From: Cording, Carl Sent: 06 March 2019 17:00 To: Tracey Smith Cc: John Rowley Subject: CBC LP EiP additional queries to EA Dear Tracey, We wish to respond to the queries in your emails of 1252hrs and 1254hrs on 1 March 2019. Email of 1252hrs on 1 March 2019 We note the comments made by Mr Gander. His concerns primarily relate to surface water flood risk which fall’s under Gloucestershire County Council’s remit; the Lead Local Flood Authority (LLFA). The L2 Strategic Flood Risk Assessment (L2 SFRA) considers the risk of flooding from surface water. For those sites where risks were identified, the SFRA recommends Drainage Impact Assessments will be required to demonstrate that the treatment and control of surface water can provide a level of betterment and recommends runoff rates for proposed development. For more detailed discussion with regards surface water flooding we would recommend liaison with the LLFA. With regards the matter of flood risk reduction/betterment, the overarching JCS policy base includes provision in policy INF2. Moreover, the NPPG supports opportunities are sought to provide net betterment. However, we would support the LP having more specific policy wording to this end. Paragraph: 010 Reference ID: 7-010-20140306 (Revision date: 06 03 2014) states that SFRAs should consider opportunities to reduce flood risk to existing communities and developments through better management of surface water, provision for conveyance and of storage for flood water. With regards Mr Gander’s last point concerning betterment: it is not possible to prescriptively define the level of betterment that should be delivered at this strategic level. The betterment that is deliverable will be very much dependant on detailed site analysis and this would be for site specific FRAs to determine and examine at a later stage. Email of 1254hrs on 1 March 2019 The policy wording recommended by Mr Mears would appear to align with the objectives of JCS policy INF2 and the guiding principles of the NPPF and NPPG. Indeed, we would expect the aims of the policy to be examined fully by any site specific FRA in accordance with policy INF2 and the NPPF/G. For more detailed discussion with regards surface water flooding we would recommend liaison with the LLFA. Best regards, Carl Cording Planning Specialist Sustainable Places Shropshire, Herefordshire, Worcestershire and Gloucestershire. Environment Agency- West Midlands Area IM Role- CIO/CIOC Lead ? Internal: 51484 - External: 02030251484 - Mobile:07775020020 ? carl.cording@environment-agency.gov.uk ? Riversmeet House, Newtown Industrial Estate, Northway Lane, Tewkesbury, Gloucestershire, GL20 8JG Information in this message may be confidential and may be legally privileged. If you have received this message by mistake, please notify the sender immediately, delete it and do not copy it to anyone else. We have checked this email and its attachments for viruses. But you should still check any attachment before opening it. We may have to make this message and any reply to it public if asked to under the Freedom of Information Act, Data Protection Act or for litigation. Email messages and attachments sent to or from any Environment Agency address may also be accessed by someone other than the sender or recipient, for business purposes. Click here to report this email as spam