Wychavon District Council
Development Control
Civic Centre Queen Elizabeth Drive
Pershore
Worcestershire
WR10 1PT
Our ref:
Your ref:
SV/2014/108165/01-L01
W/14/01463/PN
Date:
17 December 2014
F.A.O: Ms. Heather Pearson
Dear Madam
PROPOSED DEMOLITION OF EXISTING OFFICES, CONSTRUCTION OF NEW
OFFICE BUILDING TOGETHER WITH NEW WAREHOUSING AND CHARGER BAY,
AND RELOCATION OF CABIN AT SPIERS AND HARTWELL, BLACKMINSTER
BUSINESS PARK, BLACKMINSTER, OFFENHAM, EVESHAM, WR11 7TD
Thank you for referring the above application, which was received on 21 November
2014. We have the following comments to assist your determination of the planning
application:
Contaminated Land
The site is underlain mostly by bedrock of the Wilmcote Limestone Member (mudstone
and limestone), with the eastern end underlain by the Blue Lias Formation and
Charmouth Mudstone Formation (undifferentiated, mudstone). The far south-east
corner of the site has some Alluvium (clay, silt, sand & gravel) overlying the bedrock,
associated with the Littleton Brook to the east. All the underlying geological formations
are designated as Secondary aquifers.
There are a number of abstractions from surface water for spray irrigation in the locality;
the closest being 170m to the north and 500m to the south on the Littleton Brook.
The documents submitted do not include a desk study, only the architects’ Design &
Access Statement. It appears that the site is only being partly redeveloped in order to
provide new offices, an extension to the warehouses, and a new roadway along the
south of the site, with additional parking spaces to the rear and demolition of existing
buildings. It is therefore appreciated that not all of the site will be excavated. However,
the site clearly has a history of potentially contaminative use as a haulage yard with
lorry storage, fuel storage and refrigerated storage on site.
In line with the National Planning Policy Framework (NPPF) “the planning system
should contribute to and enhance the natural and local environment by: ... preventing
both new and existing development from contributing to or being put at unacceptable
Environment Agency
Hafren House Welshpool Road, Shelton, Shrewsbury, SY3 8BB.
Customer services line: 03708 506 506
www.gov.uk/environment-agency
Cont/d..
risk from, or being adversely affected by unacceptable levels of soil, air,
water...pollution...”. (Paragraph 109)
The ‘Land affected by contamination’ section of the National Planning Practice
Guidance (NPPG) states that “if there is a reason to believe contamination could be an
issue, developers should provide proportionate but sufficient site investigation
information (a risk assessment) to determine the existence or otherwise of
contamination, its nature and extent, the risks it may pose and to whom/what (the
‘receptors’) so that these risks can be assessed and satisfactorily reduced to an
acceptable level... At this stage, an applicant may be required to provide at least the
report of a desk study and site walk-over. This may be sufficient to develop a
conceptual model of the source of contamination, the pathways by which it might reach
vulnerable receptors and options to show how the identified pollutant linkages can be
broken.” (Paragraph: 007 Reference ID: 33-007-20140612)
Currently, no information has been submitted relating to contamination risks to
controlled waters. In the first instance a desk study and preliminary risk assessment
should be submitted as part of the application. In the absence of this information the
proposed development may be considered contrary to the NPPF and could be refused
on this basis.
Flood Risk
The site is located partly within Flood Zone 3 (‘high probability’) and Zone 2 (‘medium
probability’) of the Littleton Brook, based on our ‘indicative’ Flood Map for Planning
(Rivers and Sea). The Littleton Brook is classed as ‘Main River’ in this location. We
have no modelled flood level data available for the Littleton Brook in this location.
The proposed development is for the demolition of existing offices and the construction
of new office and warehousing, classified as a ‘less vulnerable’ use in Table 2 in the
‘Flood risk’ section of the NPPG, and is an extension to the existing use on site.
Development within Flood Zone 3 and 2 should be accompanied by a Flood Risk
Assessment (FRA) that is appropriate to the scale and nature of the proposed
development, in line with the NPPF.
