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APPENDIX 2 Consultation Responses – Planning Brief Clovenfords West

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APPENDIX 2 Consultation Responses – Planning Brief Clovenfords West APPENDIX 2 Consultation responses – Planning brief Clovenfords West, Clovenfords Contributor Summarised comments Response Scottish SEPA are satisfied the areas of flood risk, drainage and waste Noted. Environment have been adequately addressed in the brief. Protection Agency Due to the morphology of the catchment with steep slopes that Noted. The Council (SEPA) surround Clovenfords pluvial (over land) flooding is also an has used the 2nd issue. generation flooding maps to inform the planning brief and early consultation on the brief has included the Council’s flood prevention section. SEPA note that the brief includes the erection of a new school. Noted. The school Due to the sensitive nature of the school, it is recommended is not proposed on that the building is free from flooding from the 1 in 1000 year the site subject to event as recommended in the SPP7 risk framework. the brief, but on a site on higher grounds and closer to the village centre. Any flood risk issues will be dealt with at planning application stage for that site. Not all of the site may be developable and areas of flood risk Accepted in part. should be avoided in the first instance. SEPA recommend that The constraints the constraints section of the brief is updated to state that “no section will be built development should take place on the functional flood updated to say that plain, and that this area should be safeguarded as open development of space”. housing or major structures should not take place on the functional flood plain and the area should be safeguarded for open space. The development proposed, in the finalised brief, is a bridge for pedestrians/cyclists to minimise impact on the flood plain and the SAC. There are other pedestrian/cycle links to and from the site if flooding occurs. The Flood Risk Assessment should be undertaken in Accepted. The accordance with SEPA’s technical guidance. This guidance is flood risk section in available on our planning website through the following link: the annex on www.sepa.org.uk/customer_information/planning/flood_risk.as Developer px. Guidance SEPA recommends that the flood risk section in the developer document will be guidance in Annex 2 is updated to include reference to this updated to include technical guidance. the link to SEPA’s technical guidance. The flood risk assessment for this site should in particular Accepted. The include: requirements for x an assessment of the risk of flooding from all the flood risk sources, including fluvial and pluvial; assessment will be x identify the location of the culverts (out with the included in the site boundary) and the assess the potential flood annex on risk associated with these structures; Developer x the hydraulic model should include the culverts Guidance. and bridges located along the two main watercourses and allow a degree of blockage. For residential developments such as this, two levels of SUDS Noted. treatment (source control measures and pond or wetland) would be required for all hardstanding areas (including roads). It is important to ensure that adequate space to accommodate Noted. Figure 3 is SUDS is safeguarded within the site layout, and that this is out for illustrative with the 1 in 30 year flood plain. We note that space for SUDS purposes only and has been allocated adjacent to the watercourse in Figure 3 – if further research Development Vision, which may not be possible due to the shows that the associated flood levels. location is not suitable adjustments to the location in the development vision can be made at planning application stage. SEPA require all developments within a sewered area to Noted. Developer connect to the public sewer. As this site is within close Guidance in Annex proximity to a sewered area we would expect the necessary A makes reference upgrades to be undertaken to enable connection. Early contact to Local Plan policy with Scottish Water is encouraged. SEPA is unlikely to support Inf. 5 on Waste an application for a private waste water system. Water Treatment Standards and recommends developers to contact Scottish Water early in the planning process. SEPA supports the need for a Drainage Impact Assessment. Noted. The In addition SEPA recommends that the SUDS section in the Developer developer guidance in Annex 2 is updated to reflect our Guidance on requirement for two levels of treatment, and for features to be SUDS will be located out with the 1 in 30 year flood plain as specified above. updated to include the requirement for two levels of treatment and for SUDS to be located outside the 1 in 30 year flood plain. As specified in the planning brief, SEPA would expect space Noted. for collection, segregation, storage and possibly treatment of waste (e.g. individual and/or communal bin stores, compositing facilities, and waste treatment facilities) to be allocated within