Meeting documents

Jan Brown of Norfolk Crescent Green Residents' Association

I wish to speak about our existing Flood Risk and our concerns that development at BWR East, when combined with that upstream, could add to this.

We live in a City where the floodplain is already overdeveloped and where existing defences do not provide protection to all properties, resulting in many being within the floodplain, Flood Zone 3, and at the highest level of risk. This includes some of our buildings in Norfolk Crescent and Nelson Villas and also much of the Green. A contributory factor is piling on the south bank opposite which stands at a metre higher than the undefended north bank. Current Environment Agency maps only include for known climate change, but clearly our risk will increase when 20% is added for future change. We are very concerned this is not added to by development at BWR East and other schemes proposed upstream, most of which are in the floodplain.

PPS25 requires all new development to be flood neutral and not to increase flood risk elsewhere, particularly for adjacent and downstream properties. To achieve this, as a matter of principle, the Agency requires flood storage to be provided for any new development to accommodate future climate change. This is a distinct requirement and not affected by strategy. Therefore the only probable outcomes from the recently completed Strategic Flood Risk Assessment as it applies to Bath will be either to provide storage on individual sites in accordance with site specific Flood Risk Assessments or for some sites to be left partly or wholly for flood storage to allow development on others.

We have serious concerns that the principle of flood storage provision is being ignored and that it is assumed a strategy will provide a solution which avoids this.

If so, the situation for us would be critical. Schemes immediately upstream at Bath Quays require substantial flood storage and some will also be needed at BWR East, probably of similar order to that required for the West. If full storage were not provided on site for these schemes, with even minimal climate change, we could be subjected to regular flooding at much increased level and flow and Crest's development just downstream would also be flooded.

We therefore urge that amendment 49 is expanded to include `Development will not be permitted if it increases risk elsewhere, particularly to adjacent and downstream properties.'

Thank you