Proof of Evidence
Malcolm Parker BSc CEng MICE
APPEAL BY MR THOMAS ALLEN
AGAINST REFUSAL OF PLANNING PERMISSION UNDER SECTION 78 OF THE
TOWN & COUNTRY PLANNING ACT 1990
APPLICATION TO REMOVE CONDITIONS 1 (Time period limit) AND 2
(Restoration
of
land
to
former
condition)
OF
APPEAL
DECISION
APP/K0235/A/08/2082215 (LPA REF 07/03706/FUL) FOR PERMANENT USE OF
SITE.
CHANGE OF USE OF AGRICULTURAL LAND TO CARAVAN SITE WITH FOUR
PITCHES, ERECTION OF TWO AMENITY BLOCKS, PARKING OF COMMERCIAL
VEHICLES, LANDSCAPING AND ASSOCIATED WORKS.
AT WAITING FOR THE SUN FARM, RUSHDEN ROAD, BLETSOE, BEDFORD
MK44 1QN
PINS REF:
LPA APPLICATION REF:
LPA APPEAL REF:
APP/K0235/A/12/2187276/NWF
11/02690/S73
12/00045/REF
Proof of evidence of Malcolm Parker BSc CEng MICE
Inquiry opening 9th April 2013
1
Proof of Evidence
1
Malcolm Parker BSc CEng MICE
INTRODUCTION
MALCOLM PARKER will say
1.1
My name is Malcolm Parker I am a Chartered Civil Engineer and have been
a member of the Institute of Civil Engineers for almost 30 years. I have
worked for Bedford Borough Council for over 20 years and I am currently
employed as Head of Engineering. Prior to working for the Council I have
been employed as a design Engineer by the Ministry of Agriculture, private
practice both in the UK and abroad and by Strathclyde Regional Council.
1.2
I am Head of Engineering at Bedford Borough Council and have been
instructed to represent the Council at the Inquiry. I am familiar with the
Meadow Lane site and the surrounding area.
1.3
My evidence will show that the proposed engineering solution that includes
raising the ground level of the habitable area of the site will show that it will
be located in flood zone 1 that has a low probability of flooding. The
Bedfordshire and River Ivel Internal Drainage Board (IDB) advised that in
partnership with the Environment Agency
and Marston Vale, that
Engineering Consultants Scott Wilson (now URS) were commissioned in
2009 to undertake significant flood modelling which covers over 2000 acres
to the east of Bedford including the Meadow Lane site. This model is
referred to as the Bedford River Valley Park (BRVP) model. The evidence is
supported by a Flood Risk assessment that is based on this model. The
Environment Agency have deferred the approval of this flood risk to the IDB.
It will include communications from the IDB and the Flood Extent maps
provided by the BRVP model.
1.4
My evidence is set out in the following order:
1.
Introduction
2.
The site and its surroundings
3.
Policy & Guidance
4.
Analysis
5.
Summary & Conclusion
6.
Alternative Site – Fairhill
A separate volume of appendices is also submitted.
Inquiry opening 9th April 2013
2
Proof of Evidence
2
2.1
Malcolm Parker BSc CEng MICE
THE SITE AND ITS SURROUNDINGS
The Meadow Lane site is situated on the south-eastern side of the A421 in
Cardington Bedfordshire, with vehicle access directly from Meadow Lane. A
drainage ditch serving the A421 runs along the north-western site boundary,
with a drainage ditch also running down the eastern boundary that
discharges into Elstow Brook. Elstow Brook is approximately 230m from the
site at its nearest point. The site benefits from bunds along the eastern and
southern boundaries which will protect the site from fluvial flooding.
2.2
The flood maps available on the Environment Agency (EA) website show
that sections of the site are located within Flood Zones 1, 2 and 3. However,
the EA advised on 30.01.12 (Appendix 1) that the main source of flood risk
is associated with watercourses under the jurisdiction of the Bedfordshire
and River Ivel Internal Drainage Board (IDB) and as such defer flood risk
matters to the IDB.
