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DC/18/05621 Land Off Jacks Green Road, Creeting St Mary, Suffolk

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DC/18/05621 Land Off Jacks Green Road, Creeting St Mary, Suffolk Consultee Comments for Planning Application DC/18/05621 Application Summary Application Number: DC/18/05621 Address: Land Off Jacks Green Road Creeting St Mary Suffolk Proposal: Outline Planning Application (all matters reserved) - Residential Development for up to 43 dwellings(14 affordable). Case Officer: Daniel Cameron Consultee Details Name: Mrs Jennie Blackburn Address: 1 All Saints Road, Creeting St Mary, Ipswich, Suffolk IP6 8NF Email: [email protected] On Behalf Of: Creeting St. Mary Parish Clerk Comments The Parish Council strongly object to this application for the following reasons: - Over development of Creeting St Mary - Over subscribed school and struggling doctors surgery in Needham Market - Power cables overhead of the proposed site - Current flooding issues would become a lot worse Daniel Cameron Our ref: AE/2019/124097/02-L01 Mid Suffolk District Council Your ref: DC/18/05621 Planning Department Endeavour House Russell Road Date: 21 May 2019 Ipswich Suffolk IP1 2BX Dear Mr Cameron RESIDENTIAL DEVELOPMENT FOR UP TO 43 DWELLINGS(14 AFFORDABLE). LAND OFF JACKS GREEN ROAD, CREETING ST MARY, SUFFOLK Thank you for your consultation dated 13 May 2019. We have reviewed the application as submitted and have no objections provided the conditions below on Groundwater and Contaminated Land are includeded should the permission be granted. We are also including advice on Flood Risk below. Groundwater and Contaminated Land The site is located on Secondary B head deposits to the north of the site and Secondary A aquifer, Glaciofluvial sand and gravel deposits over the rest of the application site. The bedrock beneath the site is Newhaven Chalk, a principal aquifer. The site is within a Source Protection Zone 3 and a Surface Water Safeguarded Zone. We have reviewed the Geosphere Environmental Phase 1 Desk Study and PRA dated 6/2/19 and recommend the following condition is attached to any planning application granted. We consider that planning permission could be granted to the proposed development as submitted if the following planning conditions are included as set out below. Without these conditions, the proposed development on this site poses an unacceptable risk to the environment and we would object to the application. Condition If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the local planning authority) shall be carried out until the developer has submitted a remediation strategy to the local planning authority detailing how this unsuspected contamination Environment Agency Iceni House Cobham Road, Ipswich, IP3 9JD. Customer services line: 03708 506 506 www.gov.uk/environment-agency Cont/d.. shall be dealt with and obtained written approval from the local planning authority. The remediation strategy shall be implemented as approved. Reason for Condition To protect and prevent the pollution of the water environment (particularly groundwater associated with the underlying Secondary and Principal Aquifers, from potential pollutants associated with current and previous land uses) in line with National Planning Policy Framework (NPPF; paragraphs 170 and 178), EU Water Framework Directive, Anglian River Basin Management Plan and Environment Agency Groundwater Protection Position Statements (2017) A4 – A6, J1 – J7 and N7. National Planning Policy Framework (NPPF) paragraph 170 states that the planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of water pollution. Government policy also states that planning policies and decisions should also ensure that adequate site investigation information, prepared by a competent person, is presented (NPPF, paragraph 178). Surface Water Drainage The INGENT FRA dated April 2019 has confirmed infiltration drainage is not proposed on the site and therefore GWCL have no further comments. We recommend that developers should: 1) Refer to our ‘Groundwater Protection’ website; 2) Refer to our CL:AIRE Water and Land Library (WALL) which includes the risk management framework provided in CLR11, ‘Model Procedures for the Management of Land Contamination’, when dealing with land affected by contamination, and also includes the Guiding Principles for Land Contamination for the type of information that we require in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, for example human health; 3) Refer to our Land Contamination Technical Guidance; 4) Refer to ‘Position Statement on the Definition of Waste: Development Industry Code of Practice’; 5) Refer to British Standards BS 5930:1999 A2:2010 Code of practice for site investigations and BS10175:2011 A1: 2013 Investigation of potentially contaminated sites – code of practice 6) Refer to our ‘Piling and Penetrative Ground Improvement Methods on Land Affected by Contamination’ National Groundwater & Contaminated Land Centre Project NC/99/73. The selected method, including environmental mitigation measures, should be presented in a ‘Foundation Works Risk Assessment Report’, guidance on producing this can be found in Table 3 of ‘Piling Into Contaminated Sites’; 7) Refer to our ‘Good Practice for Decommissioning Boreholes and Wells’. 