Object

Candidate Site Register

Representation ID: 27678

Received: 20/09/2019

Respondent: Mr Ricky Carter

Representation Summary:

The land identified as Site 58 has caused significant and costly off site flooding of Aber Road and adjacent properties. During such events, the highway has been impassable, impacting both on residents, and the emergency services. TAN 15 (paragraph 10.4) " ....flood risk will be a material factor in the formulation of specific policies and allocation of sites". Other than generic reference to SuDS, there has been no specific flood mitigation measures proposed, nor the consideration of the implications of climate change. As such it is considered that the allocation of this site is considered premature.

Change suggested by respondent:

Remove this site from the proposed Replacement Local Development Plan

Full text:

The stretch of Aber Road immediately adjacent to this site has increasingly been subject to significant flooding as a result of surface water run-off from within the catchment. This has been exacerbated by limited capacity within a culverted watercourse traversing the site. During flooding events, Aber Road has become impassable to residents and emergency services and has resulted in considerable flood damage to properties to the north of the highway. Despite remedial works being undertaken by the Council, the flooding events have continued, and are becoming more frequent. In its current state, the proposed development site will naturally reduce the impact of less intense rainfall through percolation, however creating large areas of impermeable surface will reduce this capacity, and combined with the impacts of increased rainfall associated with climate change, will inevitably exacerbate the existing flood risks. Whilst the site itself is likely to be located within a Development Advice Map Zone A (and not itself at risk from flooding), the impacts for off-site flooding cannot be ignored, and Technical Advice Note 15 (paragraph 10.4) states that " ....flood risk will be a material factor in the formulation of specific policies and allocation of sites". Although the public consultation referred to Sustainable Drainage Systems (SuDS), and in view of the scale of the proposed development, it is considered essential that this is an issue that needs to be addressed prior to formal allocation of this site with the Local Development Plan. As such, allocation of the site at this stage is considered premature.


Our response:

Not accepted. The site has been sent to Natural Resources Wales for specific comments regarding flooding. Their comments will include if there is likely to be any impact on neighbouring areas. The Replacement LDP and all the sites which are to be allocated will be subject to a Floods Consequences Assessment.