PCS-20002026 - SEPA response
Argyll and Bute Council · 8 September 2025
Back to Argyll and Bute Local Review Body — 8 September 2025 and its agenda
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OFFICIAL OFFICIAL Our Ref: PCS-20002026 Planning Department Your Ref: 24/01069/PPP Argyll and Bute Council SEPA Email Contact: By email only to: planning.olandi@argyll- bute.gov.uk planning.north@sepa.org.uk 11 July 2024 Dear Fiona Scott Town and Country Planning (Scotland) Acts Renewal of planning permission in principal reference 19/02562/PPP (approved at appeal) (Site for the erection of 2 dwellinghouses) Land South East Of Elderslie, Oban, Argyll And Bute Thank you for your consultation which was received by SEPA on 19 June 2024 in relation to the above application. We understand the reason for consultation is Flooding. Thank you also for your further email of 19 June confirming that the proposal does not fall within any of the exceptions set out in NPF4 Policy 22(a). Unfortunately, the information supplied with this planning application is insufficient to allow us to determine the potential impacts in terms of flood risk. We therefore submit a holding objection and request that determination be deferred until the information outlined below has been provided for our assessment. If the planning authority proposes to grant planning permission contrary to this advice on flood risk, the Town and Country Planning (Notification of Applications) (Scotland) Direction 2009 provides criteria for the referral to the Scottish Ministers of such cases. You may therefore wish to consider if this proposal falls within the scope of this Direction.
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OFFICIAL OFFICIAL 1. Flood risk 1.1 In line with National Planning Framework 4 (Policy 22), a precautionary approach to flood risk should be taken by avoiding development within areas at risk of flooding (land or built form with an annual probability of being flooded of greater than 0.5% which must include an appropriate allowance for future climate change). 1.2 The site is not shown to be at risk of flooding based on the SEPA Future Flood Maps. However, a small unnamed watercourse (with a catchment of less than 3km2) is located at the east perimeter of the proposed development. The SEPA Flood Maps don’t cover small watercourses, but they can still cause serious flooding. You can view the SEPA Flood Maps and find out more about them at Flood Maps | SEPA - Flood Maps | SEPA. 1.3 There are small culverts situated approximately 8m upstream of the site on the access track to the south and downstream of the site adjacent to Elderslie Guest House. The path of the watercourse runs through a wooded area which could cause a blockage to the culvert structures. If the upstream culvert was to become blocked, it may result in an overland flow path which could inundate the site, similarly blockage of the downstream culvert could cause water to back up and inundate the site and other local receptors. We would expect a site-specific assessment to consider a range of blockage scenarios to investigate these potential flooding mechanisms. 1.4 We therefore submit a holding objection to the proposed development as it is potentially at risk of fluvial flooding. To enable us to review our position, we ask that a detailed Flood Risk Assessment (FRA) is provided which has been completed by a suitably qualified professional. This should consider the risk from the unnamed watercourse. For more information on SEPA’s requirements for detailed flood risk assessments, please see our Technical flood risk guidance for stakeholders (sepa.org.uk), section 3.3. Please note this document is currently being updated to reflect changes due to NPF4, so some information may be out-of-date. Advisories 1.5 We advise that you contact your Flood Risk Management Officer who may be able to
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OFFICIAL OFFICIAL provide further information regarding flood history and flooding issues in the area. 1.6 Safe access/egress by emergency vehicles and surface water risks are matters under the remit of the local Flood Risk Management Authority at Argyll and Bute Council. It is therefore for the Council to consider theses issues. 1.7 We recommend that an appropriate buffer zone is considered. We recommend that for channel widths of less than 2 meters, a riparian corridor with of 10 meters remains undeveloped on each channel bank. 2. Other planning matters 2.1 For all other planning matters, please see our triage framework and standing advice which are available on our website: www.sepa.org.uk/environment/land/planning/ 3. Regulatory advice for the applicant 3.1 Details of regulatory requirements can be found on the regulations section of our website or by contacting our local compliance team at ahsh@sepa.org.uk. If you have queries relating to this letter, please contact us at planning.north@sepa.org.uk. Your sincerely Jessica Fraser, Planning Officer, Planning Service Ecopy to: fiona.scott@argyll-bute.gov.uk Disclaimer: This advice is given without prejudice to any decision made on elements of the proposal regulated by us, as such a decision may take into account factors not considered at this time. We prefer all the technical information required for any SEPA consents to be submitted at the same time as the planning or similar application. However, we consider it to be at the applicant's commercial risk if any significant changes required during the regulatory stage necessitate a further planning application or similar application and/or neighbour notification or advertising. We have relied on the accuracy and completeness of the information supplied to us in providing the above advice and can take no responsibility for incorrect data or interpretation, or omissions, in such information. If we have not referred to a particular issue in our response, it should not be assumed that there is no impact associated with that issue. For planning applications, if you did not specifically request advice on flood risk, then advice will not have been provided on this issue. Further information on our consultation arrangements generally can be found on our website planning pages - www.sepa.org.uk/environment/land/planning/