Ref: Doncaster
Local Plan
Publication Draft 2019 (For Official Use Only)
COMMENTS (REPRESENTATION) FORM
Please respond by 6pm Monday 30 September 2019.
The Council considers the Local Plan is ready for examination. It is formally “publishing” the Plan to invite comments on whether you agree it meets certain tests a Government appointed independent Inspector will use to examine the Plan (see Guidance Notes overleaf). That is why it is important you use this form. It may appear technical but the structure is how the Inspector will consider comments. Using the form also allows you to register interest in taking part in the examination. All comments received will be sent to the Inspector when the plan is “submitted” for examination.
Please email your completed form to us at
If you can’t use email, hard copies can be sent to: Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster, DN1 3BU.
All of the Publication documents (including this form) are available at: www.doncaster.gov.uk/localplan
This form has two parts: Part A – Personal Details and Part B – Your Comments (referred to as representations) Part A
Please complete in full. Please see the Privacy Statement at end of form.
1. Personal Details 2. Agent’s Details (if applicable) Title Mr Mrs
First Name Alec Diane
Last Name Parkin-Coates Holgate Organisation DCH Consulting (where relevant) Address – line 1 White House Farm 1 Riverside Close
Address – line 2 Bramwith Lane Doncaster
Address – line 3 Barnby Dun
Postcode Doncaster
E-mail Address DN3 1ED DN4 0HW
Telephone Number
Guidance Notes (Please read before completing form)
What can I make comments on?
You can comment (make representations) on any part of the Doncaster Local Plan Publication Version and its supporting documents. These include: Sustainability Appraisal, Habitat Regulations Assessment, Topic Papers and other supporting technical (evidence base) documents. The full list of documents is available at: www.doncaster.gov.uk/localplan. However, this stage is really for you to say whether you think the plan is legally compliant and ‘sound’ (see below ).
Do I have to use the response form?
Yes please. This is because further changes to the plan are for a Planning Inspector to consider during an Examination in Public and providing responses in a consistent format is important. For this reason, all responses should use this response form.
You can attach additional evidence to support your case – but please ensure it is clearly referenced and succinct. The Inspector will decide if further additional evidence is required before or during the Public Examination.
For the inspector to consider your comments, you must provide your name and address with your response. Additional response forms are available online at www.doncaster.gov.uk/localplan
Can I submit representations on behalf of a group or neighbourhood?
Yes you can. Where there are groups who share a common view on how they wish to see the plan modified, it would be helpful for that group to send a single form that represents that view. In such cases the group should indicate how many people it is representing including a list of their names and addresses, and how the representation was agreed e.g. via a parish council/action group meeting, signing a petition, etc. It should still be submitted on this standard form with the information attached.
Question 3 (below) – What does ‘legally compliant’ mean?
Legally compliant means asking whether or not the plan has been prepared in line with statutory regulations, the duty to cooperate and legal procedural requirements such as the Sustainability Appraisal (SA). Details of how the plan has been prepared are set out in the published Consultation Statements and the Duty to Cooperate Statement, which can be found at: www.doncaster.gov.uk/localplan
Questions 4/5 (below) – What does ‘soundness’ mean?
Soundness means asking whether or not it is ‘fit for purpose’ and ‘showing good judgement’. The Inspector will explore and investigate the plan against the National Planning Policy Framework’s four ‘tests of soundness’1. These are:
• Positively prepared - the Plan should be prepared so it meets Doncaster's objectively assessed needs for housing and other development, including infrastructure and business development.
• Justified – the Plan should be based on evidence, and be an appropriate strategy for the Borough when considered against other reasonable alternatives.
• Effective – the Plan should be deliverable and based on effective joint-working on cross-local authority boundary matters as evidenced in a Statement of Common Ground.
• Consistent with national policy – the plan should enable sustainable development and be consistent with the Government's National Planning Policy Framework (NPPF).
Question 8 (below) – Do I need to attend the Public Examination?
You can present your representation at a hearing session during the Public Examination but you should note that Inspectors do not give more weight to issues presented in person than written evidence. The Inspector will use his/her own discretion to decide who should participate at the Public Examination. All examination hearings will be open to the public.
1 Paragraph 35 of Framework: https://www.gov.uk/guidance/national-planning-policy-framework/3-plan-making
Part B
Please complete this Part to make your comments. After this Publication stage, further submissions will only be at the request of the Inspector, based on the matters and issues she/he identifies for examination.
If after reading the Guidance Notes you don’t know how to answer these questions, please contact us at: or
Name / Organisation Name:
1. To which document does your response relate? (Please tick all that apply)
Doncaster Local Plan Publication Draft ☒ Policies Map ☒ Sustainability Appraisal ☐ Habitats Regulations Assessment ☐ Topic Paper? If so, which one(s): ☐ Other Document(s)? If so, which one(s): ☐
2. To which part(s) of the document / map does your response relate?
Page No.: Paragraph: Policy Ref.: Site Ref.: 108 and 147 Policies Map:
3. Do you consider the Local Plan is Legally compliant (including with the Duty to Cooperate)? No ☐ Yes ☒
4. Do you consider the Local Plan is Sound? No ☒ Yes ☐ (If yes, go to Question 6)
5. If you consider the Local Plan is NOT SOUND, is this because it is NOT: (Please tick all that apply)
Positively prepared ☒ Justified ☒
Effective ☒ Consistent with National Policy ☒
6. Please give reasons for your answers to Questions 3, 4 and 5 where applicable. If you believe the Doncaster Local Plan is not legally compliant and/or not sound please provide all the information, evidence and supporting information necessary to justify your comments.
Please also use this box if you wish to comment on any of the documents you marked in Question 1 above.
You can attach additional information but please make sure it is securely attached and clearly referenced.
Introduction
Further to the invitation to make comment on the Publication Draft of the Local Plan for Doncaster, DCH Consulting Ltd, on behalf of our client Mr Alec Parkin-Coates would like to put forward the following comments on the whether the plan is legally compliant and sound and specifically in relation to Barnby Dun and the related draft policies and proposed allocations.
Mr Parkin-Coates put forward his site at the Call for Sites Stage in relation to a potential housing development, in 2002 as a potential mixed-use site and has continued to promote the site
The site is located to the north of White House Farm, Bramwith Road, Barnby Dun. OS Grid Reference 512099 and is local plan reference 108.
Positively Prepared
It is the view of our client that, by Doncaster Council discounting all sites in flood zone 3 and Green Belt sites, they have not prepared the plan positively. The environment agency is continuously re-modelling the flood risk areas and indeed there are areas of Barnby Dun that have been recently re-modelled, reducing the risk from flood zone 3 to 1. This is as a result of the EA understanding more about flood risk in the area and analysis that has been undertaken by technical consultants in respect of specific development sites. There are many Flood Zone 3 sites and Green Belt sites that have blanketly been discounted which have a realistic potential of delivering the development needed for the borough more sustainably than some of the larger sites put forward for allocation.
Justified
Mr Parkin-Coates has promoted his site through the local plan process. The most recent representation is attached. The Council have set out there objectively assessed housing need for Barnby Dun and in order to deliver the dwellings required seek to allocate alternative site ref 147, despite much local opposition.
Our client is of the view that the Council have not considered his site as a reasonable alternative to deliver the housing need for Barnby Dun. Our client’s site is a brownfield site and is of the same flood risk as site 147. Site 147 has not been previously developed and also poses some potentially significant design issues such as access arrangements, impact on the local highway network and visual impact across the countryside.
Site Comparison
Both sites are affected by a high risk of flooding. Both sites are just outside of settlement locations.
Our client’s site is brownfield.
It is therefore our clients view that the Council have not fully justified the strategy based on his site being a reasonable alternative.
Effective
It is questionable whether the plan is deliverable. The plan, in relation to delivering homes, focuses on large scale sites, which are often in multiple ownership (including many of the Council’s own land) and are reliant on major infrastructure improvements. Many of the sites put forward for allocation are to be delivered in the longer term. The NPPF in paragraph 68 states that - Small and medium sized sites can deliver much needed housing development much quicker with less risky investment.
