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BGT-BWB-ZZ-XX-RP-YE-0006 Site 160 Flood Risk Review -Final

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BGT-BWB-ZZ-XX-RP-YE-0006 Site 160 Flood Risk Review -Final ENVIRONMENT Harworth Group Gateway 180, Bradholme Farm (Site ref. 160) Flood Risk Summary for Doncaster Local Plan Examination Oct 2020 Document Number: BGT-BWB-ZZ-XX-RP-YE-0006_FRTN BWB Reference: NTW_2654_FRTN_4 Revision Date of Issue Status Author: Checked: Approved: P03 20/10/20 S1 Iqbal Rassool Graham Littlewood Iqbal Rassool Notice All comments and proposals contained in this report, including any conclusions, are based on information available to BWB Consulting during investigations. The conclusions drawn by BWB Consulting could therefore differ if the information is found to be inaccurate or misleading. BWB Consulting accepts no liability should this be the case, nor if additional information exists or becomes available. BWB Consulting Limited accepts no responsibility for any use of or reliance on the contents of this document by any third party. No part of this document shall be copied or reproduced in any form without the prior written permission of BWB Site 160 Flood Risk Summary, Oct 2020 BGT-BWB-ZZ-XX-RP-YE-0006_FRTN 1. INTRODUCTION Instruction 1.1 As part of the current Doncaster Local Plan Examination, the Inspector requested summary information from the Environment Agency in advance of the Hearing session dedicated to Flood Risk matters (14th Oct 2020), to better understand flood risk conditions at the potential employment sites. A summary note was submitted by the Environment Agency, but the Inspector has requested that the Council expand on this summary information to provide more comprehensive comparison between the sites, making use of any supplementary site specific assessment information. 1.2 This document has been produced by BWB Consulting Ltd on behalf of Harworth Estates and presents our observations and comments to the Environment Agency’s Flood Risk summary submission, specifically in relation to Site 160, proposed Gateway 180 development at Bradholme Farm. To assist the Inspector and the Council with collating this information within a wider summary table we have retained the same format of table headings to that within the Environment Agency’s document. 1.3 Our comments within this summary are informed by the following: 1.3.1 Formal pre-application consultation meetings with the Environment Agency (8th June 2018) and Isle of Axholme Drainage Board (Feb 2020), 1.3.2 Review of the updated baseline model data received from the Environment Agency for the 2018 River Torne Hazard Mapping Study and the 2016 Upper Humber model (received Nov 2019). 1.3.3 Supplementary assessment work identifying the flood zones to be inconsistent with the latest modelling data at site 160 and resulting in the submission of a formal flood zone challenge to the Environment Agency (submitted 24th June 2020 and attached as Appendix A). We understand that this is still pending, but the output provided in the Environment Agency’s summary information to the EIP similarly confirms a lack of correlation between the indicative Flood Zones and the latest model predictions. Page | 2 Site 160 Flood Risk Summary, Oct 2020 BGT-BWB-ZZ-XX-RP-YE-0006_FRTN 2. SUPPLEMENTARY SUMMARY INFORMATION 2.1 The following table provides point by point commentary and supplementary findings associated site 160 with respect to the Environment Agency’s own summary issued as part of the Doncaster Local Plan Examination. Parameter Environment Agency BWB Comments comments Availability Refer to Doncaster Local We would concur with the Environment Agency’s view that the most up to date models and Authority Area Model covering the area relevant to Site 160 and other potential employment sites in the suitability of Update note. M18/M180 corridor are the following: model data - Upper Humber Model 2016 (which includes the River Don) - River Torne Hazard Mapping Study 2018 (which includes the South Soak Drain) - Tidal Trent Model 2013 - Isle of Axholme Flood Risk Management Strategy 2014. From pre-application consultations with the Environment Agency and Isle of Axholme Drainage Board it was identified that relatively speaking flood risk from the Trent and Drainage Board network are negligible sources and that flood risk to the site should be based on the findings of the Humber and Torne models. We would regard the Upper Humber and Torne models as being of a suitable level of detail to form the basis of a Level 2 SFRA for locations in M18/M180 corridor. Flood Zone Approximately 93% flood The first part of the Environment Agency’s comments appear to refer to the relative areas zone 3, 7% flood zone 2 of Flood Zone 2 and 3 from the published Flood Maps for Planning (extract of this is shown (Approximately 5-10% of in Figure 1 below). In terms of the flood zone information in