The Environment Agency has been involved in discussions for this site over a number of years. We always seek the best environmental outcome and seek to prevent inappropriate development. This brownfield riverside site has a long and complex planning history and has been derelict for many years. 

Our technical staff assessed the development proposals based on the information submitted with the planning application. We have negotiated with the applicants of the proposed development so that all the environmental and flood risk issues and opportunities relevant to our remit have been addressed to our satisfaction.  As our issues had been resolved we did not object to this planning application.

We have requested that Elmbridge Council include a number of planning conditions on the planning consent. These have been requested to ensure issues such as flood risk and groundwater issues are addressed as the planning process proceeds.

Managing Flood Risk

The responsibilities for managing flood risk are clearly set out on page 8 – 10 in PPS25 (Development and Flood Risk Planning Policy Statement).

With respect to flood risk, we have requested planning conditions to secure:

• Provision of a safe exit route for residents during a flood event
• Floor levels to be set at an appropriate level
• Control of basement construction
• Management of surface water. 

We will not recommend conditions are discharged until we are satisfied with the information submitted by the developer.  We will continue to work closely with the applicant and Elmbridge Council to ensure local flood risk is not increased as a result of this development.

The planning conditions we requested for the provision of a safe exit route and finished floor levels both incorporate an allowance for climate change.

Level for level floodplain compensation has been proposed up to the 100 year modelled flood level of the River Thames.  Agreements on floodplain storage and some of the details of the scheme were made before the release of PPS25.  There was no requirement to provide floodplain compensation up to the 100 year plus climate change flood level at this time. Additional volumetric flood water storage has been proposed by the applicant in addition to this compensatory storage.  This results in an improvement to the existing situation and an increase in flood storage for flood events up to the 100 year level. 

We are aware that a large underground basement structure is proposed for the new development. We have asked the developer to provide a risk assessment to demonstrate how the basement will impact on groundwater flow in the sub-surface and how it is intended to mitigate the risk associated with groundwater accumulation up-gradient. A report by Waterman Environmental submitted with the application stated that drainage plans were to be produced to detail the movement of the groundwater around the underground structure and we requested that these be submitted to us for approval.

Application of Sequential Test

We can only assess a planning application on the information submitted by the developer.  Our role is to provide general guidance on the sequential test process and to provide technical flood risk comments to Elmbridge Council. The local authority is responsible for the application of the Sequential Test.

The Environment Agency only has a limited role in assessing the methodology or evidence base for the sequential test (either borough-wide or at planning application stage) as this pertains to the wider planning application decision making process. It is the council’s role to apply both the sequential and exception tests and to make the final judgement and determination on whether or not the development meets the requirements of PPS25.

Summary

The Environment Agency has worked closely with Elmbridge Council and the developer to achieve the best environmental outcome from the development of this site.

We continue to develop a close working relationship with Elmbridge Council, by providing council planners with regular advice on flood risk and other planning issues. This partnership working is in line with national planning policy “There should be effective on-going liaison so that each party is aware at all stages in the process of the position of the others with regard to the application.”

I hope that this information is of use. If I can be of further assistance please contact me direct on 01276 454327 or email me at xxxxxxxx@xxxxxxxxxxxxxxxxxx.xxx.xx.

You should note that this information is based on that currently available as of the date of this letter. We accept no liability whatsoever for any loss or damage arising from interpretation or use of this information. You may feel it is appropriate to contact our office at regular intervals, to check whether any amendments/ improvements have been made. Should you re-contact us after a period of time, please quote the above reference in order to help us deal with your query.