Our client’s site could be classed as a small to medium sized site as around 34% is outside of Flood Zone 3, 10% would be open space as per the open space requirement in addition to the required landscaping and sustainable drainage areas required and potential water compatible uses.
It is therefore put forward that the plan is not effective to deliver the key objectives to maintain a supply of deliverable housing land and the required new homes (18,400) over the plan period.
Consistency with National Policy (NPPF)
The National Planning Policy Framework (As Amended) February 2019 sets out the Governments Planning Policy for England.
The presumption in favour of sustainable development sets out that for plan-making, plans should positively seek opportunities to meet the development needs of their area and be sufficiently flexible to adapt to rapid change. It is clear from recent re-assessment of the flood risks by the EA that the situation in respect of flooding changes rapidly and the initial studies undertaken by our client’s consultant is a positive start to development being safe from flooding. It is considered that our client’s site has not been considered as a reasonable alternative to the site put forward for allocation in that it is a brownfield site and the NPPF places weight on the re-use of brownfield sites. The site put forward is a greenfield site, is currently countryside and flood risk 3 the same as is our client’s site.
Weighing in favour of our client’s site is that the site is previously developed, deliverable, initial flood risk work indicates that the site can be developed, and the implications of flood risk can be mitigated against with further technical design. In addition, the development of our client’s site will have less impact on the local highway network as the site put forward is in an area of known highway network issues and there will be less visual impact on views across the open countryside, our clients site will be seen in context with the new development on the edge of the settlement.
It is on this basis that, in relation to the site specifically, the plan allocation proposed is not consistent with national planning policy when weighed against our client’s site and the selection methodology.
7. What change is necessary to make the Doncaster Local Plan legally compliant and/or sound? Please set out what change(s) you consider necessary to make the Doncaster Local Plan legally compliant or sound – based particularly on how you answered Question 6 relating to the tests of soundness. You need to say why the change(s) will make the plan legally compliant or sound. It will also be helpful if you put forward your suggested revised wording of any policy or piece of text. Please be as precise as possible.
(If you are suggesting that the Plan is both legally compliant and sound – please go to Question 9).
Consider our clients site (108) as a reasonable alternative to the site put forward (147) on the basis that it weighs in favour due to the re-development of a brownfield site, less significant highway and visual impact implications.
8. If your representation is seeking a change, do you consider it necessary to participate at the hearing sessions of the Public Examination? (tick one box only)
No, I do not wish to participate at the examination. I ☐ ☐ Yes, I wish to appear at would like my representation to be dealt with by the Examination. written representation.
If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.
9. If you wish to participate at the hearing sessions, please outline why you feel this is necessary:
Please note: the Inspector will determine the most appropriate way to hear those who wanted to participate at the hearing session.
Date Your 25/09/2019 Signature
Please send your completed form, by no later than 6pm on 30th September 2019, to: • Planning Policy & Environment Team, Doncaster Council, Civic Office, Doncaster DN1 3BU • or email:
Electronic copies of this form are available to download at www.doncaster.gov.uk/localplan
Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice (see link below), which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority. http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy-notice. Hard copies are available on request from:
The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.
Doncaster Local Plan Informal Consultation: Draft Policies and Proposed Sites
RESPONSE FORM
Please respond by 5pm Friday 26th October 2018. We would prefer you to email your completed form to us at If you can’t use email, hard copies can be sent to: Local Plans Team, Planning, Regeneration and Environment Services, Doncaster Council, Civic Office, Waterdale, Doncaster, DN1 3BU.
All of the consultation documents (including this form) are available at: http://www.doncaster.gov.uk/localplan This form has two parts: Part A – Personal Details and Part B – Your Comments
Part A
Please complete in full. Please see the Privacy Statement at end of form.
1. Personal Details 2. Agent’s Details (if applicable) Title Mr Mrs
First Name Alex Diane
Last Name Parkin-Coates Holgate Organisation DCH Consulting (where relevant) Address – line 1 White House Farm 1 Riverside Close
Address – line 2 Bramwith Lane Doncaster
Address – line 3 Barnby Dun
Address – line 4 Doncaster
Postcode DN3 1ED DN4 0HW
E-mail Address
Telephone Number
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For Internal Use Only ID: Rep No:
Part B: What do you wish to comment on? x Policies
x Proposed sites Evidence base x Other
Please provide your comments in the box below (please note there is no limit to the amount of text):
Introduction
Further to the invitation to make comment on the informal consultation stage of the Local Plan for Doncaster preparation, DCH Consulting, on behalf of our client Mr Alex Parkin-Coates would like to put forward the following comments on the proposed site specifically in relation to Barnby Dun and the related draft policies and evidence base.
Mr Parkin-Coates put forward his site at the Call for Sites Stage in relation to a potential housing development and also in 2002 as a potential mixed-use site.
The site is located to the north of White House Farm, Bramwith Road, Barnby Dun. OS Grid Reference 512099 and is local plan reference 108.
Site Location
The site is located to the north of Barnby Dun. Barnby Dun is the largest village in Doncaster which lies to the east of the River Dun Navigation and just outside of the Doncaster Main Urban Area.
The site forms part of the same parish as Kirk Sandall, which forms part of the Main Urban Area. Barnby Dun is around 20 minute’s walk to the train station in Kirk Sandall.
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Fig 1 – Site location – Taken from Google Maps
The Site
The site is approximately 7.151 ha of land and is currently grazing land and part of the agricultural holding.
Part of the land is defined as ‘brownfield’ as it has been previously developed in association with the agricultural holding.
The land is bound to the north by the existing minerals railway land, Bramwith Lane to the east, the River Dun Navigation and the White House View housing estate.
The site consists of various dwellings, agricultural buildings, curtilages, access roads and hard standings.
There is an existing highway connection laid out leading from White House View providing a connected route to the site. Below is an aerial image of the site showing the potential access and existing buildings.
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Fig 2 – White House Farm – Taken from Google Maps
Current Site Allocation
The site is currently allocated as Countryside Policy Area as defined by the Doncaster Unitary Development Plan 1998.
Fig 3 – Taken from Doncaster Council Interactive UDP Map
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Emerging Local Plan
The emerging Local Plan identifies Barnby Dun as one of the 10 Service Towns/Villages. The proposed housing allocation for the village is 105 new homes over the plan period to 2032.
The main physical and policy constraints in order to grow the village are Flood Risk and Countryside. Barnby Dun is affected by Flood Risk 3, a high risk of flooding with the exception of the central area which is flood zone 1, a low risk of flooding.
Fig 4 – Flood Map for Planning
The site is part Flood Zone 3 and part Flood Zone 1.
Barnby Dun Village is surrounded by Countryside Policy Area as defined by the Unitary Development Plan 1998, which the Council state will need to be reviewed as part of the Doncaster Local Plan. The National Planning Policy Framework states in paragraph 155 that new development should be directed away from areas at high risk of flooding and be safe for its life time without increased flood risk elsewhere.
The aim of the sequential test is to steer new development to the lowest flood zones. The majority of the land surrounding Barnby Dun is in Flood Zone 3.
It is considered that the site would provide wider sustainability benefits for the community. Site 108 is accessible to the centre of the village and to sustainable transport options. Site 147 is located away from the heart of the village with limited access to public transport choices.
The nearest water course is the canal which is a controlled water source. The River Don is to the south west of the site and has the benefit of defences.
A site-specific flood risk assessment is being prepared to demonstrate that the development of the site can be safe for a lifetime and without increasing flood risk elsewhere.
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Proposed Sites
Fig 5 – Local Plan Housing Site Selection for Barnby Dun
The Council state that there is a requirement of 105 dwellings for Barnby Dun. There have been 7 sites put forward for Barnby Dun. 6 of which have ben rejected. The site the subject of this consultation response is referenced 108 and rejected for the following reasons:
Rejected Housing Site – Although around 34% of the site’s area is not within a high flood risk zone (Flood Risk Zone 3) the part of the site that is low flood risk ‘may’ not be sufficient to provide the settlement’s remaining housing target and makes less sense in urban form compared to site 147.