the public domain, the relative the site is also shown to be areas for FZ2 & FZ3 is a statement of fact. within Flood Zone 3b the Functional Floodplain of the South Soak Drain). Page | 3 Site 160 Flood Risk Summary, Oct 2020 BGT-BWB-ZZ-XX-RP-YE-0006_FRTN Figure 1 – Published Flood Zones However, based on our own reviews of the latest models and the Environment Agency’s own model predictions, we would consider the flood zones to be unrepresentative of flood risk in this location and the Environment Agency comment associated with the potential for a small amount of flood zone 3b on the site is inaccurate. We would concur with the Environment Agency’s summary note that the most representative model for flood risk at site 160 is the 2018 River Torne Model. This model has been reviewed for use as the representative tool for undertaking a site specific assessments in this location and in reviewing bank levels and site specific topographical survey information the flood predictions shown in Figure 2 have been produced. Page | 4 Site 160 Flood Risk Summary, Oct 2020 BGT-BWB-ZZ-XX-RP-YE-0006_FRTN Figure 2 – Updated predictions from River Torne model Consultations with Isle of Axholme Drainage Board has established that the published flood zones are a derivation of theoretical risk from the Trent (circa 14km away) combined with the unlikely scenario of a complete failure of the pumped systems for the whole of the Isle of Axholme area. Therefore, not regarded as realistic reflection of risk but more an unlikely residual risk to inform development levels. Due to the complete lack of correlation between the flood zones shown in figure 1 and latest modelling predictions shown in Figure 2, a formal Flood Zone challenge has been submitted to the Environment Agency to alter the flood zone designations to a more realistic profile (Appendix A). Based on what we consider to be a more realistic flood zone designation in line with figure 2 the proportion of flood zones are as follows: Page | 5 Site 160 Flood Risk Summary, Oct 2020 BGT-BWB-ZZ-XX-RP-YE-0006_FRTN FZ1 (outside 1 in 1000 year prediction) = 63% FZ2 (between 1 in 100 year and 1 in 1000 year predictions) = 15% FZ3a (within 1 in 100 year prediction) = 22% It should be noted that FZ3b is not separately identified in the published flood zones. As per the flood zone definitions in Table 1 of PPG for FZ3b “Local planning authorities should identify in their Strategic Flood Risk Assessments areas of functional floodplain”. The current Level 1 SFRA does not show the presence of FZ3b in this area and therefore the Environment Agency’s comment about FZ3b under this section titled “Flood Zones” is misleading as it is not defined by a SFRA. That said from our own analysis using topographical and bank level information for the site, no functional floodplain within the site. The functional floodplain predicted to the north of the site will remain as such and would not form part of any planning application. In an Area No We would concur that the currently published Flood Zones do not show this area to be Benefiting benefiting from defences. However the Environment Agency also provide in their summary from to the EIP, output from the Upper Humber Breach model (2016) which suggest flood risk to Defences parts of the site during a breach of the flood defences on the river Don circa 2.5km away. This again places significant doubt on the accuracy and relevance of the published flood zones as the model output clearly suggests that parts of the site are benefiting from the River Don defences. We would also highlight concerns over this particular parameter in the Environment Agency’s summary table as being a yes or no response and that being interpreted as being positive or negative respectively. The proximity to defences is a hugely important supplementary consideration to make under this parameter as the consequential risk to life is much more significant in a breach event closer to the defence. This consideration is featured prominently in the Strategic Flood Risk Assessments for Goole, Hull and many other Level 2 SFRAs across the country, by restricting any form of development within the “Rapid Inundation Zone” and “Danger for All” hazard area, which are generally in areas closest to defences. Page | 6 Site 160 Flood Risk Summary, Oct 2020 BGT-BWB-ZZ-XX-RP-YE-0006_FRTN Therefore, under this parameter and the methodology employed in other Boroughs, we would regard Site 160 to be in a more appropriate location some 2.5km away from the defences compared with say Site 001 which is immediately adjacent to the defences and likely to be in the Rapid Inundation Zone. Flood Events The EA holds no records of From our own investigations and consultations we concur with this statement that there previous flood events at are no records or anecdotal suggestions of previous flooding at the site.
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