FRA:
The applicant has submitted a FRA undertaken by Three Counties Flood Risk
Assessment (dated 3 November 2014). The FRA is limited in content and does not
provide an appropriate assessment of flood risk to inform the proposed development.
In noting that our Flood Map is indicative in this location the FRA states that the site has
not flooded historically. However, the FRA provides no assessment of the floodplain
extents or any indication of what is considered to be the 1 in 100 year flood level with
allowance for climate change, to inform the siting and design of the proposed
development. In the absence of modelled flood level data, the FRA should provide an
appropriate assessment of the flood extents to demonstrate that the proposed
development would be safe and not increase flood risk elsewhere (where possible flood
risk betterment should be provided).
The FRA makes reference to the topography of the site as being to Ordnance Datum;
however this is incorrect as a temporary benchmark of 100m has been used. The
surveyed data provided is limited and does not relate to ground levels adjacent to the
watercourse or elsewhere in the floodplain.
Cont/d..
2
The FRA states that flood storage compensation is not a requirement because there are
no modelled flood levels available. This statement is incorrect; flood storage
compensation requirements should be informed by an assessment of the 100 year plus
climate change flood extent.
Notwithstanding the above, a review of our historic flood outlines and LiDAR topography
for this location shows that the proposed development is located outside of the historic
flood extent. Our historic flood map is largely based on the 2007 flood event which was
considered substantial in this location and likely to have been greater than a 100 year
plus climate change event. The proposed office development is located alongside the
road where ground levels appear to be further elevated. The positioning of the proposed
development would not obstruct flood flow routes or impact on floodplain storage in
considering the above information and that the proposal includes the demolition of
existing offices on site.
In considering safe development requirements, the applicant should set finished floor
levels of the new buildings at least 600mm above the 100 year plus climate change
flood level or, if it has been demonstrated to the satisfaction of your Council that this is
not achievable, incorporate flood resilience measures into the proposed development to
this standard. Consideration should also be given to historic flood levels. A suitable
Flood Evacuation Management Plan should be implemented for the whole site.
We do not normally comment on or approve the adequacy of flood emergency response
and flood evacuation procedures accompanying development proposals, as we do not
carry out these roles during a flood. Our involvement during an emergency will be
limited to delivering flood warnings to occupants/users if they sign up to the Flood
Warnings Service. However, it should be noted that there is only a general flood alert
(which covers the wider area) available in this location.
The NPPG places responsibilities on Local Planning Authorities (LPAs) to consult their
Emergency Planners with regard to specific emergency planning issues relating to new
development. In all circumstances where warning and evacuation are significant
measures in contributing to managing flood risk, we will expect LPAs to formally
consider the emergency planning and rescue implications of new development in
making their decisions.
We would advise that the Flood Evacuation Management Plan should identify a flood
level that will initiate evacuation of people and vehicles, and any subsequent closure of
the buildings/car park. This trigger level should be when the access/egress is still ‘dry’
i.e. flood-free, to avoid any question of what is an acceptable level of flood risk to
occupants.
You may seek the submission of a revised FRA that provides an assessment of the 100
year (Flood Zone 3) plus climate change, 1000 year (Flood Zone 2) and historic flood
extents to further inform the safe development requirements i.e. the level of protection
required for finished floor levels / flood resilience and flood risk information to inform the
management and evacuation of the site.
Surface Water Drainage: – Given the scale and nature of the proposed development,
we would not wish to provide bespoke comments on the surface water drainage
proposals. We would refer you to our local Flood Risk Standing Advice (FRSA) – FRA
Guidance Note 1 in consultation with the South Worcestershire Land Drainage
Partnership, as the Lead Local Flood Authority (LLFA), to lead on and approve the
surface water drainage scheme.
Cont/d..
3
I trust that the above comments are of use.
Yours faithfully
Mrs Rachel Whiteman
Senior Planning Advisor
Direct dial 01743 283505
Direct e-mail rachel.whiteman@environment-agency.gov.uk
cc Absolute Architecture Ltd.
End
4