Site 147 has been supported on the basis of the following:
Around 42% of the site’s area is not within an area of high flood risk (Flood Risk Zone 3) so the site is being proposed to be allocated, but with a reduced site capacity of 98 units (total site could accommodate 266 new homes) which would mean no more vulnerable residential development will be directed to an area of high flood risk and no requirement for the flood risk exception tests therefore. Although water compatible uses such as public open space and landscaping are appropriate in the part of the site that is flood risk zone 3 (subject to wider Planning considerations) so this is estimated as being a fairly cautious capacity
Site Comparison
Both sites are affected by a high risk of flooding. Both sites are just outside of settlement locations.
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Reasons in Favour of site 108
Conserving and enhancing the natural environment
Paragraph 170 of the NPPF states that planning policies should contribute to and enhance the natural and local environment by a) protecting and enhancing valued landscapes, b) recognising the intrinsic character and beauty of the countryside, d) minimising impacts on and providing net gains in biodiversity,
Site 108 is bound to the north by the minerals railway line which provides a defensible boundary to prevent encroachment of the settlement into the open countryside. Site 147 has no defensible boundary and has the potential to have a detrimental impact on the landscape visual impact on the countryside and much wider impact on views. Longer term encroachment could lead to the merger towards Stainforth in the North. Stainforth is part of the Main Town proposal with Hatfield, Dunsville and Dunscroft, of which there is significant planned growth.
Should there be no market interest in the longer term for the DN7 development to the east of Stainforth (the majority of which is also located in Flood Zone 3), the planned growth proposed by the Local Plan may materialise in other areas, such as the south-west of Stainforth and west of Dunscroft, which will have a significant adverse impact on the urban form and character of the countryside, placing a longer-term likelihood of the merger of Barnby Dun with Stainforth and Dunscroft.
In terms of the location of site 108, the next neighbouring settlements to the north of Barnby Dun is Kirk Bramwith and Thorpe in Balne, both of which are small villages not planned for growth. Both villages are also separated from Barnby Dun by permanent physical defensible boundaries such as water courses or railway lines. Therefore, to develop site 108 would not result in longer term concerns in relation to coalescence or encroachment into the open countryside.
Whilst the potential number of dwellings deliverable on site 108 are less in the short term than site 147, the longer-term implications make site 147 less sustainable. Paragraph 68 of the revised 2018 National Planning Policy Framework (NPPF) states that small and medium sized sites can make and important contribution to meeting the housing requirement of an area and are often built out relatively quickly. Therefore, site 108 will be deliverable in the shorter term.
Whilst the NPPF encourages development to be steered to sites at less risk of flooding, technical methods of construction are evolving, and mitigation measures mean that development on sites of medium or higher risk of flooding can be made safe in the longer term.
There are fewer planning tools to prevent the merger and coalescence of growing settlements where there are no defensible boundaries than there are technical and mitigation measures to ensure a development is safe from flooding.
NPPF Paragraph 117 states the planning policies should promote an effective use of land in meeting the need for homes and other uses, whilst safeguarding the environment and ensuring safe and healthy living conditions. Site 106 is ‘brownfield’ and whilst its current and previous use is agricultural there are is no evidence that the site is contaminated.
NPPF Paragraph 180 states that planning policies should ensure that new development is appropriate for its location taking into account cumulative impacts in relation to pollution on health, living conditions and the natural environment. In doing so tranquil areas should be identified and protected remaining relatively undisturbed. The occupiers surrounding site 147 are used to a semi-rural or low-density housing environment. Site 108 is close to the centre of the settlement and has activity along the navigation canal. In addition, light
7 pollution will be significantly realised across the landscape with a 98-house development across the open countryside with no or limited physical landscape features to distract the impact.
Urban Form
Site 108 consists of brownfield land, the settlement of Barnby Dun has expanded to the north of the village in the form of larger aspirational homes. The site lends its self to a quality development that can be well landscaped and with water compatible uses on areas of the site that are higher flood zone.
In Paragraph 122 of the NPPF, planning policies should support development that makes efficient use of land whilst taking account of identified needs for different types of housing and the land suitable for accommodating it.
Fig 6 – Image taken from Google maps showing potential settlement boundary
Potential Homes
The Council’s view is that 34% of site 108 is in a low flood zone. This equates to approximately 2.43 ha of land, at a density of 30 dwelling per hectare could provide a housing site of around 73 dwelling. 30 dwellings per hectare would deliver the potential for aspirational homes or good quality family dwellings of which the Borough is in need of particularly in the aspirational towns and villages close to the main urban area. Paragraph 122 of the 2018 NPPF, states that planning policies should support development that makes efficient use of land taking account of the importance of (e)securing well designed, attractive, healthy places.
Whilst on this basis site 108 would deliver 25 dwellings less than the 98 units that the Council feel that site 147 has the potential to deliver, on balance, taking into account the potential impact on the Countryside and future encroachment as a result of proposing site 147 it is our view that site 108 is preferable and more sustainable in the longer term.
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Fig 7 – Image taken from Google Maps showing potential encroachment and impact on visual amenity of the open countryside
Subject to the outcome of the site-specific flood risk assessment there is potential for a greater number of dwellings on the site which will include adequate mitigation measures and a safe evacuation route to a main road.
It is considered that site 108 would deliver a good use of land at a density that is appropriate to the village character. A larger site delivering the whole of the housing target is likely to deliver a development that is uncharacteristic with the settlement character.
Other considerations
Community Objection
There have been significant local objections since the Site Selection consultation has been publicised with a public display of site notices objecting to the site.
Highways and Infrastructure
Highways considerations form a significant amount of objection in relation to the promotion of site 147. The most direct route for a potential development at site 147 will be via Pine Hall Road connection with Station Road onto Doncaster Road, toward the main urban area in the south. Pine Hall Road is long narrow low use residential street. Whilst site 108 would require access along a short section of a lower hierarchy road within the network, the design and layout of the existing route would control traffic speeds until such a point where the route connected with Church Road. Church Road is the main route through the village, directly connecting with Top Road and Station Road. All of which are main routes for public transport and local facilities.
Hatfield Lane and Pine Hall Road have limited access to public transport and local facilities.
Paragraph 122 of the 2018 NPPF states that planning policies should support development that makes good use of land whilst taking into account (c) the availability and capacity of infrastructure and services. In supporting site 147 this decision has not taken account of the impact on the capacity of the infrastructure and local services. Site 108 is closer to the heart of the settlement and better served by local facilities within walking distance and as such should be considered more favourable.
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Archaeology
Site 147 is close to the Botany Bay Farm, Botany Bay Lane, Barnby Dun, of which was in an area of a shrunken medieval village. Whilst previous watching briefs associated with development proposals did not find any trace of the settlement in excavations, the DN area has major archaeological implications of regional importance, whilst site 108 was deemed to have negligible but unknown implications in terms of archaeology as per the Scoping Study by Arc Heritage dated March 2016 for the Site Allocations for the Doncaster Local Plan.
Conclusion
Site 108 is more favourable to deliver housing growth within the village of Barnby Dun for the following reasons:
• The site is brownfield; Environmental • The site can deliver around 73 aspirational quality homes; Social • The site is a sustainable location close to the village centre and access to public transport; Economic • The site poses less highway and traffic implications than alternative sites; Economic • The site has a defensible boundary and will not result in encroachment into the countryside; Environmental • The site has a safe evacuation route through a lower flood zone; Environmental • The site can include water compatible landscaping and open space; Environmental • The site is within walking distance to the local primary school and a development of 73 ‘family’ homes would contribute towards school places; Social • The site is likely to be unaffected by heritage assets; Environmental • There are significant objections to the alternative site. Social
A site-specific flood risk assessment is being prepared for the site to supplement this consultation response. This will be forwarded to the Council once completed.
Paragraph 32 of the National Planning Policy Framework states that alternative options which reduce or eliminate significant adverse impacts should be pursued. It is considered that site 108 is an alternative that should be pursued as it is an option that has less adverse impact than site 147 proposed as a preferred site.
Paragraph 9 of the NPPF states that planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.
It is clear that there is local objection to the proposition of the alternative site for housing development, site 108 reflects the character, needs and opportunities required for Barnby Dun and on behalf of Mr Parkin- Coates, DCH Consulting request that the Council take account of this response to the consultation and carefully consider the implications of the site currently site 147 in favour of supporting site 108.
