General Discussion
Despite no land whatsoever being identified for further housing development in Dawlish during the recent public consultation exercise for the emerging local plan - this does not stop local landowners/developers trying to beat the system (the proposed Hensford Park development being a case in point) and proposing land and plans for development
Now there is another speculative planning proposal - this time for approx 200 homes on land by the Dawlish countryside park.
Barratt David Wilson Homes are holding an open door session to meet the team and developer as part of a Public Consultation on Thursday 20th July 2023 between 14:00 and 19:00 at the Riverside Centre.
More information will be available 48 hours before the event on https:/barrattexeterplanning.co.uk
I have just come back from this presentation.
The reason this land was not selected for future development is because it lays on the Dawish Warren Critical Drainage Area. There is an increased risk of flooding in the not too distant future at Dawlish Warren and the Shutterton Area due to higher tides. I will post links to the DWCDA and future higher sea water level at Dawlish Warren. Please look at them!
The timetable at the presentation says that they are looking to submit an outline planning application in Autumn of this year.
info here on the flooding risks at Dawlish Warren and Shutterton.
https://www.getthedata.com/flood-map/dawlish-warren
https://www.devon.gov.uk/floodriskmanagement/planning-and-development/
(this link shows the Dawlish Warren critical drainage area. Click on link and then scroll down and click on Dawlish Warren)
https://www.devonlive.com/news/devon-news/devon-map-shows-impact-rising-6147817
(Click on link and then scroll down to see projected level of annual flooding at DW come 2050. Scroll down to next map and note also the projected level of flooding for further up the Exe Estuary.)
The developers have submitted a scoping opinion to TDC.
Ref 23/01389/SO
The link below should take you straight to the relevant planning page should you wish to register your thoughts on what they are proposing. I see no reason why we should not express ourselves on both the Scope and any subsequent planning application.
Should anyone reading this have posting access to Eyes of Dawlish please can you spread the word on there.
Here is the link 23/01389/SO | Scoping opinion request for up to 200 dwellings | Land At Exeter Road Dawlish Devon (teignbridge.gov.uk)
Or, we could all just be realistic and accept that whether or not this development gets the go ahead will have absolutely nothing to do with what any of us thinks about it but everything to do with whatever central government planning/housing policies happen to be at the time.
So, even if a planning application gets submitted and subsequently refused by TDC (on the grounds, say, that the land has not been identified for development) the applicant then could, and no doubt would, lodge an Appeal to the Planning Inspectorate. And the Planning Inspectorate would then determine whether or not the land should be developed. And the Planning Inspectorate would make their determination based on planning/housing policies current at the time.
So what we think means absolutely sod all. We can express our opinion(s), sure we can. But, and here's the thing, when push comes to shove, they don't count!
You think I'm making that up? Well, the above scenario is exactly how the Redrow housing development at Shutterton came about.
Back in February 2022 one of our (then) Dawlish district Cllrs made an interesting comment at a TDC planning committee meeting when he pointed out that TDC losing the Appeal for what was to subsequently become the Redrow housing development had cost TDC £300,000.
See below for the Environment Agency's response to TDC (my emphasis in red)
"SCOPING OPINION REQUEST FOR UP TO 200 DWELLINGS
LAND AT EXETER ROAD DAWLISH DEVON
Thank you for consulting us on the EIA Scoping Opinion for the above development.
Environment Agency position
We need to highlight that there are serious flooding and drainage problems within the Shutterton Brook Catchment. Until further information about the nature of flooding from all sources within the catchment is available, we recommend that your Authority does not make any long-term decisions about future development within this catchment.
Notwithstanding this, we have reviewed the EIA Scoping Report dated July 2023 by Savills. At this stage, we have further comments to make in respect of ground conditions, hydrology, flood risk and drainage, and water quality to ensure that any Environmental Statement (ES) and/or any supporting documents fully address the matters within our remit.
Our technical advice on these topics is set out below.
Ground Conditions
The scoping request document states that the potential for land contamination is low and we agree that this topic does not need to be scoped into the assessment. However, we consider that a Stage 1 Preliminary Risk Assessment should be submitted with any planning application as a minimum. Notwithstanding this, we recognise that if the potential for land contamination is identified within sections of the development area, these risks could be managed through specific planning application controls which will require remediation to an acceptable level.
Hydrology, Flood Risk and Drainage
In light of the flooding and drainage problems in the Shutterton Brook Catchment, we strongly recommend that this topic is scope into the EIA.
The Scoping Report correctly identifies that the site lies within a Critical Drainage Area (CDA). However, it has not fully explained the significance of this or the problems with the data that underpins. The CDA was designated in May 2013 because of the known critical drainage problems and high risk of flooding from various sources in the catchment. The information that informed the CDA designation is now out-of-date and the drainage standards for the catchment need updating.
We have commenced a flood modelling project to gain a comprehensive understanding of all the flood risk characteristics, as well as potential solutions. Until the results of our project are available, we will be unable to provide detailed comments on planning proposals. We believe that some modelling outputs should be available by the end of 2023, but the full model and reports will not be available until spring/summer 2024.
The modelling will inform revised flood risk areas (shown in the Flood Map for Planning) and the requirements for the CDA surface water technical standards. It will also inform any contributions required from developments for strategic flood resistance and resilience measures. On this basis, we have advised your Authority not to make any long-term decisions about future development within this catchment until the results of the modelling are available.
We welcome that your Authority has taken the above issues on board and decided not to take forward any residential allocations in Dawlish within the draft Local Plan. In terms of the flood risk Sequential Test, the PPG is clear that if this has been considered at the Local Plan stage there is no need to repeat it on individual planning applications. As your Spatial Team has documented the reasons why there are other development sites in Teignbridge that are sequentially preferable to this one, this should be sufficient evidence to refuse a planning application on planning policy grounds at this stage.
Water Quality
We also consider that water quality should be considered in terms of potential impacts from this development.
Regarding sewage management, there is some evidence of hydraulic overload in Dawlish. We would also expect to see information within any ES to demonstrate that the additional foul flows from the development will not cause deterioration in WFD waterbody status or in bathing waters in Dawlish (Dawlish Warren = excellent; Dawlish Town = good; Dawlish Coryton Cove = excellent). The applicant should liaise with South West Water to ensure that there is capacity at the sewage treatment works to accommodate the flows generated by the development. In addition, we would expect the SuDS scheme to incorporate benefits for water quality.
We welcome the applicant’s intention to prepare a Construction Environment Management Plan (CEMP) to manage the risks (which should include increased silt loads) to receiving waterbodies. The CEMP should pull together and manage the pollution control and waste management requirements during the construction phase. It should ensure that adequate pollution prevention measures are included to protect controlled waters during construction.
Run off from exposed ground / soils can pose a significant risk of pollution to nearby watercourses, particularly through soil/sediment run off and the CEMP should address how such run-off can be minimised, controlled and treated (if necessary). Please ensure that this is considered well in advance because some treatment methods can require an Environmental Permit to be obtained.
We recommend that the CEMP is drafted using guidance in our Pollution Prevention Guidelines (PPGs), in particular PPG5 – Works and maintenance in or near water and PPG6 – Working at construction and demolition sites. These can be viewed via the following link:
https://www.gov.uk/government/collections/pollution-prevention-guidance-ppg
Review of Documentation and Further Work
We would welcome pre-application consultation if the applicant would find this helpful. We will charge for our technical advice based on a standard hourly rate that enables us to cover our costs. The fee for our advice is £100 per hour plus VAT.
Please contact me if you would like to enquire about entering into a further agreement with us for technical planning advice.
Yours sincerely