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PCS-20003215 - SEPA response

Argyll and Bute Council · 8 September 2025
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OFFICIAL
OFFICIAL 
Fiona Scott Our Ref:  PCS-20003215
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   
16 October 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 re-consultation on the above planning application which was received
by SEPA on 1 October 2024 in relation to the above application. We note this follows our
previous response referenced PCS-20002028 and dated 11 July 2024. 
Following review of the information provided, we currently maintain our holding
objection to this application on the basis of flood risk and request that determination is
deferred until the information outlined below has been provided for our assessment.  
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%

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which must include an appropriate allowance for future climate change).
1.2 There is a potential fluvial flood risk from a small unnamed burn to the east of the site.
The SEPA Future Flood Maps don’t cover small watercourses (catchments <3km2),
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. The development
is potentially within the flow path of the unnamed burn in the event of out-of-bank
flooding.
1.3 A flood risk/drainage impact assessment was carried out in September 2024 by JBA
Consulting on behalf of the Planning Authority. This report provided calculations on
the culvert capacity at the northeast corner of the site. The culvert was calculated to
be able to convey flows from a 1 in 200 plus climate change flood event. 
1.4 To verify the calculations and to determine that the development is not at risk of
flooding, in the first instance, we would request the following information.
a. Topographic ground level information relating to the pre- and post-development
ground and if available minimum finished floor levels relative to Ordnance Datum.
Topographic level information should include at least one site sections and
extended cross sections across the watercourse (including the channel bed levels
and bank levels of both the nearside and opposite bank), upstream, downstream
and adjacent to the site.
b. Information on the culvert which should include the material the culvert is made
from and levels of the inlet and outlet of the culvert relative to Ordnance Datum
along with culvert length. The approximate flood relief level at the culvert is also
required. In addition to this, photographs of the culvert at the northeast corner of the
site are required. 
1.5 If the above information demonstrates that the development is well elevated above
the banks of the watercourse, we may be able to remove our objection in relation to
flood risk. However, the applicant should be aware that if this information is
insufficient to provide a robust assessment of the risk of flooding to the proposed
development, then a detailed Flood Risk Assessment may need to be carried out by a

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suitably qualified professional.
1.6 In addition to the above, in our previous response we highlighted the requirement for
a buffer strip adjacent to the watercourse. We note that this application is for renewal
of planning permission in principle and therefore a detailed site layout will be
submitted at a later stage. However, the current site layout plan shows an area of
paving over a small section of the watercourse. SEPA are generally opposed to
culverting for land gain and would expect that the watercourse is left free of
development, including an appropriate buffer area. We are likely to request this by
condition. The buffer strip should be inline with Highland Councils Riparian buffer strip
guidance in their Flood Risk and Drainage Impact Assessment Supplementary
Guidance. Although please note we may comment further on an appropriate buffer
distance following submission of the above requested flood risk information.  
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/