APPLICATION REFERENCE JMATTL/11/00507/FULM The letter from the Environment Agency enclosed with the report recommends refusal and gives reasons with which we have a considerable amount of sympathy Further to the update of the planning application for Brookside Paddock the flood risk assessment surprise surprise indicates that the new development will not be at risk of floods! The Parish Council are not concerned about the risk for the new development which is on an uphill site, what we are concerned about is the increased risk to existing property along the path of the unnamed watercourse aka "Breedon Brook", and upstream of the application site. The report also mentions a ditch which runs through the site, there is no mention of the fact that this ditch has been formed by erosion caused by water flowing from a spring at it's southern end. Following is an excerpt from the flood risk assessment supplied to us by Centremaps, it is clearly at odds with the assessment carried out, on behalf of the applicants, by RAB Consultants which on page 10 states and we quote: “Therefore the proposed development is appropriate for the flood risk and is not expected to increase the risk of flooding elsewhere" The claim is made that the site is in flood risk Zone 1, but the adjoining land at the north end of the site is according to Centremaps in flood zone 3 with a VERY HIGH RISK of flooding. The assessment also claims that the owners have no knowledge of the site flooding in the recent past, however the applicants the developers the owners and the surveyors are all of the same family and may not remember all instances of the flooding of which we have photographic evidence. Mrs Devaney at number 8 Main St also can provide compelling evidence. The letter from the Environment Agency ref LT/2011/113373/01-L01of 11th August to Mr Mattley states categorically that "The FRA will need to demonstrate that a residential development on the site is safe and DOES NOT INCREASE FLOOD RISK TO OTHERS. The letter also states that " The current proposal is concerning as the road culverts appear to be undersized and would therefore be subject to blockage risk and exacerbate any flood risk on the site". This is already a problem as blockages regularly occur. Page 7 para 8.0 of the RAB Consultants report clearly states that "The current site has an impermeable area of approximately 160.3 m ². The impermeable area of the proposed development will increase to approximately 2565.5²." This will clearly significantly add to the run off to the Breedon Brook and will exacerbate the upstream problem of flooding. RAB also state on page 8 of their report under the heading SOURCE CONTROL and subheading Soakaways that "According to www.landis.org.uk/soilscapes the subsoil type for this area of the UK is classified as "slightly acid loamy and clayey soils with impeded drainage" The report also suggests that one of the techniques that could be employed to limit surface water run off could be rainwater harvesting ie using saved water for not potable domestic purposes such as "watering gardens, car washing, flushing toilets and use in washing machines". We suggest that the developer has absolutely no control over such usage and is clutching at straws in suggesting that it is a possible way of preventing flooding. Following are two excerpts from the Centremaps report which we have referred to above. 2. British Geological Survey Groundwater Flooding 2.1 Groundwater Flooding Susceptibility Areas Where land that is prone to groundwater flooding has been built on, the effect of a flood can be costly. Because groundwater responds slowly compared with rivers, floods can last for weeks or even months. What is the highest susceptibility to groundwater flooding in the search area based on the underlying geological conditions? Very High Guidance: Where very high susceptibility is indicated, this means that given the geological conditions in the area groundwater flooding hazard should be considered in all land-use planning decisions. It is recommended that other relevant information e.g. records of previous incidence of groundwater flooding, rainfall, property type, and land drainage information be investigated in order to establish relative, but not absolute, risk of groundwater flooding. 3. JBA Surface Water (Pluvial) Flood Risk 3.1 JBA Surface Water (Pluvial) Flood Risk Surface Water (pluvial) flooding is defined as flooding caused by rainfall-generated overland flow before the runoff enters a watercourse or sewer. In such events, sewerage and drainage systems and surface watercourses may be entirely overwhelmed. Surface Water (pluvial) flooding will usually be a result of extreme rainfall events, though may also occur when lesser amounts of rain falls on land which has low permeability and/or is already saturated, frozen or developed. In such cases overland flow and 'ponding' in topographical depressions may occur. The data within this report is based upon a modelled 1 in 200 year rainfall event, and indicates the depths to which an area may expect to be flooded in such an event. What is the risk of pluvial flooding at the study site? Moderate This data is provided by JBA Consulting, © Jeremy Benn Associates Limited 2008/2009 The following pluvial (surface water) flood risk records within 50m of the study site are shown on the flood map ID Distance Direction Risk Depth of Flooding (m) 1 10.0 W Low Susceptibility Between 0.1 and 0.3m 12 15.0 N Moderate Susceptibility Between 0.3 and 1m 13 21.0 W Moderate Susceptibility Between 0.3 and 1m 16 30.0 N Significant Susceptibility Greater than 1m This information was taken from an enquiry to “Centremaps” based on 8 Main St., Breedon on the Hill. This property includes the north bank of the Breedon Brook and is at very high risk of flooding, in fact it has been flooded quite recently. Any further surface water run off flowing directly into the brook will only exacerbate this already serious problem. This application is nothing more than an opportunist attempt to convert an underutilised asset into profit for the owner. There used to be allotments on this site a facility which is in demand from the residents of the village as there are no others . It would be a good idea to utilise the site for that purpose, it would be popular and would enhance the facilities available to villagers.