Mike Huntington Our ref: AC/2018/127211/07-L01 Greater Cambridge Planning Service Your ref: S/2075/18 Development Management South Cambridgeshire Hall Date: 19 January 2021 Cambourne Business Park Cambridge CB3 6EA 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 (REVISED ES, PARAMETER PLAN, MASTERPLAN, PLANNING STATEMENT) (REVISED DRAFT PLANNING CONDITIONS) LAND ADJACENT TO WATERBEACH BARRACKS & AIRFIELD SITE, WATERBEACH, CAMBRIDGESHIRE. Thank you for updating the Environment Agency on the various proposed [draft] planning conditions and ‘heads of terms’ arrangements for the protection, maintenance and management of the proposed on-site secondary flood defences. Below we advise on the proposed conditions and close some outstanding advice on groundwater protection, environment management, water resources protection and water voles. These were in abeyance pending resolution of flood risk management and water quality matters that the Environment Agency regards as resolved, subject to the conditions listed below. We are aware that post-committee, should it be minded to approve the application, legal agreements and some tweaks to conditions may be necessary to ensure that the two are compatible and effective. We will be happy to advise as requested. Environment Agency position: Flood risk management Further to our previous letter dated 23 December 2020, the Environment Agency has now considered the ‘Appendix G - Heads of Terms Summary’ as received 14 January 2021 as an outline means of maintaining the flood defences. Whilst the maintenance proposals seem reasonable, the Environment Agency will need to be satisfied in detailed post-committee discussions that the following outline terms will be secured through legal agreements: There is a sustainable source of inspection and maintenance funding in perpetuity, which we understand will be charged from future landowners on the development; Environment Agency (Anglian Central Area) Sustainable Places Team Customer services line: 03708 506 506 Bromholme Lane, Brampton, Huntingdon, Cambridgeshire PE28 4NE Calls to 03 numbers cost the same as calls to standard Email: [email protected] geographic numbers (i.e. numbers beginning with 01 or 02). www.environment-agency.gov.uk Cont/d.. That all flood management assets will be on public or community owned land such as highways and public open space. Such assets should not be situated within private curtilages such as gardens or employment sites where asset protection, inspection, maintenance and renewal could be impractical; Submission of full details of flood management assets including GIS location shapefiles, design and construction details, including cross sectional plans, all embankment or control structure crest heights [AoDN] and channel depths. This land and asset ownership information and whole life maintenance/renewal plans will be provided and added to a Council or Environment Agency asset register [‘Third Party Asset Register’] to help assure future inspection and maintenance. Heads of terms Summary EA position: Subject to the achievement of the referenced ‘Appendix G’ heads of terms and the above terms of ownership, funding and asset registry, the Environment Agency has no objections to the proposals for maintenance and adoption of on-site flood defence assets. The Environment Agency has no objections to the flood risk management design aspects of the development. This is subject to the following condition that requires the flood risk management scheme to be submitted at a very early stage of site wide design, given the intrinsic need to allow sufficient space and protected design measures to safely deal with a flood from a breach of the River Cam embankments: Flood risk [47] Condition: No Reserved Matters applications shall be submitted and no development shall commence until such time as a scheme to manage the residual risks of flooding from a River Cam flood embankment breach (scenarios to cover risks 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 reflected and detailed in Reserved Matters submissions and 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: To manage the risk flooding by ensuring the satisfactory storage or conveyance of flood water displaced or diverted by the development during a breach of the River Cam Defences, in accordance with the National Planning Policy Framework and Policies SS/6, CC/8 and CC/9 of the South Cambridgeshire Local Plan 2018. We have advised adding references to water re-use to this primarily surface water condition, as follows: Surface water, flood, and water management – site wide [48]. No development shall commence until an integrated surface water drainage, water use and flood risk management strategy for the site has been submitted to and approved in writing by the Local Planning Authority. The strategy shall be based on the surface water principles and parameters set out in the latest FRA update (Boyer - Environment Agency (Anglian Central Area) Sustainable Places Team Customer services line: 03708 506 506 Bromholme Lane, Brampton, Huntingdon, Cambridgeshire PE28 4NE Calls to 03 numbers cost the same as calls to standard Email: [email protected] geographic numbers (i.e. numbers beginning with 01 or 02). www.environment-agency.gov.uk Cont/d.. 31 March 2020) and EIA submissions and the water use and breach risk management principles in the FRA, EIA and residual flood risk management plan to satisfy condition [47] above. The strategy shall include phasing arrangements, details of primary infrastructure for each phase and plans for whole life drainage and flood management asset operation, maintenance, and contingency. The surface water management strategy shall specify a SUDS hierarchy, to ensure that infiltration systems are used in preference to sealed systems where it can be demonstrated that infiltration will not pose a risk to groundwater quality. The strategy shall set out how rainwater storage and re-use will be used to reduce consumption of imported water along with managing drainage and flood risks on the site. The strategy shall set out what information, design parameters and design details will need to be submitted at the Reserved Matters stage for each phase of the development. The strategy shall specify design and capacity thresholds for any parts of the site where development phases or parcels share drainage, rainwater harvesting or flood management infrastructure, and the strategies shall set out how cumulative capacity will be accounted for. The development shall subsequently be implemented in accordance with the approved strategy. Reason: To ensure a satisfactory whole life method of surface water drainage, water and flood risk management having regard to climate change; to prevent an increased risk of flooding on or off site; and to protect the quality and quantity of controlled waters from the development including release of potential pollutants associated with the current, previous and proposed land uses in accordance with the National Planning Policy Framework and Policies SS/6, CC/8 and CC/9 of the South Cambridgeshire Local Plan 2018. We have no further comments on draft conditions 49-52 other than some inclusion of references to rainwater capture and re-use alongside surface water management design at Reserved Matters stages and for these to be carried into maintenance plans. Environment Agency position: Foul Water, including new Water Recycling centre Having regard to the updated position statement and advice from Anglian Water, the Environment Agency is satisfied that suitable foul drainage arrangements can be put in place for the development, irrespective of whether the Milton treatment works is relocated or not. However the timing of a relocation may raise some capacity and timing issues that have the potential to impact significantly on the water environment from either storm spills or reduced treatment standards at receiving treatment works, if these are overwhelmed by demand. Our position of ‘no objection’ on water quality grounds is therefore subject to the following planning conditions being appended on any Environment Agency (Anglian Central Area) Sustainable Places Team Customer services line: 03708 506 506 Bromholme Lane, Brampton, Huntingdon, Cambridgeshire PE28 4NE Calls to 03 numbers cost the same as calls to standard Email: [email protected] geographic numbers (i.e. numbers beginning with 01 or 02). www.environment-agency.gov.uk Cont/d.. planning permission granted. We have added a need for Reserved Matters applications to include cumulative capacity figures for the site to enable the LPA to monitor capacity thresholds. Otherwise these conditions are unchanged: Condition: No development shall commence until a site wide strategy for Foul Water Drainage conveyance, treatment and discharge has been submitted to and approved