Privacy Notice The Council is committed to meeting its data protection obligations and handling your information securely. You should make sure you read and understand the Planning Services privacy notice, which sets out what you need to know about how Doncaster Council will use your information in the course of our work as a Local Planning Authority.
10 http://www.doncaster.gov.uk/services/the-council-democracy/planning-service-privacy- notice
The Council reserves the right not to publish or take into account any representations which are openly offensive or defamatory.
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TECHNICAL NOTE
Job Name: White House Farm, Doncaster Job No: 45002/4001 Note No: 45002/4001/TN001 Date: January 2019 Prepared By: Mark Isherwood Subject: Flood Risk Appraisal
1. Introduction
PBA, now part of Stantec has prepared this Technical Note (TN) to confirm the flood zone classification for the site at White House Farm, provide preliminary advice on any constraints to emerging development proposals, advise the project team on any mitigation measures which may need to be implemented at the site and advise of any additional site specific work needed to be undertaken in support of a planning application.
The findings of this TN are based on data available at the time of the study, and on a high-level assessment that has been undertaken to date. The findings of this TN may be subject to change following receipt of further data supplied by the statutory authorities.
This TN is not a Flood Risk Assessment (FRA) and is not suitable for planning purposes. All proposals with respect to flood risk and drainage are subject to agreement with the Environment Agency (EA), Local Planning Authority (LPA), and Lead Local Flood Authority (LLFA).
2. Site Location
The site is located at White House Farm on Bramwith Lane in Barnby Dun, Doncaster; and is currently vacant greenfield land. The site lies immediately to the west of Bramwith Lane, is bounded to the south by residential properties and White House View, to the west by the River Dun Navigation and to the north by a railway line. The site is located at National Grid Reference (NGR) 509070 (E) 154410 (N) and has an area of approximately 7.52 hectares. A site location plan is shown in Figure 1 below.
The site lies immediately adjacent to the River Dun Navigation, a canalised channel controlled by the Canal and Rivers Trust (CRT) to the west, which flows in a northerly direction. The River Don, an EA designated ‘Main River’, is located approximately 100m west of the site and flows in a northerly direction. Both the River Dun Navigation and River Don confluence with the Humber approximately 20km north-east of the site. A further un-named Ordinary Watercourse flows in a northerly direction through the centre of the site.
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Page 1 of 13
TECHNICAL NOTE
River Dun Navigation
Site Location
River Don Un-named Ordinary Watercourse
Contains Ordnance Survey data © Crown Copyright and database right 2017 Figure 1: Site Location Plan
From review of LiDAR topographical data (typical accuracy +/-150mm) it is noted that the site falls from a high point of approximately 9.8m AOD in the centre of the site to an approximate low point of 4.5m AOD at the western boundary. The site also falls slightly from the centre to the east with a low point in the north-east corner of the site of approximately 6.9m AOD. A LiDAR plan is included as part of Appendix A.
3. Overview of Flood Risk
3.1 Strategic Flood Risk Assessments (SFRAs)
The 2015 ‘Level 1’ Doncaster Metropolitan Borough Council (DMBC) SFRA confirms that the majority of the site is located within Flood Zone 3a ‘High Probability’ (floodplain), as shown in Figure 2 below (and not Zone 3b (functional floodplain)). The SFRA also confirms that there is a band of Flood Zone 1 through the centre of the site.
The ‘Level 1’ DMBC SFRA indicates that most of the site, except for the far north-west corner of the site, lies within an area where 75% or greater is susceptible to groundwater flooding. The site is therefore considered as being at a moderate risk of groundwater flooding.
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TECHNICAL NOTE
Site Location
Figure 2: Flood Map extract from Appendix A of DMBC Level 1 SFRA
A ‘Level 2’ DMBC SFRA (2010) was released to better understand the residual flood risks within the borough. To do so, detailed 1D-2D modelling was used to assess the impacts of both overtopping and failure (breach) of the existing flood defences. The Level 2 SFRA seeks to assess sites allocated in the DMBC Local Plan and as the site is not part of an allocation, no further site specific flood risk information is included.
3.2 Online Flood Maps
The following information has been taken from the PBA GIS flood maps outputs (December 2018) provided in Appendix A, based on the EA Opendata datasets available online, and reproduced with Ordnance Survey (OS) mapping under licence to PBA (appended).
• The site lies predominantly within Flood Zone 3 (defined as having a ‘High Probability’ of flooding from the rivers and sea), with an area through the centre of the site which is located within Flood Zone 1 (defined as having a ‘Low Probability’ of flooding from the rivers and sea).
• The site is identified as mostly having a ‘Very Low’ risk (1 in 1,000 (0.1%) annual probability) of surface water flooding with a significant area to the north-west of the existing building noted as being at a ‘Low’ and ‘Medium’ risk (between 1 in 100 and 1 in 1000 (1%-0.1%) annual probability and between a 1 in 30 and 1 in 100 (3.3% - 1%) annual probability respectively). These ‘Low’ and ‘Medium’ risk areas have flood depths between 300mm and 900mm. There are further areas within the site shown by the mapping to be at significant risk of surface water flooding at over 900mm flood depth, however these areas are attributed to the presence of the Ordinary Watercourse in the centre of the site.
• The site is not shown to be within the extents of flooding from the residual risk of a reservoir breach.
3.3 EA Product 4 Data
EA Product 4 data has been obtained as part of consultation with the EA. A Flood Map for Planning was received as part of this consultation as shown in Figure 3 below.
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TECHNICAL NOTE
Site Location
© Environment Agency copyright and / or database rights 2017. All rights reserved. © Crown Copyright and database right. All rights reserved. Environment Agency, 100026380, 2017. Figure 3: Product 4 Flood Map for Planning
The Product 4 data includes modelled flood levels of the River Don from the Lower River Don Flood Modelling Study completed by JBA in August 2009. It is noted that the Lower Don Flood Model was developed considering the presence of flood defences along the River Don and Ea Beck as was at the time of modelling. It is further noted that the River Don is considered fluvial at this location.
The EA also provided information relating to the 2016 Upper Humber Flood Risk Mapping Study, however the model domain for this study finishes at the railway north of the site and therefore this model has not been considered further.
It should be noted that some data has not been provided by the EA as a result of the hydraulic modelling for the Middle and Lower Don currently being updated and is not yet available for release. This study has therefore been based on data available at the time of writing and should be reviewed prior to any planning application being submitted.
The EA modelled in-channel flood levels for the River Don are provided in Table 1 and the node point map is provided in Figure 4 below. The EA has not been able to provide modelled flood levels for the range of climate change allowances required for the Humber region as set out in the guidance document ‘Flood Risk Assessments: Climate Change Allowances’ (February 2016).
Table 1: 2009 Lower River Don In-Channel Modelled Flood Levels
Modelled Flood Level (mAOD) 1 in 200 1 in 100 (1%) plus 1 in 25 (4%) 1 in 100 (1%) (0.5%) Climate Change Annual Annual Annual Annual Probability Probability Probability Probability Node DON01_3604 8.426 8.496 8.530 8.522 Node DON01_3175u 8.309 8.375 8.406 8.399
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TECHNICAL NOTE
© Environment Agency copyright and / or database rights 2017. All rights reserved. © Crown Copyright and database right. All rights reserved. Environment Agency, 100026380, 2017. Figure 4: EA Node Point Map
Based on the flood level of 8.399m above and available LiDAR information, the site could be affected by flood depths of up to 4m within the area of the site within Flood Zone 3 in the west and up to 1.4m within the area of the site within Flood Zone 3 in the north-east of the site.
It is understood from the Product 4 data that the River Don defences at this location have a defence crest level ranging from 10.08 mAOD to 10.24 mAOD and as such, it is confirmed that the defences provide protection in the 1 in 100 (1%) annual probability event and are defined as fluvial/tidal defences.
Based on the flood levels above the Flood Zone 3 extent on-site has been confirmed by comparing the 1 in 100 (1%) Annual Probability flood level with LiDAR topographical data; a site specific Topographical Survey is recommended in order to provide a more accurate comparison. The extent of Flood Zone 3 on-site, as illustrated by the blue line, is presented in Figure 5 below. This exercise confirms the extent presented on the EA Flood Map for Planning as shown in Figure 3; i.e. there is a band through the centre of the site within Flood Zone 1 with the remainder of the site located entirely within Flood Zone 3.
