Question
I think we can agree that significant parts of the Borough are at risk of flooding.
Can you assure me that the Council's draft Local Plan includes robust measures to project as accurately as possible future flood risk and is not over-reliant on Environment Agency mapping of existing and historic flood zones?
I ask because both run-off from current development and the increased incidence of heavy rainfall events associated with climate change suggest that there will be a significant expansion of the areas at risk of flooding over the local plan period.
Minutes:
Question
I think we can agree that significant parts of the Borough are at risk of flooding.
Can you assure me that the Council's draft Local Plan includes robust measures to project as accurately as possible future flood risk and is not over-reliant on Environment Agency mapping of existing and historic flood zones?
I ask because both run-off from current development and the increased incidence of heavy rainfall events associated with climate change suggest that there will be a significant expansion of the areas at risk of flooding over the local plan period.
Answer
National planning guidance on accounting for flood risk has been followed in progressing the local plan, as I think you know. Our draft planning policy on flood risk contained within the Draft Plan Consultation (2020) requires consideration of climate change and that flood risk both within and outside an application site is not worsened by development.
We have prepared a Level 1 Strategic Flood Risk Assessment (2020) to consider the land that has been promoted across the Borough, as well as a Level 2 Strategic Flood Risk Assessment (2021) for the masterplanned site at Hall Farm / Loddon Valley. Moving forward, a Level 2 Strategic Flood Risk Assessment is required to consider and inform all the proposed allocations.
Turning briefly to climate change, our work has applied the Environment Agency climate change allowances, specific to the Wokingham Loddon catchment, when modelling flood risk occurs. Climate change allowances are predictions of anticipated change for peak river flow and peak rainfall intensity and are required to be considered in flood modelling works to ensure increased infrastructure resilience to future flooding. Site specific flood risk assessments for individual development sites are also required to consider these climate change allowances and developers must design drainage systems and flood mitigation to cater for current surface water and fluvial flood risk, as well as predicted future rainfall.
At each stage we have engaged, and will continue to engage, the Environment Agency and the Council’s specialist flooding and drainage team.
I am sure you have a supplementary but whatever it is will have to be a written answer because I hardly understand the words, I have read myself.
I thought that might be the case John and I am glad that you admitted that, because I have to say that I am afraid it did not fill me with enormous confidence. It did not fill me with enormous confidence because I am sure you, if not already aware, will become aware that the Environment Agency has commented on the new draft Local Plan. It has submitted its comments on 1st March. In its submission the Agency expresses concern about some of the sites, quite serious concern, including Hall Farm. It states in relation to numerous sites identified as suitable for development in the draft Local Plan, and I am now quoting the Environment Agency’s comments, forgive me for the double negative it is theirs not mine; ‘we are not satisfied that the proposals will not increase the risk of flooding on or off the site.’ This is the Environment Agency telling you that they are not satisfied that you have built in proper safeguards. This is the Environment Agency telling you that they do not believe that some of these sites are suitable for development. Their overall comment is that they disagree with the viability of the plan. Would you like to respond to the Agency’s concern?
Supplementary Answer:
I am sure that what you have read out has been a concern that the Agency has written in, and I am sure that is part of the process of having a Local Plan Update consultation. There is absolutely no point in having a consultation unless you expect people to give you a reaction to what you propose. I am sure that will be taken into account and responded to in the next consultation, which would be the Reg 19 consultation or another Reg 18 consultation if there is sufficient push back against the current Local Plan Update consultation.