Wychavon District Council Development Control Civic Centre, Queen Elizabeth Drive Pershore Worcestershire WR10 1PT Our ref: Your ref: SV/2011/104983/03-L01 W/10/02601/CU Date: 09 September 2011 FAO: Gavin Greenhow Dear Sir CHANGE OF USE OF SECTION OF RIVER BANK FOR BOAT MOORING AND CONSTRUCTION OF STAGES AND SLIPWAY - FIELD OFF TRACK TO FISHERMANS CAR PARK JUBILEE BRIDGE, MILL BANK, FLADBURY I refer to the letter dated 25 August 2011 and enclosures, from Arthur Griffiths and Mumford, which was received on 26 August 2011, in connection with the above proposed development. The information submitted included a copy of the plan (scale 1/2500, July 2011, Rev 1) showing spot levels. We would make the following comments following consideration of the above: We do not believe the site level survey, as submitted, is sufficient to make a detailed assessment of ‘safe development’. As such we are unable to fully review the risk of flooding to the development. The submission of a detailed topographic survey is normally necessary to ensure an accurate assessment of flooding. Notwithstanding the above, from the spot levels provided it appears as though the rear of the site (level of 19.015m AOD(N), which rises very slightly to 19.020m AOD(N) towards the fisherman’s car park) will be subject to depths of floodwater as much as 1.175 metres in a ‘high risk’ event. This is based on our 1% annual probability flood level of 20.19m AOD(N). With consideration of climate change depths will rise to 1.365 metres. This is based on our modelled 1% climate change flood level of 20.38m AOD(N). According to our records this area also flooded to a similar level in both 1998 and 2007. It should also be noted that almost the entire length of the proposed access track is within our ‘high risk’ Flood Zone 3 outline and has been cut off in historical flood events. We note the two spot levels of 21.520m AOD(N) and 21.180m AOD(N), some distance from the site, would be above our modelled 1% with climate change flood level of Environment Agency Hafren House, Welshpool Road, Shelton, Shrewsbury, Shropshire, SY3 8BB. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d.. 20.38m AOD(N). These may of course not be indicative of the complete length of access track between the fisherman’s car park and Jubilee Bridge. I refer to DEFRA's ’Flood Risk Assessment Guidance for New Development’ -FD2320, Table 13.1. This indicates the safety of an area in consideration of flood depth and velocity. On the basis of the above, taking the design 1% plus climate change flood level, as required by Planning Policy Statement (PPS) 25 – Development and Flood Risk, we would highlight that the risk is likely to be considered ‘significant’ and a “danger for most” people. We do not believe this degree of risk to future users, associated with sleeping accommodation, is acceptable in a new development. Unfortunately we do not have any information in relation to flood flow velocities in this specific location, to further clarify the above. It is assumed that the rear of the site may only be subject to a fairly minor flow velocity. However, this is likely to increase significantly as you get closer to the River Avon i.e. the bank and the location of the site users. In addition to the above it should also be noted that this site is an extremely rural location which is likely to significantly impact upon any evacuation procedure and the availability of access from the Emergency Services. We would recommend that you seek the views of your Emergency Planners in relation to the above matters and the proposed flood management/warning system. It is understood that Arthur Griffiths and Mumford are in discussion with them. I trust that the above comments clarify our position, based upon the information submitted, at this time. This response should be read in conjunction with our previous letter dated 9 August 2011. The submission of a full topographical survey may help to further define the risk in relation to safe access. However, it may just reinforce the above conclusions. We would also reiterate our previous suggestion in relation to the consideration of a marina/’off-line’ pontoons for the mooring of boats including overnight accommodation. Yours faithfully Mark Davies Planning Technical Specialist Direct dial – 01743 283405 cc. Arthur Griffiths and Mumford End 2