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TECHNICAL NOTE
Site Location
Flood Zone 3 Extent
Contains Environment Agency information © Environment Agency and database right
Figure 5: Flood Zone 3 extent and LiDAR comparison
It is important to emphasise that based on the information provided by the EA, the flood levels associated with the River Don do not exceed the crest levels of the defences along the reach of the Don in the vicinity of the site. Therefore, it could be argued that the site is considered to benefit from defences located along the River Don. As such, it is considered the site is at a residual risk of flooding as a result of defence breach.
Note, the EA are currently undertaking a modelling update in this area as part of a further ‘Middle and Lower Don Modelling Study’ with the full model expected to be available in the late winter / early spring 2019. Therefore, results discussed in this TN based on the existing 2009 model are subject to change. This updated model may also provide further information on the interaction between the River Dun Navigation and the River Don.
Should this updated modelling continue to show that the River Don defence crest levels exceed the modelled flood levels on-site, and if the Flood Zone classification does not change, then a formal flood map challenge would need to be submitted to allow for a formal re-classification. Please note a whilst a flood map challenge may result in an alteration of the Flood Zone classification, it can require extensive hydraulic modelling and consultation with the EA and does not guarantee a successful outcome.
It is therefore recommended that consultation is undertaken with the EA in spring 2019 to confirm the Flood Zone classification following the release of the Middle and Lower Don Modelling Study.
It is important to note that the EA have provided two records of historic fluvial flooding on-site from June 2007 and Autumn 2000, which reached in-channel flood levels, along the reach of the River Don adjacent to the site, of 8.39m AOD and 8.75m AOD respectively. Based on LiDAR topographical data for the site, this would have resulted in peak flood depths on-site of 3.99m and 4.35m respectively ignoring defences.
The full EA consultation response containing the above information is provided in Appendix B.
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TECHNICAL NOTE 3.4 Climate Change
It is a requirement of the National Planning Policy Framework (NPPF) and accompanying Planning Practice Guidance (PPG) that the projected impacts of climate change upon the 1 in 100 (1%) annual probability event over the lifetime of the development are considered in the assessment of flood risk. There is a potential risk that, in the future, the site could be impacted by fluvial/tidal flooding due to the projected impacts of climate change, which are expected to lead to increased flows.
Current projected climate change allowances on fluvial flows are set out in Table 1 of the EA guidance ‘Flood Risk Assessments: Climate Change Allowances’ (February 2016).
The EA guidance states that for development in Flood Zone 1 the ‘Central’ allowance should be considered for ‘More Vulnerable’ developments. For development within Flood Zone 3a the ‘Higher Central’ and ‘Upper end’ allowances should be considered for ‘More Vulnerable’ developments. On this basis, with reference to Table 1 of the guidance, for ‘More Vulnerable’ development proposals within the Humber Region, peak river flow allowances of +20% (‘Central Estimate’), and +30% (‘Higher Central Estimate’) to +50% (‘Upper end Estimate’) should be considered with respect to fluvial flood risk for areas within Flood Zone 1 and Flood Zone 3 respectively.
The existing modelling provided by the EA in their Product 4 consultation response includes modelling of the 20% climate change allowance and could not provide any further information on the 30% or 50% allowances.
The use of a stage-discharge relationship was investigated in order to provide an estimate of the 1 in 100 (1%) annual probability plus 30% climate change allowance and the (1%) annual probability plus 50% climate change allowance. However, a stage-discharge relationship requires existing modelled flow rates for a 1 in 100 (1%) annual probability plus 20% climate change allowance return period in order to extrapolate the climate change allowance, however in this case, this data is not available, as confirmed by consultation with the EA as provided in Appendix B. As such, any statistical analysis undertaken to estimate the 1 in 100 (1%) annual probability plus 30% climate change allowance and the (1%) annual probability plus 50% climate change allowance is not considered representative of the actual scenario.
It is recommended that defining the 1 in 100 (1%) annual probability plus 30% climate change allowance and the (1%) annual probability plus 50% climate change allowance flood levels on-site, is re-visited on production of the EA’s updated ‘Middle and Lower Don Modelling Study’. It is further noted that this updated modelling study is still not guaranteed to provide the appropriate climate change allowances or alter the flood zone classification of the site. Should this updated model still not account for the appropriate climate change allowances, a further hydraulic modelling study will be required in order to define the climate change flood level at the site.
Note, following the recent publication of UKCP18, the EA climate change guidance is understood to be in the process of being updated shortly. As such, any recommendations will need to be reviewed when this guidance is updated.
3.5 Risk of Flooding from Canals and other Artificial Watercourses
The site lies immediately adjacent to the River Dun Navigation, a canalised channel controlled by the Canal and CRT to the west.
CRT have confirmed the following:
• There have been several flooding incidents from overtoppings of the River Dun Navigation in the area in the past relating to the mechanics of the River Don / River Dun Navigation system. Full details can be found within the CRT response included in Appendix B.
• Majority of the risk from the River Dun Navigation relates to: i. Defence failure at Bramwith Lock and the north end of the River Dun Navigation. However, a direct flow path from this area to the site is considered unlikely. Furthermore, as part of
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TECHNICAL NOTE their response, CRT note that across the UK breaches only occur on an average rate of three per year. The risk is therefore considered low. ii. Potential failure of flood gates at Doncaster Lock in a river flooding situation.
• Record of significant flooding at Barnby Dun Bridge area when a flap valve owned by the Environment Agency failed to close. They note that there are several culverts under the canal with flap valves at their connection to the river and that these have two risks; firstly, backflow from the river should the door fail to seal; secondly localised flooding should they not be able to discharge when the river is in flood.
3.6 Risk of Flooding from Ordinary Watercourse
Review of the online Risk of Flooding from Surface Water (RoFSW) map has indicated that the risk of flooding from the Ordinary Watercourse located within the site is mostly confined to the watercourse channel, as shown in Figure 6 below.
Review of LiDAR topographical information suggests that this is likely due to the topographical level of the Ordinary Watercourse in relation to the topographic levels of the surrounding site; i.e. the site rises steeply in both directions from the location of the Ordinary Watercourse channel.
As such, the risk of flooding from the Ordinary Watercourse is considered to be low.
Contains Environment Agency information © Environment Agency and database right
Figure 6: online RoFSW Map
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TECHNICAL NOTE 3.7 Risk of Flooding from Other Sources
The online Risk of Flooding from Reservoirs map indicates the site is not considered at risk in the event of reservoir breach. No information has been made available on flood risk from sewers or water mains.
4. Stakeholder Consultation
In addition to provision of the Product 4 data as discussed in Section 3.3 above, the EA (Yorkshire Area) has also provided the following information:
• There was historic fluvial flooding on-site in June 2007 – the extent of this flooding is included in Appendix B;
• Confirmation that the watercourse within the site is classed as an ‘Ordinary Watercourse’;
• Confirmation that the River Dun Navigation is classed as an ‘Ordinary Watercourse’.
• The site is not within an EA Flood Warning area;
• There are no further planned flood defence works within the next 10 years within the area; and
• Regarding groundwater flooding, the site is located within the ‘Aire & Don Sherwood Sandstone’ groundwater body on a Principal Aquifer which has a medium vulnerability and within Source Protection Zone (SPZ) 3. However, due to complexity of mapping risk of flooding from groundwater in the area, the EA does not hold any information relating to groundwater flooding in the area.
• It is further noted that the East Midlands EA Operational Unit was also contacted as part of this work, however at the time of writing a response has not been received. Any response is considered unlikely to impact upon the report; however, an update will be provided on receipt of this information.
In addition to consultation with the EA, as discussed above and in Section 3.3, DMBC (as the LLFA) and the CRT were also consulted. Copies of these consultation responses are provided in Appendix B.
DMBC have confirmed the following:
• The watercourse located within the site is classed as an ‘Ordinary Watercourse’;
• A minimum 10m ‘byelaw distance’ is required from both banks of the Ordinary Watercourse, no development will be permitted within 10m of the top of the river bank without the prior written approval of the Local Planning Authority (LPA) or LLFA.
