Comment

Representation ID: 2158

Received: 14/07/2021

Respondent: Norfolk County Council - LLFA

The Policy SNVC1 - Standard Requirements confirms the need to acknowledge the existing and typical requirements for developments, however at present the current policy is limited in its provision and even indicates that specifics requirements are potentially optional. With this in mind, we question whether appropriate consideration to supporting policies (such as Flood Risk and Water Management policies) have been given due consideration and representation by the proposed VCHAP.
The Greater Norwich Strategic Flood Risk Assessment Level 2 has not considered the effects of the VCHAP sites within the assessment or it’s Cumulative Impact Assessment relating to flood risk. As the VCHAP considers the allocation of approximately 1200 homes, an appropriate level of consideration to the strategic flood risk would be reasonable to be consider both within the plan and its supporting evidence base. At present this consideration has not been observed.

Given the recent flooding events in South Norfolk during August 2020 and Christmas 2020, better consideration of flood risk and its management should be included in the housing allocation process and the supporting documentation (such as the Level 2 GNSFRA) should be adjusted to reflect the proposed VCHAP.
The LLFA would request that the VCHAP policies requires that any future development (or re-development) proposals show there is no increased risk of flooding from an existing flood source and mitigation measures are implemented to address surface water arising within the development site.