Flood Risk is a major issue.
There are 3 main aspects of concern:
- that the development will not be safe from flooding,
- that surface run off will increase the risk of flooding and put additional pressure on a recognised vulnerability in the City’s flood defences,
- that allowing surface run off into the River is incompatible with current Policy objectives relating to poor water quality in the River Frome.
We have been astonished and disturbed at the developer’s apparent lack of awareness of the extent and frequency of flooding on the proposed development site.
At the ‘exhibition’ and in subsequent statements, they have insisted the whole development site sits above the floodline in what the Environment Agency class as ‘Floodzone 1’, being the lowest level of risk. However, we believe this to be based on a gross underestimation of the actual extent of flooding in the field. The lower parts are designated as ‘functional floodplain’, meaning they are deliberately allowed to flood to hold water back from the city centre.
The aerial photo below shows the extent of actual innundation. To allow for the increased rainfall, river flow and floodlevels predicted as a result of global warming, experts have warned that calculations need to be increased by 20% – even now, we believe the lower houses on the plan are at significant risk, and will increasingly be so as future flood levels rise.
In February 2008, Bristol City Council commissioned Halcrow Group Ltd to prepare a Level 2 Strategic Flood Risk Assessment (SFRA), with a focus on the nature and extent of flood hazards in five areas with known flood risks and development pressures.
The result is Bristol SFRA L2 Final Report (known as the ‘Halcrow Report’). It contains specific references to the areas around Eastville Park Lake and Stapleton, where the flood risk is especially acute and where they consider the defences to be vulnerable. On page 44 it states ‘The main areas of risk lie around the edge of the residential area of Stapleton to the north of Eastville Park, and underneath the western edge of the M32 motorway. The greatest risk is to the Stapleton area to the north of Area B, which is considered to be Functional Floodplain (Flood Zone 3b); although no potential development is located in this area’.
The proposed development site is part of an area described in the report as ‘a significant area to the west and north of Eastville Park where flood waters of over 1.5m occur, leading to a significant hazard. The scale of flooding for events of this return period means that this is a location where residential and commercial development should be avoided’ and concludes ‘The scale of flooding in Eastville Park and the adjacent area in places warrants an extreme flood hazard, predominantly due to the depth of water around Stapleton’.
The ‘Protect Frome Valley @ Stapleton’ Community Association is taking expert advice on this issue.
In addition to the actual risk of flooding, we are also concerned that the development will generate increased surface runoff, as roofs and hard surfacing replace earth and vegetation. The developers have made vague mention of holding surface runoff in underground tanks and releasing it slowly into the river. We are not convinced and await full details. We are also concerned that any discharge into the river will be in contradiction to the City Councils stated objective of improving water quality in the Frome. Planning Policy DM33 ‘Pollution Control, Air Quality and Water Quality’ states: ‘2.33.3 Water quality is also a key issue. Under the Water Framework Directive, the council has a statutory duty to improve the condition of water bodies within the Bristol area, working towards the target of ‘Good Ecological Status’. New development adjacent to underground or surface water bodies is expected to contribute towards this objective’. It goes on to make a specific reference to the River Frome: ‘2.33.9 In terms of water quality, the River Frome, Brislington Brook, Malago, River Trym and Colliter’s Brook do not currently achieve Good Ecological Status due to impacts from flood protection / land drainage schemes and urbanisation. To comply with the Water Framework Directive water bodies should reach good ecological potential by 2027’.
We believe this building development would be totally incompatible with the planning objective to raise water quality in the River Frome to an acceptable ecological standard.Share This