• Historic flooding has occurred at the site; no further information was provided; and,
• There were reports in 2007 of surface water flooding at Bridge House at the Grove, Barnby Dun which is located approximately 125m south of the site.
5. NPPF Vulnerability Classification and Sequential Test
NPPF PPG ‘Flood Risk and Coastal Change’ Table 2 confirms the ‘Flood Risk Vulnerability Classification’ of a site, depending upon the proposed land usage. This classification is subsequently applied to PPG Table 3 to determine whether:
• The proposed development is suitable for the Flood Zone in which it is located; and
• Whether an Exception Test is required for the proposed development.
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TECHNICAL NOTE The NPPF follows a sequential risk-based approach in determining the suitability of land for development in flood risk areas, with the intention of steering all new development to the lowest flood risk areas. The NPPF encourages the application of the ‘sequential approach’ in the master-planning process for new development, i.e. locating the more sensitive/vulnerable elements of new development in the areas which lie at lowest probability of flooding and, conversely, reserve the areas of the site at greatest risk of flooding for the least vulnerable elements of the development.
The Sequential Test is a planning-led exercise to demonstrate that there are no ‘reasonably available alternative sites’ for the development at lower probability of flooding. As the site is located in Flood Zone 3 ‘High Probability’, the Sequential Test is required.
As the site is located within Flood Zone 3a, the Exception Test will also be required to demonstrate the ‘wider sustainability benefits which outweigh the risk of flooding’ of any development and that appropriate measures can be included to demonstrate the development can be made safe from flooding for its lifetime.
6. Mitigation Requirements
Standard requirements for ground floor levels of new development are set out in BS8533:2011 ‘Assessing and managing flood risk in new development – Code of practice’. This recommends floor levels are set a minimum of 300mm above the modelled 1 in 100 (1%) annual probability plus appropriate allowance for climate change flood level.
However, consultation with the EA as provided in Appendix B, has stated that for this area in Flood Zone 3 finished floor levels should be set no lower than 600mm above the 1 in 100 (1%) annual probability plus climate change modelled flood level.
With the current absence of the modelled 1 in 100 (1%) annual probability plus 30% climate change allowance and the (1%) annual probability plus 50% climate change allowance and the lack of data to be able to undertake a stage-discharge relationship assessment, appropriate finished floor levels cannot currently be defined. It is recommended that the exercise is re-visited on publication of the EA’s updated further ‘Middle and Lower Don Modelling Study’, as discussed in Section 3.3. As discussed, should this updated model still not account for the appropriate climate change allowances, a further hydraulic modelling study will be required in order to define the climate change flood level at the site. In accordance with the EA guidance, the ground floor level of proposed buildings should then be set at this level plus an additional 600mm.
Any new development located in the vicinity of a watercourse should be constructed such that it does not detrimentally impact on flow routes or reduce the available floodplain storage over the site; either of which could potentially cause an increase in flood levels on-site or elsewhere.
As the River Don is fluvial at this location, any built development within the Flood Zone 3 extent will require compensatory flood storage volume to be provided on a level-for-level, volume-for-volume basis. Given that most of the site and the surrounding land is located within Flood Zone 3, providing this compensatory flood storage volume may be a constraint to development. It is further noted that once the climate change extents are fully determined, compensatory flood storage will need to be provided on a volume for volume basis for these climate change scenarios; it is considered likely that these extents will impact on most of the site.
For any built development located within the Flood Zone 3 extent, dry access for ‘More Vulnerable’ uses (i.e. residential development) should be provided in addition to dry vehicular access that enables the voluntary and free movement in the event of a flood. If this is not feasible, safe access in accordance with EA/DEFRA FD2320 guidance should be applied.
7. Summary
The Level 1 SFRA for the area indicates the site lies predominantly within Flood Zone 3a ‘High Probability’ with an area of Flood Zone 1 ‘Low Probability’ located central to the site. Development over the site is acceptable in principle, subject to the Sequential Test and the Exception Test.
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TECHNICAL NOTE Comparison of EA modelled flood levels derived from the 2009 Lower River Don Modelling Study and freely available LiDAR topographical information has confirmed the Flood Zone extents shown on the online Flood Map for Planning are broadly accurate.
The EA has confirmed that historic fluvial flooding of June 2007 impacted the site.
In the current absence of the modelled 1 in 100 (1%) annual probability flood level including appropriate climate change allowance (plus 30%-50%) and the lack of data to be able to undertake a stage-discharge relationship assessment, appropriate ground floor levels cannot currently be defined. In order to define the 1 in 100 (1%) annual probability plus 30% and plus 50% climate change allowance flood levels on-site, it is recommended that defining flood risk to the site is re-visited on production of the EA’s updated ‘Middle and Lower Don Modelling Study’. It is further noted that this updated modelling study is still not guaranteed to provide the appropriate climate change allowances. Should this updated model still not account for the appropriate climate change allowances, a further hydraulic modelling study will be required in order to define the climate change flood level at the site.
Any built development within the Flood Zone 3 extent will require compensatory flood storage volume to be provided on a level-for-level, volume-for-volume basis. Furthermore, dry access for ‘More Vulnerable’ uses (i.e. residential development) should be provided in addition to dry vehicular access that enables the voluntary and free movement in the event of a flood.
Due to the complexity of flood risk to the site, it is highly recommended that the next stage of work should constitute meeting with the EA for detailed pre-application consultation.
DOCUMENT ISSUE RECORD Reviewed Approved Technical Note No Rev Date Prepared Checked (Discipline Lead) (Project Director) 45002/4001/TN001 - 02/01/19 MI HR HR SD
Peter Brett Associates LLP disclaims any responsibility to the Client and others in respect of any matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence within the terms of the Contract with the Client and generally in accordance with the appropriate ACE Agreement and taking account of the manpower, resources, investigations and testing devoted to it by agreement with the Client. This report is confidential to the Client and Peter Brett Associates LLP accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk. © Peter Brett Associates LLP 2018 Peter Brett Associates LLP 61 Oxford Street Manchester M1 6EQ T: E:
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TECHNICAL NOTE
Appendix A: PBA GIS maps
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Site Boundary
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0 250 500 Client 1:5,000 @ A3 WHITE HOUSE FARM m Site Location Mr A Parkin-Coates 13/12/18 Contains Ordnance Survey data (c) Crown copyright and database right 2016. Drawn: TL
Checked: MI Figure 001 Rev A
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boundary
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0 250 500 Client 1:5,000 @ A3 WHITE HOUSE FARM m Site Location (Aerial Photography) 13/12/18 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Mr A Parkin-Coates Community Drawn: TL Contains Ordnance Survey data (c) Crown copyright and database right 2016. Checked: MI Figure 002 Rev A
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boundary 0.0m - 2.0m AOD 2.0m - 4.0m AOD 4.0m - 6.0m AOD 6.0m - 8.0m AOD 8.0m - 10.0m AOD 10.0m - 12.0m AOD 12.0m - 14.0m AOD
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0 250 500 Client 1:5,000 @ A3 WHITE HOUSE FARM m Area Topography 13/12/18 Contains Environment Agency information © Environment Agency and/or database right Mr A Parkin-Coates Contains Ordnance Survey data (c) Crown copyright and database right 2016. Drawn: TL
Checked: MI Figure 003 Rev A
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boundary Main River Areas Benefiting from Flood Defences Flood Zone 3 Flood Zone 2 Flood Zone 1
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0 250 500 Client 1:5,000 @ A3 WHITE HOUSE FARM m EA Flood Zone 14/12/18 Contains Environment Agency information © Environment Agency and/or database right Mr A Parkin-Coates Contains Ordnance Survey data (c) Crown copyright and database right 2016. Drawn: TL
