17 October 2014
Following our objection with supporting report prepared by Wallingford Hydro (see previous post) the Environment Agency changed its position and lodged an objection with the Council against the Berkeleys Strategic application for the site on the grounds that safe access could not be guaranteed and the EA also expressed concern about the absence of a district wide “sequential test“.
As we expected, Berkeleys sought to refute the EA’s objections and provided large quantities of further evidence seeking to explain that it can show safe access. We have been back to talk to Wallingford Hydro and our Further Letter of Objection and Wallingford Hydro’s Report on Access (which shows the Berkeleys site does still not provide safe access) are now registered against the Berkeley’s application on the Waverley Borough Council website.
The sequential test is an exercise which consists of a developer comparing sites on the basis of relative flood risk and ranking them for flood risk. Generally the assumption is that sites should be compared across a district. Waverley Borough Council can determine how the sequential test is conducted but Berkeleys has to do the work. Our letter is quite technical but it is challenging the approach WBC has taken to the sequential test. For reasons which are currently unclear, Waverley officers have ignored the Environment Agency standing guidance on sequential tests and have just asked Berkeleys to assess other sites for flood risk in and immediately around the Cranleigh area and not across Waverley as a whole. According to the Environment Agency and Wallingford Hydro, the normal procedure would be to assess available sites across the district as a whole.
As a result of this approach WBC officers have made it considerably easier for Berkeleys to claim the site passes the sequential test. We are convinced this approach is wrong and we can see no policy justification for it.
There are even mistakes in the Berkeleys analysis of the Cranleigh sites. In particular they appear to totally discount the Hewitts site altogether although it is within the settlement boundary and on flood zone one so applying the sequential test correctly this site should be near the top of the list. According to Berkeleys evidence this site won’t be available for five years and they ignore it. However from additional information posted today (17 October) on the website page for this application we know that Berkeleys were told in a meeting with Waverley in July this year that WBC officers “believed that the Hewitts Industrial Estate application is expected imminently”.
In an era of increased extreme weather events and climate change putting new development in areas of higher flood risk has been deemed contrary to government policy – hence the sensible policy preference for building in areas of lower flood risk.
One reason for the policy and the sequential test is that newly built homes (post 2009) are excluded from the government’s Flood Re scheme which is the new agreement between the government and the insurance industry which ensures that most domestic properties can continue to get insurance against flooding. If Waverley grants permission to Berkeleys, Waverley could find itself with yet more people living in homes at risk of flooding as happened over last winter in Godalming. If these new houses do flood then householders won’t be within Flood Re and could have insurance removed i.e. they would be left without the ability to protect themselves financially by carrying flood risk insurance. That in turn can put householders at risk of breaching mortgage conditions and potentially facing financial ruin.