SOS Chair, Richard Thurlow, also Chair of SVA Environment Committee, includes a fierce rebuttal of the Environment Agency response, in this formal objection submitted to EDDC this morning:
Please use freely for your own objections, if you wish. …DEADLINE TODAY! See our most recent posts for how to comment.
Planning Application Development at Sidford. 16/0669/MOUT
The Sid Vale Association wishes to add to our previous objection letter.
We have already objected to the development on the grounds that it contravenes LP policy EN21 by reason of its failure to mitigate the flooding risks…I quote
a. The Application contravenes Devon Local Plan Policy EN21 (River & Coastal Flooding). Mitigation measures as proposed by the applicant are inadequate as they fail to take account of the substantial increase in flood risk caused by climate change contained in the latest Environment Agency guidance.
b. In particular, the Applicants’ Flood Report data (1.6.1) are out of date as they predate the new Environment Agency (EA) report on Adapting to Climate Change: Advice for Flood and Coastal Erosion Risk Management Authorities, which was issued on 13th April 2016.
This view was supported by the EA’s Sustainable Planning Adviser on the 18th may 2016. However. further to initial comment of 18th May, the Environment Agency’s Sustainable Places Planning Advisor has submitted a second comment, today 7th June, where they contradict their own objection, because they say that although the guidance came into immediate effect from 19th February, it should not apply to this application because it was well advanced. (See below for actual words).
Environment Agency position
‘With regard to the climate change allowances used within the FRA, we are satisfied that the proposed development should not be subject to the higher standards required in the new climate change guidance. This is in accordance our climate change advice issued on 19 February 2016 which advises:
The guidance will come into immediate effect. However, where local plans or development proposals and associated flood risk assessments are well advanced, we would wish to avoid where possible significantly slowing down completion or adding to costs. We will therefore, other than for particularly vulnerable locations or sensitive developments, continue to base our advice on the existing allowances in the following circumstances:
o Where a local plan has been submitted for examination
o Where development proposals are well advanced or where a valid planning application has already been submitted to the local planning authority.
We have also reviewed the flood report provided by Cllr Rixon dated March 2016 and can advise that we are familiar with the flooding referred to therein. We are satisfied that the proposed development will contribute to a reduction in flood risk overall.’
SVA believe that this is wrong because;-
1. The valid planning application was submitted to EDDC well after the Environment Agency issued its own climate change advice on 19th February 2016.
2. It is evident that this is a particularly vulnerable location and is a sensitive development…
3. The proposed development might well contribute to a reduction in flood risk overall in the immediate future. But it is clear from the latest data provided by the Environment Agency that river flows will quadruple, and surface water run-off double, over the following decades – and this must be taken into account when considering this application.
It is the SVA’s considered view that this APPLICATION MUST BE CONSIDERED TAKING INTO ACCOUNT THE EA’S REPORT ON ADAPTING TO CLIMATE CHANGE, and THE EA’S LATEST ADVICE SHOULD BE DISREGARDED
Reasons; It is clear that the application contravenes East Devon Local Plan Policy EN21 (River & Coastal Flooding), in that the development should not be permitted, as the FRA no longer takes into account the substantial increase in flood risk over the coming decades and fails to demonstrate that the development will be safe, without increasing flood risk elsewhere and, where possible, will reduce flood risk overall.