Flood Zones refer to the probability of river and/or sea flooding, ignoring the presence of defences Checked: MI Figure 004 Rev A
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Mr A Parkin-Coates Site Boun Site dary RiskofFlooding from Surface Water H igh – 1 in 30 Ann30 in 1 High– ual Probability MediumAnn100 in 1 – ual Probability Lo w – 1 in 1000 Ann1000Lowin 1 – ualProbability V ery Low - Less1000Veryin Low1than - Ann ualProbability
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0 250 500 Client @ A31:5,000 WHITEHOU SEFARM m EASurface Water Flood Risk ConEnviron tains mAgency ent inform © ationEnviron mAgency ent anddatabase right 13/12/18 ConOrdnance tains SurveyCrown (c) data copyright anddatabase 2016. right MrParkin-CoatesA Drawn:TL Mapsbased on EAupdated ‘Flood Map for Surface Water’(‘uFMfSW’) releasedof nation aiteration latest 2013as scalealinthe surfacewatermodelling exercise Checked:MI Figure005 RevA
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boun Site dary RiskofFlooding from Surface Water - Depth - Below150m m 150 - 300m - 150 m 300 - 600m - 300 m 600 - 900m - 600 m 900 - 1200m - 900 m Over1200m m
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0 250 500 Client @ A31:5,000 WHITEHOUSE FARM m EASurface Water Flood DepthRisk - ConEnviron tains mAgency ent inform © ationEnviron mAgency ent anddatabase right MrParkin-CoatesA 13/12/18 ConOrdnance tains Survey Crown (c) data copyright anddatabase 2016. right Percent Chance3.3 Drawn:TL Mapsbased on EAupdated ‘Flood Map for Surface Water’(‘uFMfSW’) releasedof nation aiteration latest 2013as scalealinthe surfacewatermodelling exercise Checked:MI Figure005a RevA
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boun Site dary RiskofFlooding from Surface Water - Depth - Below150m m 150 - 300m - 150 m 300 - 600m - 300 m 600 - 900m - 600 m 900 - 1200m - 900 m Over1200m m
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0 250 500 Client @ A31:5,000 WHITEHOUSE FARM m EASurface Water Flood DepthRisk - ConEnviron tains mAgency ent inform © ationEnviron mAgency ent anddatabase right MrParkin-CoatesA 13/12/18 ConOrdnance tains Survey Crown (c) data copyright anddatabase 2016. right Percent Chance1.0 Drawn:TL Mapsbased on EAupdated ‘Flood Map for Surface Water’(‘uFMfSW’) releasedof nation aiteration latest 2013as scalealinthe surfacewatermodelling exercise Checked:MI Figure005b RevA
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boun Site dary RiskofFlooding from Surface Water - Depth - Below150m m 150 - 300m - 150 m 300 - 600m - 300 m 600 - 900m - 600 m 900 - 1200m - 900 m Over1200m m
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0 250 500 Client @ A31:5,000 WHITEHOUSE FARM m EASurface Water Flood DepthRisk - ConEnviron tains mAgency ent inform © ationEnviron mAgency ent anddatabase right MrParkin-CoatesA 13/12/18 ConOrdnance tains Survey Crown (c) data copyright anddatabase 2016. right Percent Chance0.1 Drawn:TL Mapsbased on EAupdated ‘Flood Map for Surface Water’(‘uFMfSW’) releasedof nation aiteration latest 2013as scalealinthe surfacewatermodelling exercise Checked:MI Figure005c RevA
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd S ite Boun Site dary RiskofFlooding from ReservoirMaximum - Flood Depth Below0.3m Between0.3mand 2m Over2m
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0 250 500 Client @ A31:5,000 WHITEHOUSE FARM m ReservoirFlood Map ConEnviron tains mAgency ent inform © ationEnviron mAgency ent anddatabase right MrParkin-CoatesA 13/12/18 ConOrdnance tains SurveyCrown (c) data copyright anddatabase 2016. right Drawn:TL EAReservoir Flood Maps (RFMs) showing potentialextent ofthe flooding event ofthe breach ina from large reservoirs (over 25,000 cubic metrescubic ofbased water) onnation a scale al modelling riskofread Keyto‘Areaat floodingexercise”. reservoirin breach Checked:MI Figure006 RevA
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boundary Historic Flood Extent Recorded Flood Outline
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0 250 500 Client 1:5,000 @ A3 WHITE HOUSE FARM m EA Recorded Historic Flood Extents Contains Environment Agency information © Environment Agency and database right 13/12/18 Contains Ordnance Survey data (c) Crown copyright and database right 2016. Mr A Parkin-Coates Drawn: TL Historic Flood Map shows the maximum extent of all individual Recorded Flood Outlines from river, the sea and groundwater springs and shows areas of land that have previously been subject to flooding in England. Recorded Flood Outlines shows all EA records of historic flooding from rivers, the sea, groundwater and surface water Checked: MI Figure 007 Rev A
Z:\Projects\45002\01_pdf\FRA\mxd/Figure008_SourceProtectionZone.mxd Site Boundary Zone I - Inner Protection Zone Zone II - Outer Protection Zone Zone III - Total Catchment Zone of Special Interest
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0 250 500 Client 1:5,000 @ A3 WHITE HOUSE FARM m EA Ground Water Source Protection Zones 13/12/18 Contains Environment Agency information © Environment Agency and database right Mr A Parkin-Coates Contains Ordnance Survey data (c) Crown copyright and database right 2018. Drawn: TL
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TECHNICAL NOTE Appendix B: Stakeholder Consultation
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Mark Isherwood
From: National Requests Sent: 18 December 2018 17:47 To: Mark Isherwood Subject: NR106636 Attachments: Supporting Information (YOR).zip; Doncaster Schemes 2007-17.pdf
Dear Mark
Enquiry regarding flood risk information for a site at White House Farm in Barnby Dun, Doncaster.
Thank you for your enquiry which was received on 9 November 2018.
Please accept our apology for the delay in responding. We are still awaiting data from our East Midlands Area which we will forward on as soon as we receive it.
We respond to requests under the Freedom of Information Act 2000 and Environmental Information Regulations 2004.
Please find our Yorkshire Area’s responses to your questions below:
Fluvial/Tidal Flooding
1. Confirmation if the site is located within an area considered to be at risk of flooding from the River Don, River Trent and the Isle of Axeholme. If so, please provide the following information for each:
Please refer to the attached supporting information.
2. A detailed flood map for the site and surrounding area to include the flood extents for all available return period events, with and without climate change allowances. Please provide a map including the following (where available): • Flood Zone 2 and 3 areas; • A table showing flood levels, depths and flows for all modelled flood events; • Relevant model node point locations and unique identifiers (for cross-referencing of the flood levels, depths and flows); • Flood defence locations and details of any defences (including crest height, standard of protection and condition); • Historic flood event outlines.
Please refer to the attached supporting information.
3. Confirmation of the hydraulic modelling study used to define the Flood Zone extents at this location on the current Flood Map for Planning.
Please refer to the attached supporting information.
4. Could you please confirm if the watercourses highlighted above are considered to be predominantly fluvial or tidally influenced at this location.
Please refer to the attached supporting information.
5. Details of any local defence infrastructure, including a plan showing defence locations (including crest height, standard of protection and condition). Can you please confirm if the lock structures located along the River Dun Navigation are considered to contribute to flood defence infrastructure in the area.
Please refer to the attached supporting information.
6. Details of any historic flooding in the vicinity of the site, including written reports, photos, duration, return period and source/mechanism of flooding.
1
Please refer to the attached supporting information.
7. Details of any remedial works undertaken to alleviate flooding in the wider area or any proposed works for the future.
We have an ongoing programme of work on the Lower Don including routine maintenance, culvert surveys, addressing defects, minor works projects and capital investment schemes.
Our field team have now completed the end of season grass cuts on our embankments for this year (these are needed to encourage a healthy grass sward to protect the embankment, and also to see any damage to the earth embankment easily) and have moved on to tree works (cutting back tree growth that is causing blockage to flow) and winter walk-throughs (where our field teams or contractors walk through the river channel and remove blockages to flow). We also react to reported blockages that we consider to be a flood risk.
Recent works in and around Doncaster include - Bentley Ings Pumping Station Refurbishment – We are currently undertaking significant refurbishment works to Bentley Ings Pumping station. This is one of the most important assets in managing flood risk on the Lower Don and provides fl ood risk reduction to 1700 houses in Bentley. Site works are anticipated to be completed in March 2020.
