Planning Applications

ASHRA's Response - Flooding

Flooding

See Separate Flooding Report.

Historical records show that in the year 976 Ash was spelt Aesc meaning ‘at the ash tree’. The village of Ash grew up on an area of London Clay, and was part of the flood plain of the Blackwater River. Although the land was unsuitable for agriculture, it was important because it provided grazing for villagers’ livestock. The church of St. Peter’s stands raised above the village on a small mound of gravel on the London Clay. This is the reason that South Ash is so prone to flooding, as the fields to the rear of Ash Lodge Drive and Loddon way form the lowest point in Ash.

This area of Ash is included in the Surrey Flood Risk Strategy, as an area at risk from surface water flooding. It says a few developed areas are at high risk from flooding, notably areas of Guildford town centre on both banks of the River Wey, parts of Ash within the Blackwater Valley and some properties in villages along the Tillingbourne. Climate change is expected to cause an increase in peak river flows over the next 50-100 years and may result in some areas being at greater risk of flooding in the future. It goes on to say that with regard to surface water flooding, a large proportion of the Borough is currently undeveloped and so in those areas the surface water is unchanged from Greenfield rates. The most intensive urbanised areas are within Guildford and Ash; here any further development could increase surface water.

The developer has added to his original scope a group of existing fields for use as SANGS (Suitable Accessible Green Space).  The areas stated fail to fully meet the requirements of the site quality checklist for SANGS.  The existing fields (parcel 1) are within easy walking distance for the majority of existing residents.

In fact, the existing fields in Parcel 1 were described in the Environment Agencies letter of 30th May 2012 to Ash Residents Association as a SANG, quote:

“The risk that proposed development (12/P/00645) will flood from this watercourse is reduced by the fact that the land alongside the watercourse is designated a SANG.”

Access to the existing fields, based on a walking distance of 400 metres from any public footpath entrance, is currently available to approximately 600 homes and 3 schools which represents over 2,000 people.

The proposed new SANGS are well beyond the 400m limit for most of the existing residents (despite the developer claiming they are not) and should therefore be provided with adequate parking for visitors.  Measured distances from developers own application maps are typically 750m walking distance (not as crow flies) from the NW corner of this development to SANG main entry point (closest) and 650m from the northern end of FP350 (within the site) to the SANG main entry point.  In fact, of the houses shown on the new development plan, only about 50% of the new homes are within 400m walking distance of the SANG entrance. For any of the existing residents using the fields currently within 400m walking distance, many will have distances of at least 1 km to reach this SANG area.  None of the proposed SANGS fields are currently accessible by car and thus have no parking.

The developer, in his application, has used the centre of his site to draw a 400m radius circle to just include the entrance to the SANG as his justification for complying with the 400m rule.  This method still means that 50% of the new dwellings have more than 400m to walk to the SANG.  (If this method were used with the existing fields it would include most of South Ash and Tongham and would encompass 5,000 people having access to the existing fields.)

This SANG proposal takes away the benefit of a suitable accessible natural green space for over 2,000 people for the benefit of possibly as few as 580 people, (or 5,000 for the benefit of 1,000 if the developers method of SANG compliance were used.)

Also in the text of the developers application is a proposal to allow grazing in the fields (clauses 5.3.1 and 5.3.8 in the SANGS Management Plan).  There is no way you can guarantee that a dog off a lead will not worry or attack any livestock (including horses).

It should also be noted that one of the fields marked for SANG (Cardinal Fields) is the collecting point for a number of fast flowing watercourses from the Hogs Back, Ash Green and Poyle Road and is regularly under a considerable depth of floodwater (over 1.2m deep in places) which is totally unsuitable for a SANG, and makes it very difficult to walk and ride along the footpaths.  This area is a functional flood plain and should probably be rated zone 3b per the NPPF TG standard.

Aspect Ecology state that 24ha of land will form the SANG, with the remaining capacity available as mitigation for future development. This explains why they also state that the SANG will remain under the ownership of Bewley Homes who will manage it. The proposed large SANG area is therefore not so much to do with the Thames Basin SPA, or for the benefit of residents, but more to do with making more profit.

Barton Willmore. Environmental Statement, in their Non-technical Summary 10.2 state that "The site is at risk of surface water flooding during extreme events". This shows how very little these “experts” know about the land in question. These fields, especially the low lying ones to the north of the site, are under water for most of every winter.

It’s amazing to think that Thames Valley Archaeological Services on behalf of Bewley Homes, in their Desk based Heritage Assessment, when talking about potential archaeology on the site, state that "It is unlikely that waterlogged remains would be encountered, rather any deposits present can be expected to be typical of dryland locations"

Card Geotechnics Limited. Geo-Environmental Interpretative Report states that 12 boreholes were dug in October 2011 and no Groundwater was encountered. According to DEFRA, between September 2011 and December 2011 we were in the worst drought in Surrey for more than 30 years. Didn’t someone at Card Geotechnics think of this. If they tried to dig boreholes between May 2012 and March 2013, they wouldn't find the surface of the land through the water.

Card Geotechnics Limited. Geo-Environmental Interpretative Report also states that infiltration tests were undertaken in test pits dug between 2.5 and 2.7 mtrs., however due to the low permeability of the ground, the test were abandoned. Surely this must tell everyone that this land is not suitable for building on. Because of the clay and the flooding potential, it is unlikely that the new houses will be insurable, not only from the risk of flooding but also from subsidence. Also the increased risk of flooding to houses in the area in Ash Lodge Drive, Loddon Way, South Lane, Southlands Road, Southlands Close, The Briars, Avon Close, Wandle Close, Kennet Close is a serious one and, if this building goes ahead, could increase their insurance premiums or make their homes uninsurable.

The most ridiculous statement of all comes from Card Geotechnics Limited, once again in its Geo environmental Interpretative Report. It states that “shallow excavations are likely to remain stable in the short term. Groundwater is unlikely to be encountered within excavations on site”. This is an unbelievable statement, and this in itself shows how completely incompetent and complacent these people are. They obviously learned very little about the site, the topology and the potential for flooding. They have been given a brief by Bewley Homes and are willing to ignore warning signs.

The NPPF states that Local Plans should take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape. New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change. It goes on to say that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards.