The management of rainwater in and from the site is recognised as a significant issue by Leeds City Council and M & G.
- Flooding is a fear for villagers in Aberford; the mitigation plans have not been presented to the public other than referred to in previous documents such as Leeds’s SAP 60469705 dated March 2016. Therein references are made to the use of Cock Beck and River Crow as well as to the use of living rooves, basins, ponds, filter strips and swales, soakaways, permeable surfaces and tanked systems. All of these techniques will have a detrimental effect on the Ancient Woodland and surrounding land and I believe are, therefore, not valid.
- In addition, I believe that the peak load of run-off water will put Aberford at risk;
- The 9th principle sets out that plans should “recognise that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production);
This cannot be considered to be the case in relation to flood risk mitigation for the local area and beyond;
- The area of the Parlington Estate is vital as part of the local ecology and flood protection creating natural protection and regulation of water run-off into the local Cock Beck and River Crow thereby protecting the local villages of Aberford and Stutton from flood risk. Flooding has already occurred in recent years in 2000, 2008 and 2014. The attached photograph indicates some of the flooding on the Estate in the winter of 2015/16 (despite it being designated in Flood zone 1);
- Both the River Crow and Cock Beck are tributaries to the River Wharfe, with their confluence occurring at Tadcaster. Tadcaster was the scene of severe flooding and the destruction of the historic road bridge in the winter of 2015/16. Whilst the area itself is within flood zone 1 and therefore designated as a low probability of flooding it is the protection provided and the additional water run off that will have a significant impact on the surrounding area. I believe that this is clearly in contravention of the 9th planning principle;
- The construction of such a significant development as proposed on the Parlington Estate will fundamentally alter both the flood mitigation provided by woodland, arable land and flood plains but also have a clear impact on the water table in the area severely heightening the flood risks that have already been seen. The plans themselves include the building on land that was utilised by the Parlington Estate as an area for flood mitigation that will be lost as part of this development;
- The increase in hard standing roadways and housing water run-off will significantly affect the way in which water is deflecting to watercourses flowing into the local water systems and make the project too dangerous for Leeds City Council to proceed with MX2-39;
- This is acknowledged in the proposal (paragraph 5.6.15) which states that, “Rainwater that does not infiltrate would need to be discharged via attenuation facilities to Cock Beck, which runs along the western and northern boundary, with flow restricted to greenfield runoff values. This means that balancing, detention or retention ponds should direct their outlets to the Cock Beck”. It is also recognised within the proposal that, “The proposed development will introduce some impermeable areas, reducing the greenfield areas that currently permit rainwater to infiltrate into the ground. This will increase rainfall runoff from the site.” As noted above this will have a considerable impact both on the flood risk to the villages of Aberford and Sutton as well as into the river Wharfe at Tadcaster. There are insufficient measures indicated in the proposal that would mitigate this increased risk for areas that are already susceptible to flooding – such as those areas identified as zone 2 and 3 flood zones in the centre of Aberford as determined by the environment agency;
- I have calculated that the hard-standing areas for car parking alone will exceed 11 ha. This is an approximation based on government figures for the space that should be provided for every car. My calculation clearly shows that the Council is aware of the huge problem but is understating the magnitude of the problem in order to get the MX2-39 project past the Inspector;
- Paragraphs 99 to 104 of the NPPF are clear in their consideration of flood risks and the building on areas that are of use in the mitigation of flood risks. I do not believe that either the sequential or exception tests have been adequately applied in relation to the ‘downstream’ impacts as other brown field sites such as Thorpe Arch (EG1 – 9-64) would not have these related issues due to the topography of the land and its current use;
- The occupants of the houses will create a level of pollution that is detrimental and unmanageable and will destroy not only Parlington’s Ancient Woodland but the Ancient Woodland of the surrounding areas. M & G’s proposal does not mitigate these problems. M & G’s proposal does not sufficiently manage the sewerage nor the rainwater issues from the 10,000 to 15,000 people proposed to be living MX2-39. I cannot understand why Leeds City Council is proosing and supporting a population density of over 9,000 per sq.km.