Environment Agency Flood Risk Assessment Rejection

Environment Agency has released data for the 2012 to 2013 period which shows that the majority of planning applications objected to on “flood risk grounds” were rejected  because they considered the FRA (Flood Risk Assessment) provided to be unsatisfactory.

What does this mean, why and what if anything can be learned from it?

a) Not written by a professional civil engineering consultant. Some FRAs submitted are basic documents produced by Architects, Surveyors or others who lack the professional expertise and skill necessary to produce such reports. As the reports do not comply with the standards expected they can be rejected, even if the specific circumstances could be acceptable. Some companies on the web say they offer free or nominal £20 professional flood risk assessments and this can confuse the public. Obviously these can’t comply as they are not specifically written by a professional engineer about a site.

b) The Environment Agency reasons for rejection are not appropriate or correct. There are many cases where Environment Agency officers have rejected proposals based on elements which are specifically outside their remit or are completely out of context. A classic example is that a certain site needs dry access rather than safe access or when the EA refer to highway, or sewerage issues, for which they are not the appropriate Authority to advise on such matters.

c) The Local Authority has failed to produce adequate mapping showing 3a and 3b complaint with NPPF and current Government Advice. The EA fails to accept that it provides evidence on hydraulic grounds and that the responsibility for confirming zones 3a and 3b ONLY lies with the Local Authority. Where the Local Authority has failed to produce such evidence then the grounds for rejection are questionable.

d) Finally, it is possible that the Independent Civil Engineering Consultant’s conclusions are not accepted and rejection is substantiated.