Initial Consultation document

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Comment

Initial Consultation document

Question 5: Policy MW2 'Development Management Criteria'

Representation ID: 91938

Received: 30/07/2018

Respondent: Lead Local Flood Authority (Norfolk County Council)

Representation Summary:

Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
Thank you for your consultation on the above site, received on 28 June 2018.
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.
Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.

It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.
With regard to specific sites put forward we have the following comments:
MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.
MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems
SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

Comment

Initial Consultation document

Question 7: Policy MW4 'Climate change mitigation and adaption'

Representation ID: 91939

Received: 30/07/2018

Respondent: Lead Local Flood Authority (Norfolk County Council)

Representation Summary:

Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.
It is accepted that Mineral working is a water compatible development which can be undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
Thank you for your consultation on the above site, received on 28 June 2018.
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.
Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.

It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.
With regard to specific sites put forward we have the following comments:
MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.
MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems
SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

Comment

Initial Consultation document

Question 40: Proposed site MIN 12

Representation ID: 91940

Received: 30/07/2018

Respondent: Lead Local Flood Authority (Norfolk County Council)

Representation Summary:

MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site is at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
Thank you for your consultation on the above site, received on 28 June 2018.
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.
Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.

It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.
With regard to specific sites put forward we have the following comments:
MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.
MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems
SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

Comment

Initial Consultation document

Question 74: Proposed site SIL 02 (land at Shouldham and Marham)

Representation ID: 91941

Received: 30/07/2018

Respondent: Lead Local Flood Authority (Norfolk County Council)

Representation Summary:

SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
Thank you for your consultation on the above site, received on 28 June 2018.
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.
Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.

It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.
With regard to specific sites put forward we have the following comments:
MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.
MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems
SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

Comment

Initial Consultation document

Question 52: Proposed site MIN 37

Representation ID: 91942

Received: 30/07/2018

Respondent: Lead Local Flood Authority (Norfolk County Council)

Representation Summary:

MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems

Full text:

Norfolk Minerals and Waste Local Plan Review: Initial Consultation
Thank you for your consultation on the above site, received on 28 June 2018.
We welcome the inclusion of an assessment of flooding from all sources within the Plan.
We would like to provide information which you may wish to consider in relation to Policy MW2 and MW4.
Policy MW2: We suggest that the wording of point d) is changed to include groundwater flooding. Mineral working can change local drainage networks, including groundwater flow (though creation of a void or dewatering) and so there should be no adverse impact on this source of flooding also.
We note that the intention is that flood risk is not increased elsewhere by development through the provision of appropriate surface water management such as sustainable drainage (SuDS). We support this approach but highlight to all potential development that working of minerals may remove infiltration media (as part of the operation). Hence any drainage scheme may rely on connection to a watercourse which is not always apparent near to the scheme. We would also request that during the works and following reinstatement a drainage strategy is put forward that considers the changes to local drainage network e.g. interception of watercourses or drainage connections. Any current drainage arrangements should be maintained or diverted appropriately. Reinstatement of land can replace permeable material with less permeable, this along with the post development ground levels must not increase the risk of flooding elsewhere.
Policy MW4: We welcome that that this policy supports policy MW2 with the provision of flood risk assessments (FRA) and although not specifically stated we assume that this policy's intention is that any FRA will include appropriate consideration of the most up to date climate change allowances.

It is accepted that Mineral working is a water compatible development which can be
undertaken in most areas at risk of flooding, however, we would highlight that any impacts should be considered during a planning application and appropriate measures. These measures may not be required until reinstatement when post development ground levels are considered in detail.
With regard to specific sites put forward we have the following comments:
MIN12 - Beetley - We would like to highlight that we are aware of reports of external flooding (2017) in the village on Fakenham Road. As the site at the top of two catchments, half of the proposed site drains towards the village and half away. Any proposal would need to consider this during its design.
MIN 37 - Buxton - We would like to highlight that we are aware of reports of flooding internally and externally adjacent the site boundary (2015 and 2016). Any proposal would need to consider these local flooding issues and if assess potential opportunities to improve existing flooding problems
SIL02 - Marham - We would like to highlight that we are aware of reports of flooding internally (2016) on The Street, Marham. Although the proposal is downgradient of this location any proposal would need to consider this during its design.

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