From: Jones, Catrin [catrin.jones@environment-agency.gov.uk] Sent: 18 February 2010 13:59 To: Lucas, David Cc: Kyte, Rhian; Griffiths, Philip Subject: RE: REPRESENTOR SUBMITTED SEA/SA ASSESSMENTS Attachments: Picture (Metafile); ATT1435353.htm; EAW SEA_SA Assessment letter.doc; Record.pdf Hi Dave Given the time available, I can't look at this in a lot of detail (and I'm tied up from today till Wednesday). But I hope my comments below help (which only relate to those within EA remit). With regards the duly made submissions in appendix 1, the comments are not always legible, but it is notable that there are some notes on them such as 'to check', and a few question marks. And this ties up with my recollection of the meeting, in which we could only give a view based on what was in front of us, i.e. we were without constraint maps etc. But thanks to the maps that you sent through I have been able to check these sites against our constraint maps, with the following findings: >>>3989.D2 - HG99.1 - land Adjacent to Rhymney Comprehensive (both submissions): >The River Rhymney flows through this site. The site is at significant risk of flooding, with at least 50% of the site in DAM C2. EA floodmaps show that most of this is in the 1 in 100 (1%) flood outline. >Although I can't quite make out the markings in the SEA/SA, I do not think that this has been properly assessed in the SA/SEA, as assessment test 49 should certainly pick this up as a negative. And this relates to assessment test 51 also, as any development here would need to mitigate the impact of flooding to the site without impacting third parties. With so much of the site at risk of flooding, without assessment, it cannot be concluded that this is possible. I'm sure that you are aware that any further consideration of this site for inclusion in the LDP would need to be assessed (broad level assessment/SFCA), and that there would need to be reasons to put forward this site contrary to TAN15 (as housing would be highly vulnerable development), TAN15 says consequences of flooding cannot be managed for highly vulnerable development in DAM C2. >Although I do not have any constraints mapped, but as the site is indicated as being in a river corridor floodplain, it is likely that this will have a negative impact on biodiversity, in terms of fragmentation of habitat. I have not had the opportunity to look into the types of habitats and species likely to be on site, but the County Ecologist may have more information. >Overall, having checked the constraints, I do not view this SA/SEA to be representative. >>>2049.D18-E150 - Land At Heolddu >No obvious constraints mapped (although I was not able to access the Areas Susceptible to Surface Water Flooding Maps today) >But is it a former mine? (I just note some of the features on the OS map?) >According to the sewered area maps that we hold, this site is not in a sewered area. >Given that the site is a greenfield site, and that I have not looked in detail at the habitats/species likely to be here, I would query the conclusions of assessment tests 59, 61 and 63. Again, worth checking with County Ecologist. >Assessment test 51 - it is relevant in relation to surface water drainage, and ensuring that there is no increase in flooding elsewhere as as result of an increase in impermeable areas. >>>2049.D21- E179 - Land at Ty Mawr (North) >No obvious constraints mapped (although I was not able to access the Areas Susceptible to Surface Water Flooding Maps today) >According to the sewered area maps that we hold, this site is not in a sewered area. >Given that the site is a greenfield site, and that I have not looked in detail at the habitats/species likely to be here, I would query the conclusions of assessment tests 59, 61 and 63. Again, worth checking with County Ecologist. >Assessment test 51 - it is relevant in relation to surface water drainage, and ensuring that there is no increase in flooding elsewhere as as result of an increase in impermeable areas. >>>2049.D21 - HG1_43 - Land at Gellideg Heights >Recent appeal at this site (I do not have access to the Inspector's report today, but the Council did refuse the application, County Ecologist and EA objected on biodiversity grounds). No issue with the part of the site annotated in brown on the map you sent, but there are some constraints on the rest of the site. I think I recall this being a candidate SINC? And so I query the conclusions for assessment tests 59, 61 and 63. But the County Ecologist is in a better position