Cherwell District Council
Planning & Development Services
Bodicote House White Post Road
Bodicote
Banbury
OX15 4AA

Our ref:	WA/2014/119416/01-L01
Your ref:	14/01912/F

Date:		30 December 2014

Dear Ms Mangnuson,

ERECTION OF TWO STOREY DETACHED DOMESTIC DWELLING AND DIVISION OF SITE FOR PROPOSED DEVELOPMENT - RE-SUBMISSION OF 14/00860/F   
LAND ADJ TO 4 BARRETTS ROW MAIN STREET WENDLEBURY      

Thank you for consulting us on this matter. We received the letter on 08 December 2014 and we are now in a position to respond.

Environment Agency position

In the absence of an acceptable Flood Risk Assessment (FRA) we object to the grant of planning permission and recommend refusal on this basis for the following reasons:
 
Reason

The FRA submitted with this application does not comply with the requirements set out in paragraph 9 of the Technical Guide to the National Planning Policy Framework. The submitted FRA does not therefore, provide a suitable basis for assessment to be made of the flood risks arising from the proposed development.

In particular, the submitted FRA fails to: 

1.	Adequately consider the requirement for flood emergency planning including flood warning and evacuation of people for a range of flooding events up to and including the extreme event.

Overcoming our objection

You can overcome our objection by submitting an FRA which covers the deficiencies highlighted above and demonstrates that the development will not increase risk elsewhere and where possible reduces flood risk overall. If this cannot be achieved we are likely to maintain our objection to the application. Production of an FRA will not in itself result in the removal of an objection.

Whilst we acknowledge that the proposed built development is in Flood Zone 1, the access to site lies within Flood Zone 3b defined by the Technical Guide to the National Planning Policy Framework (NPPF) as having a high probability of flooding.

The NPPF states that “local planning authorities should only consider development in flood risk areas to be appropriate where it can be demonstrated development is appropriately flood resilient and resistant, including safe access and escape routes where required, and that any residual risk can be safely managed, including by emergency planning.”

A route of access and egress with a ‘very low flood hazard’* will need to be shown from all new units to an area wholly outside the 1 in 100 year plus 20% allowance for climate change floodplain. Where this cannot be achieved there will be an increased burden placed on the emergency services during times of flood. 

*Access and egress routes should be achieved in accordance with FD2320 (Flood Risk Assessment Guidance for New Developments). 
Further information can be found at the following link:
http://evidence.environment-agency.gov.uk/FCERM/Libraries/FCERM_Project_Documents/FD2320_7399_PR_pdf.sflb.ashx

This route should be on publicly accessible land and should have a hazard rating no higher than ‘very low’. If it is not possible to achieve a ‘very low’ route of access and egress then we would likely recommend an objection to the planning application as during a flood event access to the development will be lost, placing an increased burden on the emergency services. 

The Environment Agency will maintain an objection until the Local Authority is satisfied that the hazards associated with the development can be managed for its lifetime. This could be through a flood evacuation plan specific to the proposed development that enables the residents to evacuate before flooding occurs.

The FRA should provide sufficient information to enable Emergency Planners to determine if evacuation is possible. Issues to cover may include the rate of onset of flooding, the availability of flood warnings, duration of flooding, depth of flooding and the length of the evacuation route. Consideration should be given to all sources of flooding.
The applicability and requirements of a site specific flood plan to mitigate the risk of flooding should be discussed with the LPA and, if agreed, be included within the FRA.  It is not our role to review and assess evacuation plans or flood management plans.
If the LPA determine that a flood plan will not mitigate the risk of flooding then the applicant should revise their proposals so as not to increase the number of residential units at this site.

We ask to be re-consulted with the results of the FRA. We will provide you with bespoke comments within 21 days of receiving formal reconsultation. Our objection will be maintained until an adequate FRA has been submitted.

Yours sincerely,

Mr Jack Moeran
Planning Advisor

Direct dial 01491 828367
Direct e-mail planning-wallingford@environment-agency.gov.uk

cc Mr Henry Panton