30 August 2014
Friends of the Earth have been concerned over the application by Berkeley’s Strategic to build 425 homes on an area prone to flooding in the centre of Cranleigh. (WA/2014/0912) Our concern is so strong that we commissioned an independent flood consultant Wallingford Hydro Solutions to examine the developer’s own Flood Risk Assessment which downplays the risk from flooding on the site. The report can be downloaded here: Berkeley Homes Cranleigh – FRA review
Guildford Woking and Waverley Friends of the Earth has now lodged a letter of objection to this development with Waverley Council: Letter of Objection
We are also concerned that future residents may not be able to get insurance if the sites ever experiences any flooding. Indeed the Government’s new flood insurance scheme for householders specifically excludes houses built after 2009. Post 2009 homes are NOT covered “to avoid incentivising unwise building in flood risk areas.”
In our letter we say we object to this outline application on 10 grounds which are detailed in the attached Wallingford Hydro report and summarised below:-
“Ground 1 – Failure to include relevant recent flood risk data in Applicant’s Flood Risk Assessment relating to flooding in the December 2013 to February 2014 period.
The Applicant’s Flood Risk Assessment report was written around two months after this flooding occurred so it is reasonable to expect to see it referred to and included in the Applicant’s Flood Risk Assessment but the FRA omits any reference to these events.
Without incorporating all this data Wallingford Hydro (quite understandably) does not believe an appropriate assessment of flood risk has been undertaken in the Applicant’s Flood Risk Assessment.
Ground 2 – Failure to carry out appropriate consultation with the relevant authorities to enable and an informed assessment of flood risk based on the historic flood risk data.
Section 2.9 of the Applicant’s Flood Risk Assessment details the historic flooding record used to inform the assessment. This data has been obtained via consultation with various flood risk management bodies as listed in table 2.2 of the Applicant’s Flood Risk Assessment. Wallingford Hydro’s assessment is that this consultation has not been undertaken appropriately and that the responses to the consultation indicate a lack of formally recorded data rather than a lack of flood risk at the site. Full details of this ground of objection are given in the attached report.
Ground 3 Omission of local data contrary to requirement of National Planning Policy Framework
In the view of Wallingford Hydro, the omission of local data from the Applicant’s Flood Risk Assessment does not adequately inform Waverley Borough Council or any of their consultees and enable them to give appropriate consideration to local flood risks as required by the National Planning Policy Framework.
Ground 4 – Failure to consult Lead Local Flood Authority
The historic data for this site suggests that local flood risk are likely to significantly affect the development and therefore the lead local flood authority (Surrey County Council) should be an important consultee to inform and assist the Applicant’s Flood Risk Assessment. There is no evidence on the public record of this consultation being completed by either the developer or Waverley Borough Council
Ground 5 – Measures proposed by the Flood Risk Assessment to avoid, manage and mitigate flood risk have not been appropriately assessed and secured for the lifetime of the development.
The Applicant’s Flood Risk Assessment (Paragraph 4.1.8) argues that a garden and car park walls to the rear of High Street, St James’ Place and Cranleigh Methodist Church prevent flood water from accessing the overland flow route from Cranleigh High Street to the Littlemead Brook and therefore (according to the Applicant) water does not reach the site in all flood scenarios up to and including the 1 in 1000 year (extreme) event. The Flood Risk Assessment modelling demonstrates the dependency on these wall structures to prevent water ingress on site but does not provide the details required by Paragraph 038 of PPG relating to these structures or explain how they will be maintained and secured for the lifetime of the development.
Objections relating to access and egress from the site.
Every access route away from the development will be inaccessible by foot or car in a flood event similar to the one that occurred earlier this year (2014). Even if the properties themselves are lucky enough to escape flooding, people would be isolated for a number of hours/days whilst the surrounding flood waters recede. Futhermore the proposal is for 425 dwellings of predominately family- sized homes. This could equate to additional 1500+ people living in an area at risk of flooding, increasing the scale of any evacuation considerably.
On access and egress matters, paragraph 058 of the PPG states “Local planning authorities are advised to consult with their emergency planning officers as early as possible during the preparation of Local Plans, and also regarding any planning applications which have implications for emergency planning.
We therefore have a number of grounds of objections relating to access and egress problems which the Applicant’s Flood Risk Assessment fails to address.
Ground 6 – failure to demonstrate voluntary and free movement of people during a ‘design flood’.
Ground 7 – failure to demonstrate vehicular access to allow the emergency services to reach safely the development during design flood conditions.
Ground 8 – failure to demonstrate safe access routes during design flood conditions.
Ground 9 – failure to give due consideration to the additional burden on the emergency services in a flood event.
Ground 10 – lack of evidence of consultation with either the Emergency Planning departments, Emergency Services or Local Resilience Forum as recommended in NPPF.
These are clearly serious failures and omissions in respect of a site which is in an area of high flood risk and which includes areas in Flood Zones 2 and 3.
We wish to draw the attention of Councillors to Paragraph 101 of the NPPF which states that “the aim of the Sequential Test is to steer development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding”.
In the final analysis, by means of this highly flawed and inadequate report, the Applicant appears to be trying to persuade the authorities that a development site in an area
- prone to flooding
- which has recently flooded
- which has been made inaccessible during that recently flooding
- on a site which contains areas classified by the Environment Agency as within Flood Risk Zones 2 and 3
is in fact at no risk from flooding.
Clearly on the basis of the ‘evidence’ produced by the Applicant no such conclusion can be drawn safely by Waverley Council as the local planning authority. Nor can Councillors be satisfied that the “proposed development would be safe and that it would not lead to increased flood risk elsewhere” as required by the National Planning Policy Guidance.
Accordingly this outline application should be refused.”