From: Cording, Carl
Sent: 06 November 2015 16:36
To: 'Nigel Gibbons'
Subject: FoDDC Allocations Plan
representations
Dear
Nigel,
I
apologise for the delay in responding. I wish to make the following comments
with regards to Flood Risk and the ADPD.
Flood Risk
I
had expected the Flood Keynote Document to be revised more comprehensively. The
document is not as robust or detailed as L2 SFRAs that ordinarily support DPD
documents. As an example I would signpost you to SFRA L2 work undertaken
in nearby LPAs:
SWDP- http://www.swdevelopmentplan.org/?page_id=86
SDC- http://www.stroud.gov.uk/info/plan_strat/Stroud_Level_2_SFRA.pdf
GCT JCS- http://www.gct-jcs.org/EvidenceBase/StrategicFloodRiskAssessment.aspx
The
revised document I note is dated April 2015 but supersedes my comments in
letter dated 20 May 2015. We have reviewed the sites and have the following
comments to make:
AP 17 Land At Stowfield- ADPD policy wording should advocate a
‘Sequential-Approach’ in that development should be located in areas at the
lowest risk of flooding. Opportunities should be explored to open up the
culverted ordinary watercourse to provide for flood risk and biodiversity
betterment. Until flood risk is more thoroughly assessed the quantum of
development cannot be determined. Individual proposals that come forward should
be subject to a detailed Flood Risk Assessment (FRA). This should be reflected
in the ADPD policy wording.
AP 38 and 39 Lydney Town Centre- It is not clear from
the interactive map the exact site boundary of this over-arching town centre
policy. We would again suggest a ‘Sequential-Approach’ is advocated in the
policy wording with regards location of development. ‘More-Vulnerable’ uses
should demonstrate that they can be safe for the lifetime of the development
and that this includes the ability to achieve safe access. Individual proposals
that come forward should be subject to a detailed Flood Risk Assessment (FRA).
This should be reflected in the ADPD policy wording.
AP 42 Lydney Harbour policy to support recreational uses- Keynote Document (KD)
does not acknowledge the risk of coastal flooding. This should be addressed as
should be the presence of the flood defences at Lydney Harbour. The exact
redevelopment/intensification of uses are at this time unclear.
Individual proposals that come forward should be subject to a detailed
Flood Risk Assessment. Policy wording should advocate a
‘Sequential-Approach’ in that development should be located in areas at the
lowest risk of flooding. More ‘vulnerable uses’ should be precluded at this location.
This should be reflected in the ADPD policy wording.
AP 43 Pine End Works and Land to the North- The KD does not
identify the presence of minor watercourses to the North of the site. These
features have not been modelled and as such the flood risk in this area is
unknown. The primary access to the site is restricted and at risk of flooding
which the KD does not identify. Whilst restricted access may be acceptable for
‘less-vulnerable’ types of uses we would resist ‘more-vulnerable’ uses such as residential
where safe access cannot be achieved. Individual proposals that come forward
should be subject to a detailed Flood Risk Assessment. Policy wording
should advocate a ‘Sequential-Approach’ in that development should be located
in areas at the lowest risk of flooding. Residential development should be
excluded from the policy unless safe access can be secured. This should be
reflected in the ADPD policy wording.
AP 49 Mead Lane Lydney- The site is at risk of fluvial flooding
and policy wording should advocate a ‘Sequential-Approach’ in that development
should be located in areas at the lowest risk of flooding. A number of
unmodelled watercourses transect that the site that will require further
assessment. Individual proposals that come forward should be subject to a
detailed Flood Risk Assessment. This will impact on types of uses and the
quantum of development. This should be reflected in the ADPD policy wording.
AP 50 Mead Lane- Individual proposals that come forward should be subject to a
detailed Flood Risk Assessment. Policy wording should advocate a
‘Sequential-Approach’ in that development should be located in areas at the
lowest risk of flooding. This should be reflected in the ADPD policy wording.
AP 51 Railway Station Area- Individual proposals that come forward
should be subject to a detailed Flood Risk Assessment. Policy wording
should advocate a ‘Sequential-Approach’ in that development should be located
in areas at the lowest risk of flooding. This should be reflected in the ADPD
policy wording.
AP 60 Tufthorn Avenue and Pingry Farm- Keynote Document (KD)
does not acknowledge the risk from unmodelled watercourse that bounds the site
to the NE. Individual proposals that come forward should be subject to a
detailed Flood Risk Assessment. Policy wording should advocate a
‘Sequential-Approach’ in that development should be located in areas at the
lowest risk of flooding.
