Chris Berry and Hilary Whelan write to the Faversham News


Hats off to Mark Gardner [Gardner Digs, Dec 13] for flagging up concerns about flood risk in relation to the Faversham Creek Neighbourhood Plan.

As we write this letter, Town Green is under water, the creek is lapping the town jetty and there’s a deep flood in Church Road – and this is not even an exceptionally high tide. If building on the creekside causes even the slightest increase in flooding levels, the consequences could be disastrous.

We have repeatedly raised the question of flood risk and flood defences, but we’ve had no response whatsoever. The subject is barely mentioned in the many consultations and reports on the future of the creekside, even though most of the land is designated by the Environment Agency as a flood risk area. It’s high time this was taken seriously.

Neighbourhood Plans must conform to the EU Strategic Environment Assessment (SEA) Directive. Any potential environmental impact should be screened by the local authority at an early stage, to determine whether an SEA is required. Has this been done? Have the flood risk implications been fully evaluated?

The letters from Councillors Cosgrove and Kay raise further concerns about the Neighbourhood Plan process. It does appear that, apart from the initial launch/exhibition in May, the plan is being drawn up behind closed doors by a small group of people who consult only those they choose, that the rest of us are expected to wait patiently and be grateful for any concessions squeezed out of landowners, and that dissenting opinion is not welcomed.

Community engagement is a legal requirement in the development of Neighbourhood Plans, yet the vast majority of Faversham residents have no idea what is being done in their name and with their money. Even those who take an active interest find it difficult to get information or to have any influence on the planning process.

Six months in, the steering group has not yet developed its community engagement strategy. The guidelines on Neighbourhood Plan development state that ‘properly engaging people from the beginning … ensures that there is an opportunity to influence the detail of the plan, rather than just having the option to accept or reject the whole plan … If the outcomes have already been determined, then community engagement is tokenistic (marketing)’ – yet the steering group minutes and the councillors’ letters strongly suggest that this is what they have in mind: waiting until the plan has been drawn up, then ‘selling’ it to us and trying to convince us to vote for it, whether we like it or not, on the grounds that the alternative will be worse.

The guidelines say that: ‘Community engagement should be undertaken before work commences … and throughout the process of plan preparation … It is important to publicise the proposals as widely as possible using different media … Feedback should be provided throughout the process.’

Prominent in the ‘what not to do’ guidelines are ‘consulting too late, placing a thick document on a stand in a library or on a website and expecting people to read it, or talking at people at a public meeting. Asking consultants to produce options before consulting the community is also poor practice. Consultation should not be treated as a one-off tick-box exercise … analysis of responses is not about counting the numbers, but considering the depth and range of responses.’

If people are not actively informed and involved, it’s no wonder that tempers are raised at meetings and angry letters are written to the newspapers. Instead of peevishly disparaging their critics, complaining about how difficult their job is, and expecting unquestioning support for whatever they’re doing (but not telling us what it is), our elected representatives should be seeking to engage with objectors and address their concerns.

This plan is supposed to be local democracy in action: it needs to be opened up to public scrutiny. Publishing in full the results of the May consultation would be a good start.