8) Refer to our ‘Dewatering building sites and other excavations: environmental permits’ guidance when temporary dewatering is proposed Flood Risk We have no flood risk objection to the planning application, providing that you are Cont/d.. 2 satisfied that the development would be safe for its lifetime and you assess the acceptability of the issues within your remit. The applicant has sequentially sited all proposed development within Flood Zone 1. Our maps show the site boundary lies within fluvial Flood Zone 3a defined by the ‘Planning Practice Guidance: Flood Risk and Coastal Change’ as having a high probability of flooding. The proposal is for residential development for up to 43 dwellings, which is classified as a ‘more vulnerable’ development, as defined in Table 2: Flood Risk Vulnerability Classification of the Planning Practice Guidance. We are satisfied that the flood risk assessment, referenced 1708-024 Creeting St Mary, Suffolk, Rev A and dated April 2019, provides you with the information necessary to make an informed decision. In particular: Drawing 252 01 Rev A shows all proposed development (residential dwellings) lies within Flood Zone 1 The access and egress route travels through Flood Zones 1 and therefore does have a safe route of access. Flood depths on the site and within the building remain unknown because the Flood Zones are derived from JFLOW modelling. Flood Storage Compensation is not required. A Flood Evacuation Plan has not yet been proposed. JFlow The Flood Zone maps in this area are formed of national generalised modelling, which was used in 2004 to create fluvial floodplain maps on a national scale. This modelling was improved more recently, using a more detailed terrain model for the area. This modelling is not a detailed local assessment, it is used to give an indication of areas at risk from flooding. JFLOW outputs are not suitable for detailed decision making. Normally, in these circumstances, an FRA will need to undertake a modelling exercise in order to derive flood levels and extents, both with and without allowances for climate change, for the watercourse, in order to inform the design for the site. However, as the applicant has sequentially sited their proposed development to be wholly within Flood Zone 1, we feel it is unnecessary to request the applicant to model the designated ordinary watercourse with regards to the safety of the proposed development because the development should remain dry and provide refuge throughout the 0.1% (1 in 1000) annual probability event. If you feel you do not have sufficient information with regards to flood levels on the access/egress routes, we advise that modelling should be undertaken to accurately establish the risk to the access/egress routes in terms of potential depths and locations of flooding. The watercourse should be modelled in a range of return period events, including the 1 in 20 (5%), 1 in 100 (1%) and 1 in 1000 (0.1%) year events, both with and without the addition of climate change. Please remember to request the new climate change allowances. The flood levels on the access/egress routes should be determined and compared to a topographic site survey to determine the flood depths and extents along the access/egress routes. This should be used to establish a route of safe access. Cont/d.. 3 Further flood risk advice can be found in the appendix to this letter. We trust this advice is useful. Yours sincerely Mr Liam Robson Sustainable Places - Planning Advisor Direct dial 020 8474 8923 Direct e-mail [email protected] Cont/d.. 4 Flood Risk Appendix Guidance for Local Council on Safety of Inhabitants Safety of Building The development has been designed to provide refuge above the predicted flood levels. Given that refuge is identified as a fall back mitigation measure it is important that the building is structurally resilient to withstand the pressures and forces (hydrostatic and hydrodynamic pressures) associated with flood water. We advise that supporting information and calculations are submitted to you to provide certainty that the buildings will be constructed to withstand these water pressures. Emergency Flood Plan The Environment Agency does not normally comment on or approve the adequacy of flood emergency response procedures accompanying development proposals, as we do not carry out these roles during a flood. Our involvement with this development during an emergency will be limited to delivering flood warnings to occupants/users covered by our flood warning network. The Planning Practice Guidance to the National Planning Policy Framework states that those proposing developments should take advice from the emergency services when producing an evacuation plan for the development as part of the flood risk assessment.
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