Comments on Dawn Homes’ Phase 2 Planning Application
I am writing on behalf of the Allanton Park Terrace Residents’ Association, whose aims and constitution were agreed at a series of minuted meetings between January and March this year and are available for scrutiny on request.
We are generally supportive of the comments and objections made, or shortly to be made, by Fairlie Community Council on behalf of the community as a whole, but we have specific concerns about the issues raised in the Flood Risk Assessment (FRA) as they relate to local residents, and to the marine environment in Fairlie Bay.
- The FRA highlights a number of water courses running through the site, one of which is the Keppen Burn;
- The results of their own modelling (pages 25-35) indicate that the risk of significant flooding will increase around the petrol station, the train line and the access road junction on the A78 when work is undertaken on the proposed new site;
- The FRA recognises that the current drainage system through the existing culvert is insufficient and liable to blocking as things stand. This was demonstrated over the last winter, when flooding was clearly shown to have increased, when siltation was unacceptably allowed to flow into the sea through the Keppen Burn culvert, and when several remedial attempts to address the problem were shown to be inadequate;
- In order to mitigate against the increased risk of flooding it is proposed to make significant alterations to the Keppen Burn culvert that runs under the A78, Marine Court and Pier Road to the outfall on Fairlie Beach at the end of Allanton Park Terrace (see Figures 7 & 8). The size of structure required for the upgrade of the culvert to manage the expected flow of water appears, by the figures given, to be approximately four times the size of the current culvert.
- The Flood Risk Assessment refers to ‘unattenuated surface water flows’ to be discharged from the developed site directly into the Keppen Burn – but there is no modelling of what impact this would have on increasing flooding risk to those between the site and the sea (Figure 6.6), or on the fragile marine environment in Fairlie Bay, Southannan Sands etc.
- There is mention of overland flow pathways being added to mitigate against culvert blockage as water flows west to the sea, but there is no explanation of what this means and the likely impact of them raising flooding risk for properties between the site and the sea (Figure 6.6).
General Comments and Questions Arising:
Flood Risk Assessment:
- The FRA is very technical. As lay people how do we know that the parameters used for the mathematical modelling are correct and the risk not underestimated? For example, has the effect of rising tidal levels, the likely increase in the occurrence of storm surges andthe effect of putting unattenuated surface water runoff direct into the Keppen Burn been included?
- Figures 5 & 6 do not show the western extent (i.e. Pier Road, Allanton Park Terrace, Fairlie Beach) of the model or predicted flooding. There is a clear blue ‘Issues’ line drawn on figure 6 that is at the end of Allanton Park Terrace and around the whole of the beach area. What are these issues and what is the data on them?
- If the culvert required to manage flooding upstream needs to be four times the size of the existing culvert, what quantity of water is being anticipating as having to flow, and what will be the impact on the area of the outfall at Fairlie Beach and the integrity of the Allanton Park Terrace retaining/sea wall?
Potential Environmental Impacts
- What are the likely effects on the marine environment of the beach and the waters of Fairlie Bay of the significant sedimentation from the site that the report refers to?
- What are the risks of pollutants and other contaminants entering the Keppen Burn and Fairlie Beach from allowing unattenuated site surface water to run off directly into the Keppen Burn?
General Comments: The document refers to a consultation with SEPA on flood planning. Our experience is that North Ayrshire Council & SEPA have not been interested in helping us address recent questions regarding the maintenance of the sea wall that runs along Allanton Park Terrace. As a result, we formed the Allanton Park Terrace Residents’ Association to enable us to engage effectively with local issues that affect the terrace. We need assurances that any increase in flow or volume of water onto Fairlie Beach will not affect the integrity and maintenance costs of the retaining/sea wall. In addition, no mention is made of the likely impact of significantly increasing the size of the culvert on surrounding properties, and on properties beneath which the culvert runs.
Necessary urgent action:
- We require a report of the data and an analysis in plain English that shows full modelling of the flows through the Keppen Burn and includes the whole of the western section between the A78 and Fairlie Beach, and the impact of mitigation proposals.
- We require that SEPA and North Ayrshire Council advise on how best we can work with them to understand the impacts on surrounding properties and the retaining/sea wall along Allanton Park terrace.
- We require a full environmental impact assessment (EIA) to address the impact of increased volume and flow of unattenuated surface water.