Regarding “The plan will set out the approach to runoff rates, including that peak runoff rate should be no greater for the developed site than it was for the undeveloped site.” Whilst we support this, there may be cases where flooding is already a problem and the development provides an opportunity to reduce flood risk, in such cases we would hope that there would be a policy requirement to reduce runoff rates from pre-development levels. For example, a development in the upper water catchment that is subject to flash flooding.

Policy should recognise the value of SuDS for the provision of natural green space and biodiversity and encourage above ground SuDS for this reason. We have seen a number of development proposals where SuDS have been located surrounded by roads, this is problematic because it encourages semi-aquatic wildlife to cross the roads and risk being crushed (eg spawning amphibians) and it fails to recognise ecological principles of connecting habitat (not isolating it with roads). We would welcome wording in the draft Plan that discourages this type of design.

Policy needs to meet requirements of Environment Agency, Lead Local Flood Authority and water companies