2.3
The IDB advised that in partnership with the EA and Marston Vale, that Scott
Wilson (now URS) were commissioned in 2009 to undertake significant flood
modelling which covers over 2000 acres to the east of Bedford including the
Meadow Lane site. The results of which are referred to as the Bedford River
Valley Park model (BRVP). The IDB advised that the information contained
and provided by this model would be used to asses the flood risk to the
proposed development and would supersede any information provided on
the EA Flood Maps website. (Appendix 2)
2.4
The information shown on Plan A477.POE.01 (Appendix 03) represents the
information provided by the BRVP Model and shows that the proposed
development falls mainly into Flood Zone 1 with a small section in Flood
Zone 2 and 3. Olaf Bierfreund (CEng MICE, A.M. ASCE, Associate Civil
Engineer, Head of Motor Sports URS Infrastructure & Environment UK
Limited) of URS confirmed the model does not take account of the bunding
on site(Appendix 04). However, as the BRVP Model does show a small
section of the site to fall into Flood Zones 2 and 3 this needs to be taken in
to account within the design. It has been verbally accepted by URS and in
Inquiry opening 9th April 2013
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Proof of Evidence
Malcolm Parker BSc CEng MICE
writing by the IDB (Appendix 02) that the existing bunding would protect the
site from fluvial flooding. As the BRVP model shows some of the habitable
area of the site within Flood Zones 2 and 3 the ground level will be raised,
this land raising is required to provide a gravity fed surface water drainage
system for the site. Any land raising in an area within the 1:100yr + climate
change outline will require flood storage compensation to be provided else
where on the site on a volume for volume and level for level basis as shown
in Ciria C624: Development of Flood Risk – Guidance for Construction
(2004). The IDB require that the minimum floor level is 600mm above the
1:100yr event or 500mm above the 1:100yr + climate change event,
therefore 23.02mAOD or 23.12mAOD respectively (Appendix 02). The
maximum depth of flooding on the site is just greater than 250mm and the
area to be raised within the flood zones is 505.112m2 as shown on Plan
A477.POE.01 (Appendix 03). Flood depth grid data was provided by URS
for the 1:100yr + climate change event, This information combined with the
flood outline was input into Autocad Civil 3D 2013 to calculate the volume of
flood storage compensation required, determined as 43.485m3. This volume
will be increased by 10% and rounded up to provide a safety factor, the
volume of compensation will be 50m³. This information is shown on Plan
A477.POE.03 (Appendix 05).
2.5
The ground levels and bunds surrounding the site provide a minimum height
of 22.82mAOD protecting the site from fluvial flooding given that the 1 in
100yr + climate change flood level is 22.62mAOD. As the ground and bund
level is generally in excess of 23.2mAOD and the lower level of 22.82mAOD
is only over a short distance the proposal is to raise this level to a minimum
of over 23.2mAOD. In addition the access and habitable site levels will all be
raised to ensure all finished levels are considerably above the 22.62mAOD 1
in 100 year plus climate change flood level provided by the BRVP Model.
The minimum site level will be 23.500mAOD. This provides a safety
clearance of 880m above the 1:100yr + climate change level, which is a
further 380mm above the IDB minimum requirements of 500mm.
3
POLICY & GUIDANCE
Inquiry opening 9th April 2013
4
Proof of Evidence
3.1
Malcolm Parker BSc CEng MICE
The Flood Risk Assessment (FRA) was produced in February 2012, based
on information contained within Planning Policy Statement 25 (PPS25):
Development and Flood Risk and the Technical Guidance to the National
Planning Policy Framework that accompanies this document. PPS25 has
since been replaced by National Planning Policy Framework (March 2012).
The FRA can be found in Appendix 06.
3.2
This policy sets out to avoid inappropriate development in areas at risk of
flooding, by directing developments away from areas at highest risk. Flood
Zones are categorised as Zone 1 – low probability, Zone 2 – medium
probability and Zone 3 - high probability. An area at risk of flooding means
land within Flood Zones 2 and 3. Flood Zone 1 covers all land not classified
as either Zone 2 or 3.
3.3
The existing ground levels and bunds surrounding the site provide a flood
defence against fluvial flooding from Elstow Brook. Without this the BRVP
Model shows that following a 1 in 100 year event with allowances for climate
change a small section of the site would fall into Flood Zones 2 and 3. The
IDB have insisted they will not take account of the bund unless the BRVP
Model is updated to take account of the bund and the site is shown not to
flood. Therefore the design assumes a worst case scenario and ignores the
presence of the bund as instructed by the IDB. The habitable area of the site
has been raised to a minimum level of 23.50mAOD. The IDB have
confirmed that providing a minimum ground level of 23.50mAOD will take
the site out of Flood Zones 2 and 3 into Flood Zone 1 (Low Probability). In
addition to this the existing bunding will provide additional protection from
fluvial flooding. The proposed site following construction will therefore be
classified as Flood Zone 1(Appendix 02).
