Subject: FW: Cheltenham Plan - Today's hearing From: Trevor G Sent: 27 February 2019 21:37 To: Tracey Smith Cc: Trevor G Subject: Cheltenham Plan - Today's hearing Dear Tracey, Thank you for helping us to have an opportunity to discuss the plan with the Inspector today. We are also grateful to the inspector for listening to our issues and for her courtesy. During the meeting we highlighted the fact that the SFRAs presented were silent on the impact of surface water flows onto and off the proposed development sites and were also silent on ensuring the safe management of those flows from the proposed sites. We believe these matters fail the NPPF requirement of paragraph 156 which states:- 156. Strategic policies should be informed by a strategic flood risk assessment, and should manage flood risk from all sources. The Inspector asked Mr Mears of the Leckhampton Hills Parish Council for a proposed wording and we thought the passage below might be helpful for the Inspector which we believe addresses the matter which still needs to be addressed in the plan. Where a Surface Water Management Plan shows the presence of pluvial flooding (surface water flooding from rainfall storm events) , the development will need to compensate for the pluvial flood volume lost (water generated on and flowing off the site) providing additional flow and storage capacity within the developments surface water drainage system and attenuation storage. We believe that this attention to safely managing overland and surface water flows onto and off the proposed development sites would merit being emphasised in the Inspector’s comments as this is a pertinent point both to the plan as well as to all sites mentioned in the plan. In addition, the Inspector acknowledged that National Policy requires that developments should reduce the causes and impacts of flood risk overall the JCS also calls for this but this is not yet delivered or quantified in the plan and FRAs to hand INF 2 of the JCS Para 2 states • Minimising the risk of flooding and providing resilience to flooding, taking into account climate change, will be achieved by: • Requiring new development to, where possible, contribute to a reduction in existing flood risk We highlighted that the plan does not yet address the matter of reduction at all and also that none of the FRAs identify or quantify reductions in existing flood risk which we believe should be a requirement imposed on all of the sites mentioned in the plan. Para 5.3.8 of the JCS also states :- 5.3.8 As an overarching principle, all new development should seek to provide an overall reduction in flood risk? We think the Inspector should question why this has not been addressed in this plan yet or at least for the new developments proposed. One last point, some of the FRA’s discussed had EA statements concerning the achievement of betterment, the lack of any definition in the plan of what is meant by “betterment” or how much “betterment” is desirable is an unacceptable gap in the plan and so it would be helpful if the inspector were to seek clarification here of what is meant by betterment and why this is not called for for all the development sites. We hope these comments are considered to be constructive and do cover matters that fall within the inspector’s scope of work relating to this plan. Please do not hesitate to contact us if you need any more information or clarification. Kind regards Trevor Gander Cheltenham Flood and Drainage Panel