Our Ref: SE 15255



Dear Mr Palmer



Jolly Boatman Site



Thank you for contacting the Environment Agency.



Please find attached the requested information on sequential tests
together with an email from Jack Hayes (Environment Agency Planning
Officer) to Elmbridge Borough Council. This was pre-application advice
following our request to the applicant to include a sequential test in
the application. As the application was submitted in January 2007, this
meant that PPS25 had just been released (Dec 2006) and therefore
required the test.


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
[email address].



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.



This information is provided subject to the enclosed notice, which you
should read.



Yours sincerely





Andy Goymer

External Relations Officer

The Environment Agency

Tel: 01276 454327

Email: [email address]