Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9053

Received: 05/09/2025

Respondent: Environment Agency

I&O_9546
We welcome the inclusion of a Strategic Flood Risk Assessment (in preparation) as supporting evidence for the Local Plan and will continue to engage with the Council throughout the preparation of this.

Comment

Representation ID: 9054

Received: 05/09/2025

Respondent: Environment Agency

I&O_9547
We welcome the inclusion of tackling climate change to the vision for Cheshire West and Chester, including the mitigation against effects and net increase in biodiversity.

Comment

Representation ID: 9055

Received: 05/09/2025

Respondent: Environment Agency

I&O_9548
Whilst we have no specific view on which option is the most appropriate approach for the new local plan, we take this opportunity to highlight opportunity for objectives 10 and 11 in option B to go further. The objectives to “Minimise the risk of flooding from all sources” and “… minimise the risk of pollution and improve water efficiency” are welcomed, however, we would encourage the Council to consider the objectives go further to reduce the risk of flooding and pollution.

Comment

Representation ID: 9056

Received: 05/09/2025

Respondent: Environment Agency

I&O_9549
Whilst we have no specific view on the spatial strategy approach, we would highlight the importance of considering wider environmental issues when deciding upon land allocations. Blue and green infrastructure must be considered and protected; opportunities to enhance these features should be explored.   Whilst we have no specific view on the options for where development could be located, in identifying potential land for development and the creation of policy relating to the release of land from the Green Belt for development, as outlined in Planning Practice Guidance flood risk must be considered with the sequential approach being applied during the plan-making process to help ensure that development is steered to the lowest risk areas, where it is compatible with sustainable development objectives to do so.

Comment

Representation ID: 9057

Received: 05/09/2025

Respondent: Environment Agency

I&O_9550
We welcome the strengthening of policy STRAT 11 to include greater environmental protection and climate resilience including water and sewerage infrastructure and flood defenses.    There are locations (for example, upstream of the Great Sutton Flood risk area) where (should development come forward) we would like development to not only offset its own increase in runoff flood risk but also add more attenuation to mitigate known risks downstream. We would welcome the consideration and inclusion of such requirement in forthcoming policy.

Comment

Representation ID: 9058

Received: 05/09/2025

Respondent: Environment Agency

I&O_9551
Our remit in relation to land contamination extends only to controlled waters, considerations relating to human health fall within the remit of the Council’s Environmental Health Officer. We advise the council that in the development of any site that appears to have been the subject of past industrial activity which may pose a risk of pollution to controlled waters, we recommend developers should: Follow the risk management framework provided in Land Contamination: Risk Management, when dealing with land affected by contamination   Refer to our Guiding principles for land contamination for the type of information that we require in order to assess risks to controlled waters from the site - the local authority can advise on risk to other receptors, such as human health Consider using the National Quality Mark Scheme for Land Contamination Management which involves the use of competent persons to ensure that land contamination risks are appropriately managed Refer to the contaminated land pages on gov.uk for more information Refer to ‘The Environment Agency’s approach to groundwater protection’

Comment

Representation ID: 9059

Received: 05/09/2025

Respondent: Environment Agency

Map 5.5 EP04
I&O_9552
We have concerns over site EP04 shown on map 5.5 (Ellesmere Port Growth Option) as part of option A for growth, part of the Spatial Strategy. This site is within Ince Marsh (an area of flood zone 3b) and is designated a potential growth area. The flood risk for this location is governed by the operation of the culvert under the Manchester Ship Canal. If flooding was to occur it could occur in this 3b area. If this land was developed, the level adjacent could be considerably worse, posing risk to the nearby commercial land use.  

Comment

Representation ID: 9060

Received: 05/09/2025

Respondent: Environment Agency

I&O_9553
We agree with the suggested policy approach towards flood risk. We are satisfied that there will be the ‘ requirement for watercourses and riverside habitats to be conserved and enhanced, where necessary through management and mitigation measures. ’ However, under the statutory requirements of the Biodiversity Net Gain watercourse module and Water Framework Directive objectives, we would expect to see river restoration specifically referenced in this policy and a commitment to improve riverine habitats not only through ‘management and mitigation’ but through actual net gain. The suggested approach sets out adequate protections for surface water. It should be noted that pollution during construction is a concern for water quality, both from solids run off and from sewage infrastructure prior to adoption by the water company. Therefore, we would expect forthcoming policy to reference surface water pollution prevention during construction.

Comment

Representation ID: 9061

Received: 05/09/2025

Respondent: Environment Agency

I&O_9554
Where appropriate, we encourage the implementation of nature-based solutions, recognising their multiple co-benefits across environmental, social, and economic domains. Nature-based solutions can increase resilience to flooding whilst offering opportunities for increased biodiversity and water quality. SuDs which can act as mitigation to pollution from all sources can be beneficial in reducing the risk of environmental pollution.

Comment

Representation ID: 9062

Received: 05/09/2025

Respondent: Environment Agency

I&O_9555
Yes, we would agree with and support this policy suggestion. We would ask the council to clarify the criteria for designation, are our existing flood storage assets in Cheshire West and Chester designated in this way?