to advise. >Part of the site (the northern most part)is a landfill site for old railway cuttings, and it would appear that it holds a current waste licence. The site lies on a minor aquifer, and so there could be a risk of polluting controlled waters from developing the site that has been/is landfill. This would need to be managed if any development came forward for this site. >Most of the area is in a sewered area, but not the landfill part of the site. >Assessment test 51 - it is relevant in relation to surface water drainage, and ensuring that there is no increase in flooding elsewhere as as result of an increase in impermeable areas (I was not able to access the Areas Susceptible to Surface Water Flooding Maps today) >>>2500.D8 - E360 - Land at Danygraig Works >A tiny part of the site, and its access road lies in DAM C2. EA floodmaps show this bit to be in flood zone 2 (1 in 1000 year/0/1% flood outline). So this risk would need to be managed (unlikely further assessment needed at strategic stage, as development on this site could easily avoid the areas at risk of flooding and access could be achieved without going into the area at risk of flooding). (I was not able to access the Areas Susceptible to Surface Water Flooding Maps today) >Possible contaminated site, on a major aquifer, so risk of polluting controlled waters would need to be managed. See assessment tests 16 and 48 >Site is in sewered area. >Assessment tests 50 and 51 - it is relevant in relation to surface water drainage, and ensuring that there is no increase in flooding elsewhere as as result of an increase in impermeable areas. APPENDIX 2 - >>>4116.D1 - HG99.20 - Land at Gwaun Fro, Penpedairheol >Part of site (eastern side near current settlement) is in DAM Zone C2. EA floodmaps show this to equate to a 1 in 100 (1%) flood outline. And so the conclusions for assessment test 49, and therefore 51 (without further assessment), are incorrect. (I was not able to access the Areas Susceptible to Surface Water Flooding Maps today) >Only small part of site in sewered area, but it is nearby. >Also query the conclusions at 59, 61 and 63, but refer to County Ecologist. >Overall, do not agree with conclusion primarily because of flood risk issue. >>>4115.D1 - E123 - Land At Waun Rydd >Peripheral parts of the site only in a sewered area, but it is nearby. >Again, query the conclusions at 59, 61 and 63, but refer to County Ecologist. The SA/SEA for Maesmafon Farm, Nelson was not included in the meeting notes, but as the map was sent through, only comment is that it is not in a sewered area, except the south western corner of the site. GENERAL/CONCLUDING comments: >Possible underestimation on impact to biodiversity etc for the greenfield sites. >Many of the greenfield sites appear not to have the essential infrastructure, such as mains sewer connection available. >Flood risk has either been misunderstood as an issue (i.e assumption that if no fluvial flooding constraints flagged, then not an issue), or it has not been accurately portrayed in the SA/SEA. Were these all the SA/SEAs that were sent for the alternative sites? Are any of these likely to be promoted by the Council or put in front of the Inspector for examination? Whilst the meeting note is indeed a fair reflection of the conclusions at the meeting, it has to be noted that the conclusions, particularly those documented at section 58, were made in good faith i.e. assuming that the SA/SEAs presented accurate information. My brief check against constraints though has exposed that the submissions may not have been as accurate as we thought. I've gone a step further than was requested in your letter, but I needed to go through this exercise in order to answer your question, so I trust this information is useful. If you have any follow up queries, please do not hesitate to contact me. Regards Catrin Catrin Jones Technical Specialist Planning Liaison Environment Agency Wales, South East Area Office, Rivers House, St Mellons Business Park, Cardiff CF3 0EY External: 029 2024 5091 Internal: 726 2091 Mobile: 07920287597 catrin.jones@environment-agency.gov.uk P Defnyddiwch llai o ynni y gaeaf yma trwy wisgo rhagor, yn hytrach na gwresogi rhagor P Keep energy use lower by wearing more layers this winter, rather than turning up the heating -----Original Message----- From: Lucas, David [mailto:LUCASDJ@CAERPHILLY.GOV.UK] Sent: 16 February 2010 17:20 To: Jones, Catrin Cc: Kyte, Rhian; Griffiths, Philip Subject: REPRESENTOR SUBMITTED SEA/SA ASSESSMENTS