Stainforth, Dunston Hill piling – last week our contractors (BAM Nuttall) completed repairs to a short section of piling on the right bank of the River Don at Dunston Hill, downstream of Stainforth.
Fishlake – In September we completed works to Fishlake Barrier bank on Plumtree Hill Road, and replaced a former stop log gap with a ramp and carried out improvements to the remaining entrance which still requires a stop log. We have proposed works to reduce seepage through the flood wall/embankment at Fishlake Nab, adjacent to Stainforth Bridge.
Thorpe Marsh Reservoir – This is the largest flood storage reservoir in the Doncaster area. It underwent a 10 yearly inspection by the Defra-appointed All Reservoirs Panel Engineer in August. We are yet to receive the report on this inspection, but are not anticipating any significant works to result from this inspection.
I have also attached a map (Doncaster Schemes 2007-17) summarising the construction works we have carried out to improve flood risk management on the Lower Don since the flooding of June 2007.
There are no planned flood defence works within the next 10 years in this area. There may possibly be some refurbishment works in the longer term dependent on funding but this is not confirmed at the moment.
8. Details of any local hydraulic features/controls and hydrological influences that should be considered e.g. condition, capacity, ownership and maintenance requirements.
Please refer to the attached supporting information.
9. Confirmation of any requirements for compensatory flood storage volume.
Where a development is likely to increase flood risk by taking up flood plain storage, it may be necessary to provide compensatory storage to mitigate this risk. Compensation works are divided into direct and indirect. These terms come from CIRIA report C624 “Development and flood risk – guidance for the construction industry (2004)”.
Direct or ‘level for level’ methods as they are also known re-grade the land at the same level as that taken up by the development. Direct schemes therefore provide a direct replacement for the lost storage volume.
Indirect methods rely on water entering a storage area which then releases water at a slower rate, akin to a surface water attenuation scheme. The storage area can be remote from the flood plain or even a tank. Indirect schemes are complicated to design and construct and require a more intensive maintenance regime, which must be continued indefinitely. For these reasons we are generally opposed to indirect schemes unless a planning decision has already been made and they are the only remaining option.
10. Any specific recommendations regarding a Flood Warning and Evacuation Plan for the site.
2 Identification of safe access and egress for the property during a flood event should be made. It is recommended that a flood evacuation plan should be formulated and dwelling occupants are advised to sign up to Floodline Warnings Direct. This can be done online at https://www.gov.uk/sign-up-for-flood-warnings or by phoning Floodline Warnings Direct on The NPPF places responsibilities on local authorities to consult their Emergency Planners and the Emergency Services with regard to specific emergency planning issues relating to new development.
It is not our role to comment on or approve the adequacy of these plans and we would expect local planning authorities, through their Emergency Planners, to formally consider the implication of this in making their decision.
Please note that the Local Planning Authority must be satisfied with regard to the safety of people (including those with restricted mobility), the ability of such people to reach places of safety including safe refuges within buildings and the ability of the emergency services to access such buildings to rescue and evacuate those people.
11. Confirmation of the EA’s requirements with respect to applicable finished floor levels for the proposed development with respect to local fluvial flood levels, including recommendations on the appropriate application of climate change allowances as per the current EA guidance1.
Setting the ground floor level above site ground level will provide a measure of protection against any flooding. In flood zone 3 finished floor levels should be set no lower than 600mm for residential or 300mm for industrial/commercial above the 1% (1 in 100) + climate change modelled flood level. Updated guidance on how climate change could affect flood risk to new development - ‘Flood risk assessments: climate change allowances’ was published on gov.uk on 19 February 2016. You should confirm the flood risk vulnerability classification and lifetime of your proposed development in line with NPPF and apply the appropriate climate change allowances. The River Don catchment falls within the Humber River Basin District.
12. Any other pertinent information for the site which may need to be considered as part of the FRA, or any specific requirements for issues to be addressed within the FRA.
Residual Risk Residual risks are those remaining after applying the sequential approach to the location of development and considering mitigating measures in place, such as formal defences. An example of residual flood risk is the failure of flood management infrastructure such as a breach of a raised flood defence, blockage of a surface water conveyance system, overtopping of an upstream storage area, or failure of a pumped drainage system. Areas, such as this site, behind flood defences are at particular risk from rapid onset of fast-flowing and deep water flooding, with little or no warning if defences are overtopped or breached. We would expect to see the residual risk to the site assessed and mitigated.
Flood Resilient Construction We recommend that consideration be given to use of flood proofing measures to reduce the impact of flooding when it occurs. Flood proofing measures include barriers on ground floor doors, windows and access points and bringing in electrical services into the building at a high level so that plugs are located above possible flood levels. Please refer to the following document for information on flood resilience and resistance techniques to be included: ‘Improving the Flood Performance of New Buildings - Flood Resilient Construction’ (DCLG 2007); https://www.gov.uk/government/publications/flood-resilient-construction-of-new-buildings Consultation with your building control department is recommended when determining if flood proofing measures are effective. Additional guidance can be found in our Flood line Publications. A free copy of these is available by telephoning 0345 988 1188 or they can be found on our website https://www.gov.uk/topic/environmental- management/flooding-coastal-change.
Discharging to watercourse Where a new surface water drainage connection to a main river is proposed, pre-approval from the Environment Agency must be sought. New connections must be discharged at Greenfield run off rate. The acceptable greenfield runoff rate is normally 5 litre/second/hectare, but you should consult with the Lead Local Flood Authority for variances in their district. If it is an existing brownfield site then 30% reduction in discharge will be required if the site bigger than 1ha.
Post 6th April 2016: Introduction of Environmental Permitting Regulations (EPR) for Flood Risk Activities (replaces FD Consenting under WRA):
3 This development may require a permit under the Environmental Permitting (England and Wales) Regulations 2010 from the Environment Agency for any proposed works or structures, in, under, over or within eight (sixteen) metres of the top of the bank of the (tidal) River Don, designated a ‘main river’. This was formerly called a Flood Defence Consent. Some activities are also now excluded or exempt. A permit is separate to and in addition to any planning permission granted. Further details and guidance are available on the GOV.UK website: https://www.gov.uk/guidance/flood-risk-activities-environmental-permits. It can take up to two months to determine the application from being duly made. Every effort will be made to process it as quickly as possible, but you are reminded that works should not commence until the permit is granted. Charging for Advice
Should you require any further advice, including the review of any technical documents, we can provide this as part of our pre-planning advice service. This will speed up our formal response to the planning application and can provide the applicant with certainty as to what our response to the planning application will be. It should also result in a better quality and more environmentally sensitive development. As part of this service, we will provide a dedicated project manager to act as a single point of contact to help resolve any problems. We currently charge £100 per hour, plus VAT for this work to allow us to recover our costs. If you wish to take advantage of this service, please email us at with details, so we can provide you with an estimated cost.
Please note that this response is based on the information made available at this time. It is based on current national planning policy, associated legislation and environmental data / information. If any of these elements change in the future then we may need to reconsider our position.
Groundwater
13. Details of any groundwater Source Protection Zones (SPZ) and the nature of groundwater flow in the vicinity of the site i.e. if the site is located on an aquifer. Please provide indicative details of the ground conditions and the level of the water table, if possible.
The site is located in the Groundwater body called Aire &Don Sherwood Sandstone . It is upon a Principal aquifer which has a medium vulnerability. It is in Source Protection Zone 3 (SPZ). It lays on the Chester Formation. Unfortunately there are no monitoring boreholes within 1 km therefore I can’t provide any groundwater level
14. Details of any known groundwater flooding issues.
Unfortunately, we do not hold any information relating to groundwater flooding in this area. Mapping the risk of flooding from groundwater is complex and is currently not possible. There are no flood risk maps for groundwater. However, although we do not have specific data in relation to ephemeral springs or unexpected groundwater emergence in this area, it does not mean that they are not present. If found, they could contribute to localised flooding events.
Please refer to Open Government Licence which explains the permitted use of this information.
Please get in touch if you have any further queries or contact us within two months if you’d like us to review the information we have sent.
Yours sincerely
Robert Longden National Request Team National Customer Contact Centre Contact Centre Services - Part of Operations, Regulation, Monitoring & Customer Environment Agency