Chris Berry & Hilary Whelan – Upper Brents, Faversham


2 responses to “Chris Berry and Hilary Whelan write to the Faversham News

  1. Intro to the SFRA documentation at SBC: “In April 2008, Swale Borough Council commissioned Halcrow to produce a Strategic Flood Risk Assessment (SFRA) in accordance with Planning Policy Statement 25 (PPS25) Development and Flood Risk (December 2006). Advice on flood risk within the administrative boundary of the planning authority is required to support the preparation of their Local Development Framework (LDF), in accordance with government guidance and advice from the Environment Agency.”
    The following is copied from that assessment. I have it on cd if anyone has time to look through it in detail.: (Apologies for the formatting I have just copied and pasted)
    Development Area 6 Faversham Creek AAP
    Size of Development Area 28.1 ha
    Previously developed land? Yes
    Potential sources of flooding Tidal, fluvial, groundwater, surface water
    Historical flooding EA10 and MIDB20 (tidal), EA23 (groundwater), MIDB19 (surface runoff) and 3 Southern Water incidents.
    % of area covered by 1 in 20 yr tidal flood zone (FZ3b)
    47% in 2010 67% in 2070 78% in 2115
    % of area between 1 in 20 & 1 in 200 yr tidal flood zone (FZ3a)
    30% in 2010 12% in 2070 9% in 2115
    % of area between 1 in 200 & 1 in 1000 yr tidal flood zone (FZ2)
    2% in 2010 3% in 2070 3% in 2115
    % of area beyond 1 in 1000 yr tidal flood zone (FZ1)
    21% in 2010 19% in 2070 10% in 2115.
    Sensitivity of flood zones to climate change
    By 2115 about a tenth of DA6 will no longer be Flood Zone 1 and over three-quarters will be in Flood Zone 3b. Therefore climate change will have a significant impact on flood risk.
    Potential for development
    DA6 has a reasonable potential for development since it is on land within the town area. However, a good part of the DA is within Flood Zones 2 to 3b which will place restrictions on the type of development possible.
    Advice for undertaking Sequential Test
    DA6 is a low preference DA as there is very little area within Flood Zone 1. When allocating sites within the DA, the sequential approach should be followed as described in Chapter 6 so that sites with the most vulnerable land use go in Flood Zone 1 and so on. When taking defences into account, allocate development in order of vulnerability first in FZ1, then the defended part of FZ2, then the undefended part of FZ2 and so on.
    Potential to increase flood risk elsewhere
    The development area borders Oare Creek and therefore if development encroaches on the
    floodplain this may exacerbate flooding downstream in the marshes. If adequate measures are not put in place (e.g. use of SUDS) to restrict surface runoff it may cause flooding downstream or downhill.
    Standard of defences The length of Faversham Creek running through DA6 is undefended. Downstream the defences are 1 in 10.
    % of area flooded by defence overtopping of 1 in 20 yr tidal extent
    47% in 2010 67% in 2070 78% in 2115
    % of area flooded by defence overtopping of 1 in 200 yr tidal extent
    67% in 2010 77% in 2070 82% in 2115
    % of area flooded by defence overtopping of 1 in 1000 yr tidal ext.
    76% in 2010 79% in 2070 91% in 2115
    % of area benefitting from defences in a 1 in 200 yr tidal event
    10% in 2010 2% in 2070 6% in 2115
    % of area benefitting from defences in a 1 in 1000 yr tidal event
    3% in 2010 2% in 2070 0% in 2115
    Tidal Depths and Hazard
    Maps WBSWLE–HAZ–029 to 046 indicate that by 2115 most of the 200 year overtopping flood
    extent will be ‘danger for most’ with a significant proportion of ‘danger for all’ – along Upper Brents, Church Road, Brent Road and the opposite Bank, and at the north end of Belvedere Road (but redevelopment may alter this).
    Generally the flood depths reflect the hazard patterns; the deepest flooding of up to about 3m in the Development Area 6 Faversham Creek AAP elsewhere.
    Emergency Plan recommendations
    Emergency planning should plan for all potential sources of flooding, including breaches. Escape routes should avoid passing through flooded areas, especially where the hazard rating is high. Tidal events are usually known well in advance so flood warnings should be issued and defences checked to assess whether they appear at risk of breach.
    Further study for DPDs?
    Site specific FRAs will be required for each site as part of the planning application. If defences need to be considered (should only be considered after the Sequential Test has been applied), run the model developed for the SFRA, modified appropriately, to investigate the effect of proposed defence schemes – in particular to assess the effect on other new and existing developments.
    A survey to improve the model topographical representation around Faversham Creek is
    recommended. If a Surface Water Management Plan is carried out it is recommended that DA4,
    DA5 and DA6 be considered together.
    Policy Recommendations