AP 62 Land At Poolway Farm, Coleford- Keynote Document (KD)
does not acknowledge the risk from an unmodelled watercourse that dissects the
site. Individual proposals that come forward should be subject to a detailed
Flood Risk Assessment. Policy wording should advocate a
‘Sequential-Approach’ in that development should be located in areas at the lowest
risk of flooding. This should be reflected in the ADPD policy wording.
AP 65 Newent Town Centre- We would again suggest a
‘Sequential-Approach’ is advocated in the policy wording with regards location
of development. ‘More-Vulnerable’ uses should demonstrate that they can be safe
for the lifetime of the development and that this includes the ability to
achieve safe access. Individual proposals that come forward should be subject
to a detailed Flood Risk Assessment (FRA). This should be reflected in the ADPD
policy wording.
AP 66 Newent Town Centre Mixed Development Allocation- Individual proposals
that come forward should be subject to a detailed Flood Risk Assessment. This
will impact on types of uses and the quantum of development. We would again
suggest a ‘Sequential-Approach’ is advocated in the policy wording with regards
location of development. ‘More-Vulnerable’ uses should demonstrate that they
can be safe for the lifetime of the development and that this includes the
ability to achieve safe access. Individual proposals that come forward should
be subject to a detailed Flood Risk Assessment (FRA). This should be reflected
in the ADPD policy wording.
AP 68 Watery Lane, Newent allocation for 30 dwellings
1.1ha- Keynote
Document (KD) does not acknowledge the risk from an unmodelled watercourse to
the South of the site that then enters into culvert. Proposals that are brought
forward should be subject to a detailed Flood Risk Assessment. This will impact
on types of uses and the quantum of development. We would again suggest a
‘Sequential-Approach’ is advocated in the policy wording with regards location
of development. ‘More-Vulnerable’ uses should demonstrate that they can be safe
for the lifetime of the development and that this includes the ability to achieve
safe access. Individual proposals that come forward should be subject to a
detailed Flood Risk Assessment (FRA).
AP 72 Ross Road Newent mixed redevelopment allocation- The KD does not
acknowledge the risk from FZ2 that effects Bridge Street. Proposals that are
brought forward should be subject to a detailed Flood Risk Assessment. This
will impact on types of uses and the quantum of development. We would again
suggest a ‘Sequential-Approach’ is advocated in the policy wording with regards
location of development. ‘More-Vulnerable’ uses should demonstrate that they
can be safe for the lifetime of the development and that this includes the
ability to achieve safe access. Individual proposals that come forward should
be subject to a detailed Flood Risk Assessment (FRA). This should be reflected
in the ADPD policy wording.
AP 71 Gloucester Road Newent allocation- The KD does not
acknowledge the risk from unmodelled watercourse to the South of the site.
Proposals that are brought forward should be subject to a detailed Flood Risk
Assessment. This will impact on types of uses and the quantum of development.
We would again suggest a ‘Sequential-Approach’ is advocated in the policy
wording with regards location of development. ‘More-Vulnerable’ uses should demonstrate
that they can be safe for the lifetime of the development and that this
includes the ability to achieve safe access. Individual proposals that come
forward should be subject to a detailed Flood Risk Assessment (FRA). This
should be reflected in the ADPD policy wording.
AP 78 Drybrook Farm former farmyard- The KD does not
acknowledge the risk from unmodelled watercourses to the West of the site. We
are aware of historic flooding adjacent to site also that has not been
identified. Proposals that are brought forward should be subject to a detailed
Flood Risk Assessment. This will impact on types of uses and the quantum of
development. We would again suggest a ‘Sequential-Approach’ is advocated in the
policy wording with regards location of development. ‘More-Vulnerable’ uses
should demonstrate that they can be safe for the lifetime of the development
and that this includes the ability to achieve safe access. Individual proposals
that come forward should be subject to a detailed Flood Risk Assessment (FRA).
This should be reflected in the ADPD policy wording.
AP 77 High Street, Drybrook- I would reiterate those comments in my
letter dated May 2015.
AP 81 Longhope Industrial Estate- Proposals that are
brought forward should be subject to a detailed Flood Risk Assessment. This
will impact on types of uses and the quantum of development. We would again
suggest a ‘Sequential-Approach’ is advocated in the policy wording with regards
location of development. ‘More-Vulnerable’ uses should demonstrate that they
can be safe for the lifetime of the development and that this includes the
ability to achieve safe access. Individual proposals that come forward should
be subject to a detailed Flood Risk Assessment (FRA). This should be reflected
in the ADPD policy wording.
