Medway Developer Contributions and Obligations Guide

Comment: The Environment Agency has their own charged advice service which should be utilised when developers are submitting a planning application. This is of particular importance for those sites that are located within flood zone 3b. Proposed additional sentence below:

‘Where sites are being developed which are at risk of flooding, engagement with all relevant authorities should be sort prior to any formal planning application being submitted.’

Comment: At present, the Environment Agency has only reviewed a draft of the Level 1 and 2 SFRA, as part of the Local Plan Regulation 19 consultation. The SFRA’s currently does not clearly demonstrate how high and medium flood risk site allocations have been justified by applying the Sequential Test, and where appropriate, the Exception Test. There remain some site allocations located in areas at high risk of flooding (either existing or in the future) which are inappropriate and go against both national planning policy and guidance.

Currently the Environment Agency has not reviewed the final draft of the flood defence infrastructure report. Additionally, there may be a requirement to provide further guidance outside of the flood defence report to assist in supporting planned development. Proposed wording changes are below:

‘The Environment Agency are working with the Council to produce further details which will include, but are not limited to, a flood defence infrastructure report. These details will help support planned development.’

Comment: The MEASS adopted date is incorrect and should be amended to 2019.

Comment: FRA’s should take into account national policies as well as local policies. We would propose specific reference to national policies is also included.

Further context and information may be required to determine the risk of flooding at a site. As such consideration should be included which allows for additional information to be provided when determining flood risk. This may include flood modelling, additional drawings and calculations.

Comment: We are committed to working with Medway Council to bring forward sustainable development in the area. We look forward to future engagement with Medway Council.