    FRAs are required as per Chapter 7; if a site has more than one flood zone, the FRA should be prepared following the guidance for the most frequent flooding (e.g. if any part of the site lies within FZ3b then Section 7.4 should be followed).
    For sites within FZ1, an FRA, as per Section 7.2 of this SFRA, is recommended even where the area is less than 1ha, as historical incidents indicate groundwater and surface water flooding may be a problem in Faversham.
    In light of the recently reported flooding on 10th December 2009, the Quay Lane, Conduit Street, North Lane and Belvedere Road area should be treated as part of Flood Zone 3b; in the absence of alternatives, as indicated by the flood extent in the SFRA map. However, the GIS tide-projection methodology gives a conservative estimate. To refine the flood extent, it is recommended that further survey work is carried out as part of the FRA to improve the hydraulic model representation of flood patterns in this area.
    If the Sequential Test concludes it is necessary to allocate land uses which are too vulnerable within Flood Zones 2 to 3a, development must be made safe using flood control measures, and these must be in accord with other planning policies. The CFMP policy is to ‘continue with existing or alternative actions to manage flood risk at current level (accepting that flood risk will increase over time from this baseline)’, and the Medway Estuary and Swale SMP policy for Faversham Creek is to ‘hold the line’, therefore within DA6 it is acceptable to refurbish and raise the defences to a level which would protect the proposed land uses. The standard of protection required depends upon the land use vulnerability classification for the return period, and upon whether the development is
    residential or commercial for the design life horizon – 100 years, i.e. up to year 2115, and 60 years, i.e. up to year 2070, respectively, although defences for commercial development should have the capability to be raised in the future in case land use changes to residential. Modelling work will be Development Area 6 Faversham Creek AAP
    necessary to check the new defences will not increase flood risk in neighbouring locations –
    especially if Oare DA is also developed. A legal agreement must be in place for funding the upgrade and maintenance of the defences, if required. The recommendations and approach described in Section 7.5 needs to be followed to identify the preferred defence raising solution.
    Exception Test to be linked to reduction of surface runoff, adoption of flood resilient and flood resistant measures, production of an adequate Evacuation Plan as well as commitment to fund the raising and maintenance of the defences (if required).
    Surface runoff to be reduced as described in the SUDS recommendations row, following the
    guidance in Chapters 7 and 8. Where discharge to the drainage system is unavoidable and it has been identified (e.g. in an FRA or SWMP) that there is no spare capacity at an outfall or in the current surface drainage system, development must include upgrade of outfall or drainage system, or construction of separate drainage. The DA is within CFMP “Policy 3” area which anticipates that action will be taken to reduce flood risk in urban areas while accepting that flooding will worsen in the more rural areas. However, it is recommended that increased flooding of rural areas be prevented if possible in order to avoid a negative impact on the designated areas downstream.
    Basement flooding has occurred within the DA in the past, therefore it is recommended that
    basement dwellings should not be permitted.
    Evacuation routes from flood risk areas must be ensured. Where development will affect those
    identified in this SFRA (see Maps WBSWLE-FZ–001 to 004), alternative routes must be identified.

  2. Apologies… I meant to point out that this assessment (done by quite a big company, probably not cheaply) was ‘superseded’ by a document referred to in the Fullwood Report of 2010 ( page 10) . The reference is simply to ‘this document’. I have no idea if this indicates that it is the Fullwood Report itself which supersedes the Halcrow flood report or if another report has done this. There is merely reference to the fact that this has been done by person or persons unnamed “in consultation with the Environment Agency”. So we have no idea if it was given the full blessing of the EA or if they were a bit dubious…
    However, the effect of this document wherever and whatever it might be, is to allow development not only on the 1:20 year flood risk area, but on the bits designated as functional flood plain – which latter areas should only have water compatible uses — perfect land for boat repair…
    This has been done because the land is ‘previously developed’ and in some twist of logic I don’t follow, because its a restricted area. The fact that much of it was previously developed, strangely enough, as boat yards, or other uses related to its creekside position, appears irrelevant to the powers that be.

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