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Ham Road – Application No. 23/ 502113 - Flood Risk – Third Supplemental Representation

The Faversham Society are disappointed that the EA have not responded to our last
representation, submitted on 11th September 2023, which further addresses flood risk
from the sea.

We are concerned to note that due process has not been followed by the EA when
issuing their letter dated 24th August. This withdrew your previous objection to the
application and set out draft conditions for the Local Authority to impose if Swale were
mindful to grant consent. This withdrawal letter may have crossed with our letter dated
22nd August (attached for ease of reference).

It appears that the EA have not directed the applicants to rebase their flawed Flood
Risk Assessment submitted with the initial application. This was modelled on an
incorrect assumption that the site was defended from flood risk from the sea. It is not,
as you have since acknowledged.

No account has been paid to the Flood Risk and Coastal Change Guidance, published
by the Department of Levelling Up Housing and Regeneration in support of the 2022
NPPF. This identifies that development, or the cumulative impacts of development,
may result in an increase in flood risk elsewhere. The guidance directs that the impact
of deflection of flood waters or constriction of flood flow routes (an inevitable
consequence of obstruction created by ground raising) should be assessed in the
site-specific FRA to identify any impacts and demonstrate how mitigation measures
have addressed them.

We had expected to see a revised assessment modelling the undefended scenario
prior to validation of the approval. This should also have taken into account the impact
of diverted flood waters on the residential properties and industrial estate immediately
adjoining the development site in accordance with the guidance.

We are concerned that this ‘process omission’ exposes Swale to the risk,
inconvenience and cost of judicial review should consent be granted. In the light of
this we wish to formally request that the EA respond to the two questions posed in
our last representation.

1. Please can you confirm whether the withdrawal of this objection is supported
by a revised FRA and if not how the withdrawal of this objection has been
2. Clarification from the EA and Applicant was also requested to establish that
Flood risk guidance parameters have been addressed and specifically that
the updates from the UK Climate Projections: Headline Findings Aug 2022
have been incorporated.

Please can we request that you respond to both these queries

November 27, 2023

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