FLOODING - review of the Local Plan review issued in 2017
Remember if you are going to use these in your letters to put them into your own words:
1. Proper consideration is not being given to the Functional floodplain and building more critical infrastructure in an already restricted floodplain is not a good idea
2. There is no commentary on providing any compensatory floodplain and far too little detail around the size, scope and placement of sustainable urban drainage schemes (the one at Kingfisher Reach has not been built correctly by the developer and isn't working properly either)!
3. The Local Plan should have adopted best practice and make a whole Catchment Based assessment of flooding - this simply has not been done
4. The Strategic flood Risk Assessment (I think the work was undertaken in 2014) uses generalised flow data from 2008 and the latest update to the Local Plan does NOT appear to have any update to the SFRA or commentary on REAL Flood data
5. The update makes no reference to published reports (such as the National flood Resilience report) so it gives the impression that MDDC are downplaying the flooding issues at every turn and this is simply unacceptable as plenty has been going on nationally and they should be at least noting all of this!
6. Catchment Based Assessment - The National Planning Policy Framework (NPPF) is the overarching policy framework against which Local Plans will be judged (and 3 key criteria are: as it been positively prepared; is the plan deliverable and is it consistent with national policy)? My strong argument is that the MDDC plan is inconsistent with NPPF policy in relation to flooding as a Catchment Based Assessment has NOT bee adopted!
7. And, whilst a Strategic Flood Risk Assessment was undertaken (reported sometime in 2014 from memory) the modelling was undertaken using "generalised flow data from 2008". This is simply not good enough AND the most recent update to the LP does not refer either to the post 2012 flooding report conducted by Devon County Council and nor does it refer to ANY of the national studies e.g. The National Flood Resilience Review and the Future Flood Prevention reports published by the EFRA Committee in the House of Commons!
8. There are NO references to abundant flood research (nothing on natural flood management for example), nothing on exemplar approaches (Pickering in North Yorkshire is a good example) and absolutely nothing in relation to how re-allocation of land at J27 may impact flooding if 15o Ha development occurs.
9. Functional Floodplain - NPPF guidance is that Functional Floodplain should NOT be developed in and it SHOULD be allowed to do what it supposed to do e.g. flood and hold water during flooding events. This is a massive problem wrt East Cullompton (and indeed Cullompton as is) because the FF is massively constrained by the M5 and main-line railway using up FF land. The proposed relief road, the new motorway access are both 100% in FF (as is the aspiration for a new railway station) BUT the is nothing I can see in the plan in relation to providing "Compensatory Floodplain" e.g. additional land to offset these developments and land which can flood.
10. Critical Drainage Areas - Cullompton already has a CDA designation and the Sewage Pump Station at Culm Lea and the sewage treatment works at the bottom end of Cullompton are both 100% in the FF! What happens if/when these flood? What happens when the STW operates above 100% capacity?