Flooding

B&NES CPRE, on behalf of Avonside CPRE, responded to the consultation on the Bristol Avon Catchment Flood Management Plan.

Our response, referring to the original document published by the Environment Agency, was as follows:

General

CPRE supports the role of the EA in constraining development in areas of risk of flooding and encouragement of appropriate and sensitive landscape management to reduce the impact of adverse rainfall and tidal events. We welcome the General planning statements:

• we will aim to make sure that all new developments comply with PPS25, do not increase flood risk and support the CFMP policies;
• we will provide advice to make sure that there is no increase in runoff from new developments and look for opportunities to reduce current runoff rates;
• we will seek to influence local authority Strategic Flood Risk Assessments and planning policies.

It is assumed that the proposals made represent a proposed allocation of limited funds available or likely to be available to maintain and improve flood prevention measures. As such, the allocation of risk and the prioritization approach adopted appears intuitively appropriate to a lay reader. This does not underestimate the potential impact of those whose property, livelihood and day to day existence would be at a greater risk than others. It would be interesting to understand the overall financial constraints for this planning process and how they fit with other planning / risk assessment activities.

House-building proposals

One major concern relates to the potential impact of any significant house-building in the area e.g. p171
“There is expected to be a significant amount of urban development in the future in the area to the north of Bristol, which may increase the flood risk downstream and also to the newly developed areas.”

We would welcome a view as to the extent of any increased risk. This is particularly important in view of the instances of Policy areas where defences are to be maintained in their current condition in spite of increased risk due to climatic change.

Policy Unit A

We do have some concern regarding Policy 3 e.g. page 111, policy unit A actions
“In the short term we will continue with current operations and maintenance (O&M) activities on the River Avon and its tributaries (including existing flood warning procedures). However, we will identify areas where these O&M activities could be reduced to save money”

It would be helpful to have asssurances that any reductions would not jeopardize the Policy 3 objective of not reducing the level of flood protection.

We would also welcome further information of the level of risk associated with Policy unit A ECON2 and ECON3 where the current degree of risk appears high and therefore a potential deterioration could have significant adverse impacts.

Policy Unit C

We welcome the planned improvement to flood prevention in Bath p137,8, however would be keen to understand the statement that Policy 5 will
“provide an opportunity to combine recreational enhancements into new proposals for the provision of flood risk management in Batheaston and Bathampton.“

B&NES CPRE are not in favour of the relocation of the Bath Rugby club Training facilities relocating to Bathampton from Lambridge to make way for the P&R.

Policy Unit D

Improvements to retain the current degree of risk are welcomed, although the current risk does appear significant (see general comment above)

Policy Units E and F

Improvements to reduce the current risk are welcomed as is the recognition that these should be done in such a way as to avoid adverse effects on the natural environment.

Policy Unit G

CPRE is keen to be consulted once proposals for increased flooding of selected areas have been developed.