The Environment Agency (EA) have objected to the KPI (now in the name of A2Dominion Developments Ltd) on the grounds that there is not an acceptable Flood Risk Assessment (FRA) for the site.
You can read the full objection by clicking on the link below:
EA obj KPI 4 Jan 2017
The main summarised reasons outlined in the EA objection letter are that the Flood Risk Assessment does not demonstrate that the development will be safe from flood risk for its lifetime, and the potential impacts of climate change have not been satisfactorily taken into consideration.
The Cranleigh Society has maintained serious concerns about the flood risk on this site, which is part of Cranleigh’s rapidly diminshing natural flood plain.
We are extremely glad that the EA have carried out a thorough study of the FRA and echoed many of the points that we raised in our letter against this application:
Although there is a presumption in favour of sustainable development however NPPF para 14 states that even if the development plan is absent, silent or relevant policies are out of date, permission should not be granted where specific Framework policies indicate it should be restricted, this includes flooding.
We also object on the grounds that the assessment of flood risk informing the measures proposed by the FRA to avoid, manage and mitigate flood risk, are incomplete and have not been appropriately secured for the lifetime of the development. There also does not appear to be provision for increased climate change allowances agreed by the Environment Agency and the Government, published in February 2016. These now require applicants and developers to assess a range of climate range allowances from 25% to 70% above the 1% AEP as part of planning applications. As the application appears to have been submitted to Waverley in November 2016 the new allowances and ranges should be used.
Document 9.0 WATER RESOURCES AND FLOOD RISK point 9.28 fails to mention the significant flooding on Alfold Road in 2013/14 or the flooding on Elmbridge Road. the Our own FRA review by RAB consultants (Bedford) acknowledges that the recent flooding of December 2013 on the Cranleigh Waters and Littlemead Brook has not been recognised within the flood risk assessment (FRA) dated October 2014. They go on to say that the extreme nature of the flood in December 2013 warrants recognition within the FRA and an assessment of flood depths and extents at the site if possible. Additionally, given the nature of flooding in December 2013 and the significant groundwater flooding experience across many parts of the Thames Catchment throughout winter 2014, it would be prudent to include this within the assessment of groundwater risk to the site.
Water Environment Ltd October 2016 appears to be missing Appendices B, C and D. Previously Appendix B of the FRA shows that EA “Product 4” flood data, received 29 July 2014, was used for the assessment. The EA have updated their flood modelling in the area since this data was obtained. The data used in the FRA has therefore been superseded. Without incorporating all this data we do not believe an appropriate nor up-to-date assessment of flood risk has been undertaken.
Furthermore, evidence exists and data has been collated of the recorded flooding in the vicinity of this development during 2013/14. This has been submitted in support of a planning application ref WA/2014/0912 by Berkeley Strategic Land Ltd in Appendix 1 from “Technical Review of Flood Risk Assessment (FRA) for the construction of 425 dwellings on land south of Cranleigh, Surrey” dated August 2014. The FRA should take this evidence into account.
Paragraph 040 of the Planning Practice Guidance (PPG) states: “To demonstrate to the satisfaction of the local planning authority that the development will be safe for its lifetime taking account of the vulnerability of its users, a site-specific flood risk assessment may need to show that appropriate evacuation and flood response procedures are in place to manage the residual risk associated with an extreme flood event. Proposals that are likely to increase the number of people living or working in areas of flood risk require particularly careful consideration, as they could increase the scale of any evacuation required. To mitigate this impact it is especially important to look at ways in which the development could help to reduce the overall consequences of flooding in the locality … through off-site works that benefit the area more generally.”
This proposal would significantly increase the number of people living in an area affected by very recent flooding and would increase the scale of any emergency evacuation considerably. The FRA has not considered how this additional burden will be managed in the extreme flood event and has not suggested any off-site mitigations to reduce the overall consequence of flooding in the locality. We therefore object on the grounds that the additional burden on the emergency services in a flood event has not been given due consideration in the FRA.
A further objection is that the FRA fails to prove that the voluntary and free movement of people during a ‘design flood’ can be demonstrated. Assessments of the adjacent Berkeley Homes WA/2014/0912 application site have shown that dry access/escape routes from the site across green fields are unsustainable in flood risk terms. The FRA addendum (9 June 2015) for this site previously proposed an approximate 5km pedestrian diversion along unlit and unmade footpaths and public highways without footpaths. This does not provide a safe nor appropriate route for people, especially for more vulnerable residents.
Evidence to support this is outlined in Appendix 1 of “Technical Review of Flood Risk Assessment (FRA) submitted by Berkeley Strategic Land Ltd WA/2014/0912 which demonstrates that every access route away from this adjacent development, using the Alfold Road, will be inaccessible by foot or car in a flood event like the one that occurred during 2013/14.
NPPF places significance with respect to land in the “Functional Floodplain” or Flood Zone 3b. Figure 4.3 of Volume 3: Mapping of the WBC SFRA identified areas of Functional Floodplain within the borough. This figure shows parts of the development site are likely to be within the Functional Floodplain.
The extent of the Functional Floodplain is normally defined by the extent of flooding in the undefended 1 in 20 year (5% annual probability) event and the EA flood data indicates that parts of the site lie within the 1 in 20 year (5% annual probability) flood extent. As the FRA has not delineated the extent of the Functional Floodplain at the site, we do not believe an appropriate nor up-to-date assessment of flood risk has been undertaken and object on these additional grounds.
The NPPF makes it very clear that the aim of the sequential test is to steer new development to areas with the lowest probability of flooding. The Sequential Test provided by the applicant does not provide satisfactory justification as to why other suitable sites have been discounted. We object on the grounds that the site fails the Sequential Test and the Exception Test cannot therefore be applied. There is a site a far less risk of flooding for 120 dwellings currently at Appeal, the result of which will be available on 9 January 2017. The council currently has a five-year housing supply and does not require housing on green fields at risk of flooding, on a flood plain, which will increase flooding elsewhere.
We also have concerns about the ability of new residents moving into the site to obtain meaningful flood risk insurance at an acceptable cost since the Association of British Insurers has stated that New Houses built after 1 January 2009 will not be covered by Flood Re; this is to avoid incentivising unwise building in flood risk areas.
The assessment of flood risk needs to demonstrate that the flood risks posed by the development can be managed, ae realistic, taking into account current climate change allowances, and are safe, the FRA fails to do this.”