3.4
Regarding access and egress from the site reference to Plan A477.POE.02
(Appendix 07) shows Meadow Lane and the A603 Cambridge Road west to
be passable giving access onto the A421. A section of the A603 to the east
of Meadow Lane would be covered by water. The A603 westbound to the
A421 shows water in the southern channel. In an extreme event we would
therefore recommend that access and egress from the site uses the A603
Cambridge Road to the west of Meadow Lane.
Inquiry opening 9th April 2013
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Proof of Evidence
3.5
Malcolm Parker BSc CEng MICE
Table D.1:Flood Zones shows that all land uses are appropriate within Zone
1 – low probability.
3.6
Table D.2: Flood Risk Vulnerability Classification, classes the proposed
development as ‘Highly Vulnerable’.
Inquiry opening 9th April 2013
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Proof of Evidence
3.7
Malcolm Parker BSc CEng MICE
Table D.3: Flood Risk Vulnerability and Flood Zone ‘Compatibility’,
compares the information provided in Tables D.1 and D2 and assesses if the
development is appropriate in the specific circumstances of the site.
Inquiry opening 9th April 2013
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Proof of Evidence
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4.1
Malcolm Parker BSc CEng MICE
ANALYSIS
The information provided by the BRVP Model was used to inform the Flood
Risk Assessment (FRA) as carried out using the guidance set out in PPS25
(The current document at the time of writing). The results of this analysis
show the proposed site is a suitable location for the proposed development.
4.2
The level of the 1 in 100year + 20% Climate Change flood event on the site
is 22.620mAOD as provided by the BRVP Model. The bund running around
the site will have a minimum height of 23.2mAOD and protect the site from
fluvial flooding. In addition the actual site levels will be increased to a
minimum level of 23.50mAOD. This provides a site level 880mm above the
1:100yr + climate change level The IDB require a minimum clearance of
500mm which the proposals exceed by 380mm and as directed by the IDB
does not take into account the existing bund.
5
5.1
SUMMARY & CONCLUSIONS
In summary, Bedford Borough Council prepared a FRA for the site based on
information of the BRVP detailed model for flood risk. The planning authority
consulted with the IDB regarding the flood risk to this site and its suitability
on those grounds for the purposes of a Gypsy and Traveller site. The IDB
classified the pre-developed site as Flood Zone 1, 2 and 3. The design
provides a minimum site level of 23.50mAOD post development, and flood
storage compensation of 50m³ which is 10% greater than the existing
Inquiry opening 9th April 2013
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Proof of Evidence
Malcolm Parker BSc CEng MICE
volume. The IDB agree with the classification of the site as Flood Zone 1
following construction and expressed no objections to the proposal
(Appendix 02).
5.2
In conclusion the proposals for the site are acceptable from a flood risk
viewpoint.
6
6.1
ALTERNATIVE SITE - FAIRHILL
The proposed site is for 14 pitches with the accommodation providing for
hard standing for two caravans per pitch and day rooms including kitchens
and bathrooms. The proposal also includes for a site office and play area.
The site will be known as the Fairhill site because part of the proposed site
occupies a small part of the former Fairhill allotments site.
6.2
Access will be via Cut Throat Lane which connects to the A6 Clapham Road
at the existing roundabout. The site is bounded by the River Great Ouse to
the west, the A6 to the north, the Midland Railway to the south and
Sainsburys to the east. With a UK Power Network substation to the southeast of the proposed site for which access will be maintained. The proposed
location will not inhibit the development or construction of the Bedford
Western Bypass Phase 2, however depending on timescales co-ordination
will be required between the two proposed developments.
6.3
The Fairhill site is located approximately 300m from the River Great Ouse
and located entirely within Flood Zone 1 (low probability) as shown on the
Environment Agency flood maps. The BRVP model used to determine the
flood zone classification for Meadow Lane does not cover the area occupied
by the Fairhill Site, and therefore can not be used.
6.4
A pre-planning application was made to Anglian Water to identify suitable
routes for both Foul and Surface Water. They identified a point of connection
on the A6 Clapham Road for the foul sewer and advised that a sustainable
drainage method for surface water should be explored before approval can
be granted to dispose of the site surface water to an existing surface water
main. The feasibility proposals for surface water are to provide on-site
Inquiry opening 9th April 2013
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Proof of Evidence
Malcolm Parker BSc CEng MICE
attenuation and discharge to the Great River Ouse at a rate to be agreed
with the Environment Agency, equivalent to Greenfield run-off rate. This will
provide a sustainable drainage system without the need to discharge to a
sewer main.
Inquiry opening 9th April 2013
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