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PCS-20005081 - 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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Page 1

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/