Comment

Representation ID: 23092

Received: 11/10/2021

Respondent: Canal & River Trust

It is important to ensure that policy CC5 is effective in minimising the probability and consequences of flooding from all sources, in accordance with the NPPF. Whilst f
some points of this policy, we suggest that part 1 The BCA will seek
to minimise the probability and consequences of flooding from all sources is referred to within some points of this policy, we suggest that part 1 of the should be amended to state 'The BCA will seek to minimise the probability and consequences of flooding FROM ALL SOURCES by...' (and the amendments that we suggest to CC1) would help to ensure that the requirement is clear from the outset.

The Trust owns and manages reservoirs within the Black Country. Building properties in the inundation zone of a dam could adversely alter the risk assessment for the reservoir which may require additional works to be carried out at the expense of the applicant/developer, to reduce the risk to an acceptable level. Whilst the likelihood of reservoir failure may be considered low, the consequences of such a failure can be significant. The failure of a reservoir has the potential to cause catastrophic damage due to the sudden release of large volumes of water. This change in risk cannot be properly quantified and assessed without detailed information and may require updated breach models, funded by the developer, to compare the current and proposed consequences of a dam failure. The outcome of this modelling should then form a key part of the Flood Risk Assessment for the site and will aid in determining whether mitigation measures either on or off-site can alleviate flood risk concerns and make the development compliant with national planning policy. This work would be necessary for the Trust to determine whether the applicant / developer will need to fund any work at a reservoir to mitigate increased risk. It should however be recognised that it is highly unlikely to be able to remove the risk entirely.

Developers need to be aware that sluices and weirs that CRT use to remove excess water from canal infrastructure may run in culvert under their site - even some distance from the canal. The same applies for feeders. Feeder abstraction points will soon be under licence conditions so any development near a point on a watercourse where the Trust abstracts must not alter the current set up.