewhere in the report, it recommends SuDs use in all locations, irrespective of a direct pathway

Table 13.2

• The wastewater collection section could do with specific mention of the need to assess the impact of growth on storm water related discharges


Appendix 2: Environment Agency flood alleviation schemes

Name of scheme NGR
Cartbridge Lane FAS, Bloxwich SK0232100518
Collins Road Sheet Pile Refurbishment SP00049541
Dawley Brook Flood Alleviation Scheme, Kingswinford SO8751989251
Ford Brook South FAS, Walsall SP0049796230
Halesowen, River Stour, Property level Protection Scheme SO9688084180
Hobnail Brook FRMS, West Bromwich SP0208894523
Kelverley Grove flood defence repairs SP0220094140
Ocker Hill Flood Storage Area SO98089423
River Stour headwater storage and INNS eradication SO9603882413
Smestow Brook FRMS, Wolverhampton SO8908499752
Tame Tunnel Flood Risk Management Scheme, Willenhall SO94589782
Thimblemill Brook Flood Alleviation Scheme, Smethwick SP0221087920
Tipton & Swan Brook Flood Alleviation Scheme SO9787293262
Waddens and Bentley Flood Relief Culvert FRMS, Willenhall SO96859924
Waddens Brook Flood Risk Management Scheme, Willenhall SO96289862
Whiteheath Brook FRMS, Tipton SO9837588669
Wordsley and Lye, Stourbridge Property level Protection
Scheme
SO8927086690