No Flood Risk at Burry Port? Planning Advice Lags Behind Climate Change
Planning permission for major construction in Burry Port, on the shores of Burry Inlet, could be granted by Carmarthenshire County Council, on Thursday (April 23rd). The development would be “on the Grillo site”.
I thought the fat lady had sung and it was all over. The High Court rejected the scheme in late autumn 2013, because of flooding risk. Mr Justice Cranston’s decision was reported in the Llanelli Star on November 6th 2013 under the headline ‘Rejection of Burry Port Grillo development an ‘absolute disaster’ ‘.
It wasn’t all over. Try, try and try again, and if you have enough backing, you can carry on until you get the answer you want. The ‘absolute disaster’ quote, from chair of Burry Port Yacht Club, Andrew Davies, hints at the disappointment felt by some local people, including the Pembrey and Burry Port Town council.
The Grillo site at Burry Port harbour was a chemical works run by German-owned Grillo Zincoxide (UK) Ltd, which last submitted accounts for 2005-06. You could not get a site much more ‘brownfield’ than Grillo. The land is contaminated. And liable to flood – isn’t it?
Well, somebody has altered a map. Now the flood risk has disappeared as quickly as glaciers in Antarctica. Oh. Disappearing glaciers mean rising sea levels which increase the flood risk. Surely?
Not in bureaucratland, evidently. Bonnie Palmer, development planning adviser with Natural Resources Wales, wrote to Carmarthenshire County Council on March 26th 2015 saying:
“Welsh Government has updated the development advice maps referred to under TAN 15 Development & Flood Risk (July 2004). Previously Site 6 [at Burry Port harbour] partially fell within zone C2 [at high risk from flooding, and without a significant flood defence infrastructure] however, subsequent to the recent update the site is now shown to lie outside of the C2 outline.”
A ‘TAN’ is a Technical Advice Note from the Welsh Government, and TAN 15 relates to flood risks. The introduction to the updated development advice maps states, though, that they are “not designed for small-scale investigation but as a trigger for policy advice in TAN 15”. The maps are supposed to be used only at scales of 1 inch to 0.4 of a mile or more. The updated map for Burry Port does indeed suggest that the harbour-side Grillo ex-works are at no risk of flooding, but as the introduction suggests, it should not be relied upon for a flood risk assessment of an individual site – and especially not at a time of rapid ice melt.
Carmarthenshire County Council has long been very keen for the site to be developed, by Castletown Estates Ltd. This entity is controlled by St James’s Company Ltd, 99% owned by Lord Magan of Castletown, a merchant banker and Conservative peer with a stately home in Ireland. Documents prepared on behalf of the county council show attractive artists’ impressions of colourful quayside homes, a vast improvement on today’s derelict 4.55 hectare (11.24 acre) site. Shopping and leisure developments, and up to 230 seaside homes, would be built.
Based on measures which planners are obliged to use, the flooding risk is low – but guidance inevitably lags behind the actuality of climate change and the extreme weather events which occur. The consultants Waterman Transport & Development Ltd conclude, in paragraph 5.2.6 of their Flood Consequences Assessment for Carmarthenshire County Council, that:
“The model outputs for the 0.1% probability Tidal event in 2114 are shown in Drawing No. CIV16025-CSA-90-007-A01, included in Appendix D herewith. The evolution of flooding during this scenario is very similar to that already described above. Water levels within the Outer Harbour and East/West Docks are sufficient to spill over the dock walls and flow in a northerly direction towards the B4311 Road. The peak water elevation of ~6.88m AOD [above ordnance datum, meaning above average sea level] causes flood waters to also flow in an easterly direction across the Site and over the old access road towards the adjacent Grillo Site. Parts of both Site 5 and 6 are affected by flood waters in this scenario, albeit relatively shallow depths of circa 0.3m.”
The report’s Summary Assessment, Section 8, contains the following:
“With regard to the risks associated with Tidal Flooding: – – The NRW [Natural Resources Wales] Flood Map confirms that the Site is not affected by the extreme 0.5% and 0.1% probability tidal events in the present-day (2014). – It is predicted that the Site will remain flood-free during the 0.5% probability tidal event (baseline) in 2114. However, when the Upper Confidence Interval is applied to the tide level estimate, the Site is shown to experience flooding of up to 1.3m deep during this scenario. – It is predicted that the existing Site will be partly affected by the 0.1% probability tidal event (baseline) considering future sea level rise to 2114. – It is proposed to raise ground levels within the Site to a minimum of 7.1mAOD (the 0.5% probability level in 2114, with Upper Confidence Interval applied), which satisfies TAN 15’s threshold of flooding criteria. – The Site would remain flood-free during all scenarios assessed as part of this FCA. – The raised ground does not cause a significant impact on flooding for third party land and property, when considered as part of the wider Master Plan Development. – Safe Emergency Access/Egress is available via the Southern Distributor Road.” (my emphasis)
As 2114 is 99 years into the future, and it’s only a model anyway – can only be a model – potential flooding to a depth of 1.3 metres does not sound too worrisome, maybe – but a coastal situation, affected by wind and waves, adds more potential dangers to the scenario.
The avoidance mechanism to be deployed – raising the ground level – would inevitably impact on nearby areas which have not been artificially raised, although the Waterman report rejects this repercussion.
When we know that glaciers are melting alarmingly fast, and the unfrozen water has only one place to go, how wise is it to build right next to the sea?
And at Burry Port, that’s without considering the chemical contamination of the land, the impacts on wildlife, sewage discharges from hundreds of additional people, or Network Rail’s worries about dangers facing pedestrians streaming over the Church Road level crossing.
The derelict Grillo site needs a new use, but is this really the best option? I hope that all members of the planning committee will have read and digested the encyclopaedia-sized agenda of hundreds of pages, detailing the key applications for the site, and that any concerns about climate change will not be deemed irrelevant to planning decisions.