the site layout. We note that the site is located in close proximity to a Special Noted. The Council Area of Conservation, and as such the ecological impact of the is aware of the development will need to be considered. Please note that in an location close to effort to reduce duplication of effort between us and Scottish SAC and is in the Natural Heritage (SNH) we no longer provide advice on finalised planning ecological issues. As you are aware, SNH have a clear lead brief including only on biodiversity and nature conservation policy and we ask that a pedestrian/cycle their comments on the planning brief are taken into account bridge to be constructed over the burn to minimise impact. Scottish SNH supports the publication of planning briefs as a means for Noted. Natural clearly setting out expectations of the Council and constraints Heritage and opportunities in the development of the site as means of (SNH) improving the design of housing development in the Borders. SNH expect the developer to submit a design statement with Noted. Design their planning application, in accordance with PAN 68 – statement is Design Statements. included in the key submissions on page 15. SNH welcomes the advice regarding landscape considerations Noted. and design, pedestrian and cycle access and sustainable building design. Specific comments; The sentence referring to the designated Accepted. (SAC) site, River Tweed Special Area of Conservation (page 6) and (AGLV) will be should include (SAC) so that the use of the acronym on page included on page 6 7 is self explanatory. Note that the SAC is not a landscape and the heading on designation (page 7) and inclusion in this paragraph is page 7 will be misleading. SNH strongly suggest a link to SNH website is changed to included so that a developer can locate the citation for the ‘Designated sites’. designation. Web link will be included. Accepted. The last Protected species: No reference to the potential requirement sentence in the for European protected species (EPS – bat and otter are most Phase 1 Habitat likely) surveys, depending on the extent of the development Survey paragraph impact – especially in relation to the Caddon Water and will be expanded to woodland. The Phase 1 habitat survey paragraph (page14) include’ including may be appropriate place to include reference to need for a habitat for simple survey of suitable habitat for EPS and badger setts. European protected species and badger setts.’ Historic Historic Scotland has no comments to offer for our statutory Noted. Scotland historic environment remit. The Council’s conservation and archaeology service should Noted. Countryside advise on conservation area and Category B and C9S) listed & Heritage section building issues and on the potential archaeological interest has been identified in para 5.8. consulted on the draft planning brief before the public consultation. For information; Memorandum of Guidance on Listed Buildings Noted. and Conservation Areas is being replaced. Managing Change in the Historic Environment Guidance Note is out for consultation. The guidance notes have been designed to offer clear, consistent advice to professionals. Developers and applicants and be published on-line. CALA Homes The contributor fundamentally disagrees with the proposal for Accepted. The (East) Limited site access via Caddonfoot Road. When discussed at Local finalised brief Plan Inquiry, roads officer agreed point of access from Cliff includes access Road (A72) was acceptable, and provision of roundabout from the A72 to would assist in reducing traffic speeds into the village. follow the decision Representation includes quote from the Report of Inquiry made at the Local (page 55-44, 2nd last para.). “the site is well related to the Plan Inquiry and village, with even the most remote part of the proposed new avoid unnecessary housing conveniently located for pedestrian access (about impact on the 600m from the village core); visually well concealed and Special Area of contained within the local topography to the west and the Conservation woodland to the south; largely free of flooding constraints; and (SAC) and the that suitable road access (acceptable to the Council’s Roads flood plain. Officer) could be provided by means of new roundabout on the A72”. Access arrangements contained within the Draft Planning Brief are contrary to the reasons of justification for the allocation of the subjects. The proposal for Caddonfoot Rd access would necessitate Accepted. A provision of a bridge structure to span a considerable area of carefully designed flood plain, leading to significant infrastructure disproportionate minor bridge to local surroundings and character of Caddonfoot Rd. should have less of an impact on flooding and the character of the area. CALA has provided the Council with a copy of Flood Risk Accepted in part. A Assessment, and if applied correctly, the ‘indicative crossing’ Flood Risk (figure 3) could be regarded as not representative of the Assessment flooding characteristics.
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