Stephen Holloway
Wychavon District Council
Development Control
Civic Centre
Queen Elizabeth Drive
Pershore
Worcestershire
WR10 1PT
Our ref:
Your ref:
SV/2014/107871/01-L01
W/14/01099/CU
Date:
25 July 2014
Dear Stephen,
ERECTION OF TWO HOLIDAY LODGES
LAND OFF, BROOK LANE, CROPTHORNE
Thank you for consulting us on this application which was received on 7 July 2014.
The application site is shown to be partially located within Flood Zone 2 (medium
probability) and Flood Zone 3 (high probability) of the River Avon.
In accordance with the National Planning Policy Framework 2012 (NPPF) a Flood Risk
Assessment (FRA) is required to demonstrate that the development is appropriately
located, is safe from flooding and will not have the effect of increasing flood risk impacts
on third parties. The applicant has submitted a brief FRA but this is very limited in detail
and does not fully demonstrate accordance with the requirements of national policy
noted above. We therefore OBJECT to the application at this time. We make the
following comments in this respect.
Sequential Test
The proposed holiday lodges are shown on our flood map to be partially located in
Flood Zone 2. Paragraph 101 of the NPPF advises that “Development should not be
allocated or permitted where there are reasonably available sites appropriate for the
proposed development in areas with a lower probability of flooding.” The Council
should therefore be satisfied that the applicant has sufficiently demonstrated that there
are no reasonably available sites for the proposed development in Flood Zone 1.
Environment Agency
Newtown Industrial Estate (Riversmeet House) Northway Lane, Tewkesbury, Gloucestershire, GL20 8JG.
Customer services line: 03708 506 506
www.gov.uk/environment-agency
Cont/d..
The FRA infers that the proposal falls within the PPS25 definition of ‘minor
development’ and is thus not subject to the Sequential or Exception Tests. You will
note however that PPS25 is superseded by the NPPF and its Planning Practice
Guidance (PPG) and in any event the definition of ‘minor development’ is limited to
minor non-residential extensions, alterations and householder development (see section
17 within the Flood Risk and Coastal Change advice within the PPG). The development
of a new dwelling should not therefore be regarded as ‘minor development’ in flood risk
terms and thus the requirements of the Sequential Test should still apply. We can
confirm however that the Exception Test will not be required in this instance due to the
location of the buildings in Flood Zone 2.
The Flood Risk Assessment
The applicant has indicated that they believe the 20m contour on the site to be the
boundary of the extent of Flood Zone 3. However, there is an EA fluvial flood model for
the River Avon, which should be referred to in the FRA. The River Avon has also
experienced significant flooding in recent years which should be commented upon in the
FRA, in particular the floods during summer 2007.
The 1 in 100 yr plus climate change level at this location is 19.71m AOD. All proposed
development should be located above and outside this extent.
Based on the site plan submitted with the application the proposed dwellings appear to
be located on the edge of the 21m contour and the proposed floor levels of 23.2 and
23.50m AOD will ensure that the proposed development is set sufficiently above likely
flood levels.
The proposed access to the lodges would be from the existing track which provides a
connection with Cropthorne village via Brook Lane. Although the access track is not
likely to be subject to flooding, Brook Lane is located in Flood Zone 3 and experienced
significant flooding during 2007. The existing track would not therefore provide a safe
flood free route for people.
No alternative access routes are demonstrated in the application but it is noted that
there is potential to access the site from the B4084 via the adjacent farm track. It is not
known however if the applicant will have the ability to access the site via this route and
thus we are unable to comment if this will provide a suitable solution.
Conclusion
Taking the above points into consideration, we agree that the proposed lodges will be
safe from flooding based on the proposed floor levels of 23.2 and 23.5 being sufficiently
above the 1 in 100 yr plus climate change flood level at this location of 19.71m AOD. It
is unclear however if a safe flood free access can be provided and thus we are unable
to conclude that the users of the development will be safe for its lifetime.
To address our concerns the applicant should provide evidence to show that a safe
flood free access is available during times of flood.
I trust the above is clear however please do not hesitate to contact me if you would like
to discuss this letter in more detail.
Cont/d..
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Yours sincerely
Mr Matthew Tyas MSc MRTPI
Senior Planning Advisor
Direct dial 01684 864381
Direct e-mail matt.tyas@environment-agency.gov.uk
End
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