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Mike Huntington Our ref: AC/2018/127211/06-L01 South District Council Your ref: S/2075/18 Development Control South Cambridgeshire Hall (6010) Date: 23 December 2020 Business Park Cambourne CB3 6EA

Dear Sir/Madam

OUTLINE PLANNING PERMISSION (WITH ALL MATTERS RESERVED) FOR DEVELOPMENT OF UP TO 4,500 DWELLINGS, BUSINESS, RETAIL, COMMUNITY, LEISURE AND SPORTS USES; NEW PRIMARY AND SECONDARY SCHOOLS AND SIXTH FORM CENTRE; PUBLIC OPEN SPACES INCLUDING PARKS AND ECOLOGICAL AREAS; POINTS OF ACCESS, ASSOCIATED DRAINAGE AND OTHER INFRASTRUCTURE, GROUNDWORKS, LANDSCAPING, AND HIGHWAYS WORKS LAND ADJACENT TO BARRACKS & AIRFIELD SITE, WATERBEACH, CAMBRIDGESHIRE.

Thank you for your recent consultation.

FLOOD RISK MANAGEMENT. I refer to Boyer correspondence dated 31 March 2020, received 19 November 2020, and have the following response to make in respect of their FRA update.

The current proposals include a combination of ground raising and embankment construction to reduce the risk of the development flooding if the defences fail. Applying the Applicant’s indicative development and mitigation scenario this is shown to increase the depth of flooding experienced by adjacent land owners. The applicant has committed to resolving this issue with detailed design and given the scale of the development, we are satisfied that this can be achieved, although it may result in a reduced development area. Until such time as this can be quantified, The LPA will need to be satisfied* that either the development can be achieved by higher densities/substituting open space locations or using a different quantum.

The submitted information must clearly demonstrate that the development would be safe during a flood without flood depths, velocity, frequency and duration of flooding being increased offsite.

Environment Agency position – Flood risk. The proposed outline planning permission will only be acceptable to the Agency if the proposed flood defences and any related flood control and drainage assets are protected and maintained in perpetuity. We advise that this is only achievable with appropriate S.106 planning agreement. Without a suitable legally binding agreement in place, the Environment Agency maintains its objection to the outline application. By the planning committee stage we would expect to see heads of terms for the agreement in order to provide substantive advice on the scheme before the committee.

We also recommend that any subsequent planning permission should be subject to the following planning condition submitted in draft for your consideration.

Draft EA Condition. No development approved by this planning permission shall commence, unless otherwise agreed in writing by the LPA, until such time as a scheme to manage the residual risks of flooding (both within and outside of the site) to and from the development has been submitted to, and approved in writing by, the local planning authority. The scheme shall be fully implemented and subsequently maintained, in accordance with the scheme’s timing/ phasing arrangements, or within any other period as may subsequently be agreed, in writing, by the local planning authority.

Reason(s). To prevent flooding by ensuring that the satisfactory storage or conveyance of flood water diverted by the site during a breach of the River Cam Defences.

Although we are satisfied at this stage that the proposed development is reasonably attainable in principle (assuming the LPA is satisfied that some flexibility exists as described above*), the applicant will need to provide further information, as part of a site flood risk and drainage strategy, to ensure that the proposed development can go ahead without posing an unacceptable flood risk to existing properties in the vicinity of the site and Waterbeach.

The Environment Agency will be pleased to assist in the assessment of proposals submitted by the applicant to meet these conditions. Whilst we comment on s106 heads of terms, we do not normally advise on the content of the legal agreement itself where, as we expect in this case, we are not signatory to the agreement.

Flood Risk Activity Permit. Under the Environmental Permitting Regulations 2010 a flood risk activity permit will be required from the Environment Agency for any proposed works or structures within the flood plain or within 8 metres of the toe of the landward bank of the River Cam which is designated a ‘main river’, irrespective of any planning approval.

Information on how to apply for a flood risk permit can be found on the GOV.UK website at: www.gov.uk/guidance/check-if-you-need-an-environmental-permit. Any application for flood defence consent should be submitted to the following email address: PSOEastAnglia [email protected]

FOUL WATER DRAINAGE. I refer to recent AWS update statement dated 07 December 2020.

We are grateful to AWS for their input into this matter and have amended your draft Foul Water (including new Water Recycling centre) Condition 5 accordingly, see attached.

It is important that all parties appreciate the significance of these Conditions given the dwindling local foul water drainage capacity, and the complexity of balancing infrastructure provision and compliance with environmental legislation. The limited, and in some cases non-existent, permitted capacity at local WRC’s poses a significant threat to achieving development targets within this geographical area. It is therefore essential that these conditions are secured, complied with and monitored throughout the entirety of the construction.

GROUNDWATER, PILING AND BASEMENT CONDITIONS. These issues are currently work in progress and we envisage responding to you early in the New Year.

DRAFT GREATER CAMBRIDGE PLANNING CONDITIONS. Please find attached our response to your draft conditions.

Yours faithfully

Mr. T.G. Waddams Planning Liaison

Direct e-mail: [email protected]

Enc: Draft GCP conditions

We are currently working to government advice regarding Covid-19 and as such our operational ability has been disrupted. We are trying to work remotely as best as we can. However our ability to deliver within our normal timescales is compromised and we are responding to our current work on a risk based approach.

(My normal working days are Tuesdays, Wednesdays and Thursdays.) Please note – Our hourly charge for pre application assessments is currently £100 + VAT Environment Agency, East Anglia Area (West), Bromholme Lane, Brampton, , Cambs. PE28 4NE. www.gov.uk/environment-agency