Sunday, 5 June 2016

Sidford business park > Fords planning application >>> 16/0669/MOUT >>> Strategy 3 Target: "Reduction in the number of permissions granted contrary to the advice of the Environment Agency"

The Local Plan was adopted in January this year:
Local Plan 2013-2031 - East Devon

Then in February, the Environment Agency issued new advice on flooding and development, in the light of new research on climate change:

Big changes are on the way for developers following publication of new Environment Agency guidance on allowing for climate change in flood risk assessment, predicting river flows will double and sea levels will rise by over a metre

Developers beware: river flows predicted to double | Infrastructure Intelligence
Futures Forum: Sidford business park... and flooding: "Right now there are more questions than answers about how the new climate change guidance is going to be implemented. But be aware: this guidance is already a material consideration for all new planning applications and therefore, a valid reason for planning objections."

The changes are quite dramatic:
Flood risk assessments: climate change allowances - Detailed guidance - GOV.UK

And there are several policies and strategies specified in the Local Plan which would in effect make building on the Sidford flood plain untenable:

Strategy 3 - Sustainable Development: 
The objective of ensuring sustainable development is central to our thinking. 
We interpret sustainable development in East Devon to mean that the following issues and their interrelationships are taken fully into account when considering development: 
a) Conserving and Enhancing the Environment - which includes ensuring development is undertaken in a way that minimises harm and enhances biodiversity and the quality and character of the landscape. This includes reducing the risk of flooding by incorporating measures such as sustainable drainage systems. 
Developers should maximise the proportion of their developments that take place on previously developed land.

Strategy 5 – Environment: 
All development proposals will contribute to the delivery of sustainable development, ensure conservation and enhancement of natural historic and built environmental assets, promote ecosystem services and green infrastructure and geodiversity. 
Open spaces and areas of biodiversity importance and interest (including internationally, nationally and locally designated sites and also areas otherwise of value) will be protected from damage, and the restoration, enhancement, expansion and linking of these areas to create green networks will be encouraged through a combination of measures to include;
7) Making use of and protecting from development areas that are vulnerable to surface water runoff and flooding.

Strategy 6 - Development within Built-Up Area Boundaries: 
Built-up Area Boundaries are defined on the Proposals Map around the settlements of East Devon that are considered appropriate through strategic policy to accommodate growth and development. Within the boundaries development will be permitted if: 
2. It would not lead to unacceptable pressure on services and would not adversely affect risk of flooding or coastal erosion

17 Climate Change and Renewable Energy
Transition to a Low Carbon Economy
17.4 There is strong evidence that the climate is changing (69). The outcome for East Devon is predicted to be increases in summer temperatures, greater fluctuations in weather, uncertainty surrounding rainfall trends and an increased risk of flooding. These have the potential to increase risks to health and comfort, cause damage to buildings and infrastructure and increase building energy consumption from cooling. It is important that new development responds to these risks.

18 Our Outstanding Natural, Built and Historic Environment
Promoting Green Infrastructure
18.5 Green Infrastructure is seen as an essential part of our Vision for a long-term sustainable future for East Devon. The Council is committed to developing strategic networks of accessible, multi-functional sites (including parks, woodland, informal open spaces, nature reserves and historic sites) as well as linkages (such as river corridors and flood plains, wildlife corridors and greenways). 

To reduce the risk of flooding 
Strategy 3 
Target: Reduction in the number of permissions granted contrary to the advice of the Environment Agency

22 The Natural and Historic Environment
Flooding and Flood Prevention 
22.29 Both the impact of flooding on future development and the impact that development could have on patterns of flooding elsewhere are important planning considerations. Climate change may lead to increased risks of flooding over the lifetime of new developments. A Strategic Flood Risk Assessment for East Devon was completed in 2008. The policy approach set out follows the advice in both documents to apply a sequential approach and, if necessary, an exceptions test. 

EN21 - River and Coastal Flooding: 
A sequential approach will be taken to considering whether new developments excluding minor developments and changes of use (minor development includes non residential extensions with a footprint of less than 250 square metres, development that does not increase the size of the building or householder development unless it would create a separate dwelling) will be permitted in areas subject to river and coastal flooding. 
Wherever possible developments should be sited in Flood Zone 1 as defined in the East Devon District Council Strategic Flood Risk Assessment (106). Only if there is no reasonably available site in Flood Zone 1 will locating the development in Flood Zone 2 and then Flood Zone 3 be considered. The flood vulnerability of proposed development, as set out in Appendix D of the East Devon Strategic Flood Risk Assessment will be taken into account. 
If, after following this sequential approach, acceptable sites cannot be found and the development is necessary for wider sustainable development reasons, development may be permitted if all of the following criteria are met. 
1. It is demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk. 
2. The proposed development is on previously developed land that is suitably located and available for development, unless no reasonable alternative sites are available. 
3. A flood risk assessment demonstrates that the development will be safe, without increasing flood risk elsewhere and, where possible, will reduce flood risk overall. 
This shall not apply to ‘highly vulnerable’ development in Flood Zone 3a or ‘less vulnerable’; ‘more vulnerable’; or ‘highly vulnerable’ development in Flood Zone 3b as defined in the East Devon Strategic Flood Risk Assessment.


The planning application for a business park at Sidford was made in May - but has not taken the latest evidence from the Environment Agency into account:
16/0669/MOUT | Outline application accompanied by an Environmental Statement (with all matters reserved except access) for the development of up to 22,800sqm of floor space for use classes B1 (Office Light Industry), B2 (General Industry) and B8 (Storage and Distribution) with details of, and associated strategic landscaping for, the access, linking cycleway and footway, and flood improvements/attenuation. | Land Adjacent To Two Bridges Two Bridges Road Sidford

Submissions to the District Council planning department have to be in by Wednesday 8th June:
URGENT! Sidford Business Park Planning Application now in. “The more people who write in, the better”. DEADLINE for comments, WEDS 8th JUNE. | Save Our Sidmouth

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