PCS-20005081 - SEPA response
Argyll and Bute Council · 8 September 2025
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OFFICIAL OFFICIAL Graham MacEachen Our Ref: PCS-20005081 Your Ref: 24/01069/PPP SEPA Email Contact: By email only to: gm@pointfivebd.com planning.north@sepa.org.uk 22 April 2025 Dear Graham MacEachen Town and Country Planning (Scotland) Acts 24/01069/PPP 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 email relating to the above planning application which was received by SEPA on 30 March 2025. We note this follows our previous response referenced PCS- 20003215 (16 October 2025). As this relates to a live planning application, we have also copied in the case officer at Argyll and Bute Council for information. We have considered the two photographs attached to your email. However, unfortunately these are not sufficient to demonstrate that the site is not at risk from flooding. We therefore currently maintain our holding objection to this application on the basis of flood risk. We confirm that our previous comments (PCS-20003215) still apply. Please therefore refer to our previous letter. We have also provided some further explanation below which we hope will assist.
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OFFICIAL OFFICIAL 1. Flood risk 1.1 In our previous response (PCS-20003215) we requested that a topographic ground level survey relative to Ordnance Datum is undertaken to assess the fluvial risk to the site from the small unnamed burn at the site. Small watercourses can cause serious flooding, especially during summer convective storms, which have been observed to generate the highest peak flows in small catchments such as this one. It therefore needs to be ensured that the site is not at flood risk from this small watercourse pre- and post-development, which is why minimum finished floor levels are also requested, if available. As the Planning Authority has confirmed that this site does not fall into any of the exceptions of National Planning Framework 4 (Policy 22a), the development site must sit outwith the flood risk area. 1.2 We also asked that topographic ground level information 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. This is to determine whether the channel can convey flows of a 1 in 200 year flood event, with an allowance for climate change, without flooding the site. We appreciate the submission of photographs of the channel however we cannot determine cross sectional levels from these photographs. 1.3 As previously highlighted, we acknowledge the assessment carried out in relation to the culvert in the northeast corner of the site in September 2024 by JBA Consulting. However, to enable verification, and to ensure the culvert can convey flows from a 1 in 200 plus climate change flood event without affecting the development site, we asked that information be submitted on: the material the culvert is made from, levels of the inlet and outlet of the culvert relative to Ordnance Datum, culvert length, the approximate flood relief level at the culvert and photographs of the culvert at the northeast corner of the site. It is particularly important that full consideration is given to the culverts as the development is situated within a wooded area, and therefore blockage from wood debris can affect the conveyance of flows.
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OFFICIAL OFFICIAL 1.4 For our full advice, please see our previous response, which also included advice on buffer strips. We will be happy to review our comments following submission of the above requested information. However, we wish to highlight that if that 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 suitably qualified professional. If you have queries relating to this letter, please contact us at planning.north@sepa.org.uk including our reference number in the email subject. 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/