Representation by Environment Agency (Environment Agency )
- Date submitted
- 11 January 2019
- Submitted by
- Non-statutory organisations
We are submitting more detailed representations (Via email: Our ref A303Stonehenge_RReps_11.01.19) to assist your understanding of the outstanding information requirements and issues of concern that we wish to be addressed by Highways England (the applicant).
Our detailed relevant representation outlines where further work, clarification or mitigation is required to ensure that the proposal has no detrimental impact on the environment. In summary these areas cover the following topics:
Groundwater Protection and Land Contamination (Baseline Groundwater modelling*, drainage, construction impacts, site investigation, etc.)
Flood Risk Management (Baseline modelling/Flood Risk Assessment*, floodplain compensation)
Fisheries and Biodiversity (Environmental Enhancements, Protected species, Invasive species)
Protective Provisions (Environment Agency Protective Provisions / disapplication of permissions)
Each section highlight concerns which we believe need to be addressed prior to a development consent order being granted. In some instances, it may be acceptable for additional information to be provided later, by requirement.
*Groundwater and Flood Risk Modelling - To date there is still outstanding work on these matters being undertaken on behalf of the applicant It is imperative that these are finalised prior to the examination, as they underpin the Technical Reports submitted to support this application. Please note that at the point of submission of the relevant representations we do not have any agreed deadlines for the submission of this work outstanding work to support the DCO submission. Our current estimate is that it may be, due to the amount of outstanding work on the flood model, a minimum of 4 weeks from when the works commence for the information to be made available for us. We would highlight that due to the technical nature of reviewing this baseline modelling that it is likely to take several weeks for us to review.
It is our opinion that the submission of evidence in relation to Groundwater Modelling and Flood Risk Modelling / Assessment must be required prior to the Examination for any Development Consent Order (DCO). As the evidence in the baseline has implications for the position in the Technical Reports, and therefore the positions in the Environmental Statement that support this submission. Our position on this matter that they should be resolved prior to examination would be supported by National Policy Statement for National Networks, section 5.96 which confirms the preference for these technical matter should be agreed prior to submission.