Development Management Development Plan (DPD)

Comment

Representation ID: 928

Received: 19/10/2010

Respondent: Environment Agency

Issue DM1: Question 5
We note that flood risk is not included in the list provided under part 1. Flood risk is addressed in SO15 and policies KP1 and KP2 of the adopted Core Strategy. If you feel there is any way that you can add to these requirements through the Development Management DPD, we would request its inclusion. It is possible that flood risk and making space for water could be covered under "(vii) Natural environment and trees"

Comment

Representation ID: 929

Received: 19/10/2010

Respondent: Environment Agency

Issue DM3: Question 15
There could be an increase in flood risk if intensification of existing residential sites and areas in flood zones is considered. It could also place further burden on the emergency services by placing more people at risk. We therefore feel that flood risk should be considered in the list under part 1 of the suggested option.

Support

Representation ID: 930

Received: 19/10/2010

Respondent: Environment Agency

Issue DM4: Question 16
We are in general agreement with the approach set out in the suggested option. We welcome the requirement for a minimum Code Level 4 rating, but this could also go further to require increasing ratings in line with the Government aspiration for zero carbon development by 2016. We are pleased to see a BREEAM rating of 'Excellent' for non-residential development.
We welcome all of the measures set out in parts 1-7. We are particularly interested in the water efficiency requirements and reference to your Water Cycle Study should be made and might allow more detailed requirements to be set. We would also recommend that you refer to our Thames Gateway Environmental Standards for further advice on other issues.

Support

Representation ID: 931

Received: 19/10/2010

Respondent: Environment Agency

Issue DM4: Question 18
We support the council in taking positive action ahead of Government changes. The Thames Gateway is an Eco Region and should lead the way in resource efficiency and climate change mitigation.

Support

Representation ID: 932

Received: 19/10/2010

Respondent: Environment Agency

Issue DM4: Question 19
We would support you should you wish to seek zero carbon development ahead of Government changes to the Building Regulations in 2016.

Comment

Representation ID: 933

Received: 19/10/2010

Respondent: Environment Agency

Issue DM4: Question 21
Development should use the lowest carbon energy production technologies and reduce inefficiencies in the energy supply to minimise carbon dioxide emissions. Decentralised energy networks could provide the lowest carbon solution. Supply infrastructure and buildings should be adaptable to future innovative technologies.

Low carbon producing technologies

Assess the development to examine whether community scale systems for energy, heating and cooling would be more efficient than relying on centralised supply or micro-generation.

Efficient Energy Production and Supply

Community energy systems for heating and cooling allow primary energy resources to be processed, distributed and used more efficiently than generation at either a centralised or micro scale. However, it is possible that power may be most efficiently produced from a centralised location. Waste that cannot be recycled or reused should be used for energy recovery. An assessment should be made at a strategic scale as to whether there are sufficient quantities of non-recyclable waste to support energy from waste facilities. Industrial symbiosis should be encouraged between neighbouring developments to improve resource efficiency. This symbiosis is the trade of materials, energy, heat, water and other by-products.

Please see recommendation ERE3 on Page 23 of our Thames Gateway Environmental Standards for more info.

Comment

Representation ID: 934

Received: 19/10/2010

Respondent: Environment Agency

Issue DM4: Question 22

The Water Cycle Study might highlight areas where increased water efficiency is required, which in turn will reduce carbon dioxide emissions. Water efficiency measures add a minimal cost to development but can achieve significant results. In addition, all developments should aspire to incorporate community water harvesting and reuse systems, which are needed to achieve water use of less than 95l/head/day.

We would also recommend retrofitting strategy. Existing development could be retrofitted with resource efficiency measures to decrease carbon dioxide emissions and mitigate climate change. Implementing measures to reduce water use and improve waste recycling will also help to use resources more efficiently and reduce carbon dioxide emissions. A strategy should be produced and implemented which identifies:

* the means of reducing carbon dioxide emissions from direct and indirect sources;
* the funding for retrofitting resource efficiency measures;
* who should benefit; and
* how the contributions should be administered and measures implemented.

Support

Representation ID: 935

Received: 19/10/2010

Respondent: Environment Agency

Issue DM7: Question 29
We are in general agreement with the approach set out in this suggested option. It should be noted that, under part 1, sustaining the current level of flood risk into the future does not necessarily mean that defences will be (or are able to be) raised. Effective floodplain management is therefore likely to play a major role into the future - this includes effective development control, for example applying the principles of PPS25 including the Sequential Test and the Exception Test, and also effective emergency planning.

Comment

Representation ID: 936

Received: 19/10/2010

Respondent: Environment Agency

Issue DM7: Question 31
New development can provide opportunities for the incorporation of innovative flood defences into the design of the development. This would not only afford protection to the development, but could also make better use of the riverfront areas. The TE2100 Plan provides a vision for this area where improvements to the flood risk management system provide amenity, recreation and environmental enhancement. This could also positively contribute to the Thames Gateway Parklands vision.

Comment

Representation ID: 937

Received: 19/10/2010

Respondent: Environment Agency

Issue DM7: Question 32
You need to consider all risks of flooding which are identified in your updated SFRA, Water Cycle Study and in the future by your Surface Water Management Plan. These background studies form a key part of your evidence base and must support the formulation of policies within this document and in your Core Strategy review.
This whole section should be updated in light of the (soon to be) completed SFRA and the TE2100 Plan.