AP 90 Land North of Newnham on Severn and adjoining Unlawater
Lane- We
would reiterate those comments in my letter dated May 2015 with regards this
site. Despite our comments the KD fails to acknowledge the ordinary watercourse
transecting the site. Proposals that are brought forward should be subject to a
detailed Flood Risk Assessment. This will impact on types of uses and the
quantum of development. We would again suggest a ‘Sequential-Approach’ is
advocated in the policy wording with regards location of development.
‘More-Vulnerable’ uses should demonstrate that they can be safe for the
lifetime of the development and that this includes the ability to achieve safe
access. Individual proposals that come forward should be subject to a detailed
Flood Risk Assessment (FRA). This should be reflected in the ADPD policy
wording.
AP 98 Whitecroft Scovill employment site identified for mixed
housing and employment use (30 dwellings)- The KD does acknowledge the risk from the
unmodelled watercourse to the North of the site. Proposals that are brought
forward should be subject to a detailed Flood Risk Assessment. This will impact
on types of uses and the quantum of development. We would again suggest a
‘Sequential-Approach’ is advocated in the policy wording with regards location
of development. ‘More-Vulnerable’ uses should demonstrate that they can be safe
for the lifetime of the development and that this includes the ability to
achieve safe access. Individual proposals that come forward should be subject
to a detailed Flood Risk Assessment (FRA). This should be reflected in the ADPD
policy wording.
Limitations
Whilst
we accept that there are unlikely to be ‘showstoppers’ for any of the
allocations in the ADPD, it should be revised to highlight the flood risk
constraints identified. For those sites where flood risk is identified as a
constraint the document places emphasis on review and assessment at the
planning application stage. This 'back-loading' of evidence serves to bring
uncertainty into the ADPD. Where flood risks to a site are unknown this is
likely to impact on quantum of development at the application stage. This could
serve to reduce the flexibility and deliverability of the ADPD. The ADPD does
not specifically address the application of the Sequential Test either and
should be strengthened in this regard.
The
constraints, and indeed opportunities, should be clearly listed in the ‘Special
Requirement’ section in the policy wording (this should also be undertaken for
sites with foul drainage capacity issues that need to be phased, indeed, this
is a recommendation of the HRA). Furthermore, the number of houses attributed
to each allocation for those areas at risk of flooding needs to be flexible
with caveats. Until a more robust assessment of flood risk is undertaken the
exact quantum of development assigned to an allocation cannot be quantified.
The ADPD needs to factor in this uncertainty and make accommodations accordingly.
Climate Change
The
KD or ADPD does not address the issue of climate. This should be signposted in
the ADPD wording. Proposals should assess the risk to and from a site for the
lifetime of the development. We are expecting new climate change allowances to
be published this Autumn (2015). These are presently in draft but would update
the current NPPG referenced ‘Table 2’ September 2013 allowances (see link
below). The table below is for ‘peak river flows’ within the Severn River Basin
district, and for your information at this time in considering the impact upon
(and of) proposed development and mitigation/resilience measures. (‘Table 1’
Rates of Sea level rise are not changed).
|
Severn Peak River Flows: Total potential change anticipated |
2015-39 |
2040-2069 |
2070-2115 |
|
Upper end |
25% |
40% |
70% |
|
Higher central |
15% |
25% |
35% |
|
Central |
10% |
20% |
25% |
|
Current NPPG allowances September 2013 |
1990-2025 10% |
2025-2115 20% |
Source:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296964/LIT_8496_5306da.pdf
Surface Water
It
is not clear how the surface water risks to and from sites have been assessed
(and with what datasets). We would advise early liaison with the Lead Local
Flood Authority (LLFA) and your land drainage engineer for their appraisal of
the sites with regards surface water flood risk. This is not within our remit
and a role that the LLFA would lead on. Indeed, sites being brought forward may
interact with existing/planned surface water management plans in the
District/County. They will be able to advise further.
Summary
FoDDC
needs to be satisfied that once the above issues are addressed the resultant
plan will remain flexible and deliverable. I trust that the above is clear and
of use and provides you with a meaningful way forward to address those flood
risk issues identified to date. Please feel free to call should you wish to
discuss in further detail.
Best
regards,
Carl
Cording
Planning
Specialist
Sustainable
Places
Environment
Agency - Shropshire, Herefordshire, Worcestershire and Gloucestershire
( 722 4382 (Jabber - 51484) / 02030251484
8 [email protected]
/ Team email: [email protected]
* Riversmeet House,
Newtown Industrial Estate, Northway Lane, Tewkesbury, Gloucestershire, GL20 8JG
