Letter to the press about new flood hazard

Here is the letter I sent . . .

I have sent you a copy of our email to Stephen Belli about this new flooding hazard for Seaton.  I am now sending you the supporting diagrams and explanatory argument.   Much of this is discussed on our blog at http://www.tescowatchseaton.blogspot.com/, but this had no pictures and these are essential to understanding our concerns.
 

Look at T1 above  This is taken from the sucessful Tesco planning application and shows the overall layout of the whole regeneration site.  Important here is the role of the flood relief channel, which I have marked.  

This runs from Harbour Road at the bottom of the picture (south) to the marshes at the top (north).  Harbour Road is the lowest part of Seaton and most susceptible to flooding from the sea or river.  This danger is greatly increased by raising the regeneration site and so stopping flood water draining north to the marsh.  To reduce this danger, the Tesco plan provides a flood relief channel (also called a monsoon drain or berm) running north-south right through the development site at low level, so cutting the site into two halves.

When the site is raised and a flood comes, water can flow from Harbour Road to the marshes along this channel.  Without the channel, raising the site means a serious increase in the flood risk for the whole area, which is largely residential.  We were not terribly happy about this solution, but it is better than nothing.

Now look at T2.  This shows Tesco's proposal to raise the whole site by pumping in infill from the sea.  The idea is to build a high wall right round the site, pump in a mix of seawater and aggregate along the black pipeline grid, allow it to settle, collect the seawater in a lagoon (blue arrows) and then pump it back out to sea.

The flood relief channel (FRC) is visible (and dotted by me), along with all the later buildings, so they seem to have just pasted their proposals on top of an earlier version of T1 without paying attention to the details.  They clearly have no understanding of the function of the FRC, as both the black pipeline and the blue water arrows flow straight over it, and it will be filled up with the rest of the site.  Without the FRC, the only flood protection device is lost and the whole area is at enormously greater risk of flooding.

We complained about this to the Environment Agency.  The correspondence is covered in the blog but, basically, they said leave it to the Tesco engineers.  But we can see no economic solution, and after 5 weeks, nor (it seems) can they.

Consider the options.

1.  Fill the site in two halves, on either side of the FRC.  This will require two separate filling operations, with separate piping and drainage lagoons.  It might be possible, but it is going to be very slow and very much more expensive.

2.  Fill the whole site and then dig out a new FRC.  This has two objections.

• While the site is being filled, there is no FRC.  If a flood comes along during the filling process, Harbour Road has no protection.
• Digging a channel through slippery sediment deposited from seawater is not going to be easy - and may be actually impossible.

There is no official acknowledgement of these problems, nor of the hazard to Seaton.  The Tesco contractors have made mistakes in the past (see the blog) and we are worried that they may be about to make another one - with potentially catastrophic results.

 We want EDDC and the EA openly to acknowledge the problem and tell us how they propose to deal with it.  Under these circumstances, we can only appeal to the power of the press and public opinion to bring this about.

No satisfaction yet on wall safety and flooding hazard

On 8th March (see below) we flagged up a new flood hazard presented by the Tesco scheme, and wrote to the Environment Agency on 9th March for their reaction.  In addition, we asked about the safety of the high temporary walls to be built around the site.  For several weeks there was silence - presumably while the EA consulted the Tesco consultants.  Then, on 25th March, we received their reply.

On the issue of the wall safety they say . . . "The use of hydraulic fill is a well established civil engineering technique and has been used to fill dams and move aggregates and minerals for many years. We are currently unaware of any examples where this technique has been used to fill prospective development sites in the manner being suggested in Seaton.  You may wish to search the internet for examples as they may exist.  However, we cannot rule this technique out as a possible solution to the raising the site in an efficient and timely manner.   Civil liability would rest firmly with the consultants/contractors in the event of any problems occurring.

The integrity of any temporary impounding banks is largely a matter for the consulting engineers, to satisfy themselves upon as part of any overall scheme design.  We must wait to consider any proposal that Jubbs wish to promote but shall at all times seek to protect the local environment and ensure as far as we are able that any proposal is safe.  "

To summarise the reply on wall safety. . .

1. This site infill method is unknown to them
2. If anything goes wrong, sue Tesco
3. It is up to the consultants (Jubbs) to decide on the quality of their own work
4. The EA will ensure safety as far as they are able, but no further.

Now, Jubbs are a well-known firm of engineering consultants who advised Liatris, the previous potential developers of this site.  However, anyone can make a mistake, and we were able to find a serious flaw in their flood risk analysis for Liatris.  By using an outdated version of our old friend PPS25, they proposed a much smaller (hence cheaper) infill volume than was actually required by law.  This was not noticed by the EA, nor by EDDC . . . it was left to our small team of amateurs to detect and correct it.  Our correction was then enforced without explanation or apology.

Now we are looking at a much more ambitious procedure - totally new and untried on this kind of site (says the EA). Who is to say that Jubb may not make another mistake - as they did before?  Who is going to be checking their work ?  Only the EA, as far as they are able; and how far is that ?  Judging from past performance, and the letter above - not very far at all.

Tescowatch will do it's best; but without access to the site or professional advice we may miss something.  It would be far better for the regulating authority (EA) to take on this role with committment and enthusiasm on behalf of us all - as is their function.

As far as flood protection during construction is concerned, the EA reply says . . . " Separate drainage proposals would need to be agreed prior to the main body of work proceeding. Consideration would have to be given to adverse weather, impact on watercourses and potential impact on groundwater.  We understand Jubbs have been considering a number of options to fill the site so we do not wish to speculate upon which, if any, might meet with our approval. "

This sounds reasonable enough (if rather vague), except for the fact that several site plans have already been tabled by Tesco - and approved by the EA - which show no flood protection at all during the infill phase.  Why was this problem not raised by the EA at that stage ?  Why did it have to wait for us amateurs to query it ?

No-one doubts the expertise available to the EA. Why won't they use it ?

Work about to start

ON 4th March, East Devon District Council gave Tesco's contractors the go-ahead to start work on . . . "Construction of temporary trial embankment to assess compaction/water absorption rates of soil/compacted concrete in advance of future filling operation". 

The document is called "Conditions11038258.pdf" and can be downloaded from the EDDC planning portal under the number 09/2337/FUL.  It is 16 pages long and consists of reports from:

• PJ Carey (Contractors) Ltd of Wembley describing the crushing of the hardstanding and formation into test bunds;
• Aspect Ecology from Banbury outlining the ecological safeguards to be adopted - mostly slow-worms and japanese knotweed - and providing a blurred site plan;
• Delta-Simons Environmental Consultants of Lincoln who reply to queries from the Environment Agency about unexpected contamination procedures.

The various Tescowatch teams are looking in detail at these reports; but a problem is presented by the poor quality of the site plan.  I have written to Aspect Ecology asking (nicely) for a better copy of the plan.  If and when it arrives, I will post it on this blog.

It is clear that Tesco are calling in contractors from across the land - no local employment opportunities here.  It also looks serious - giving every indication that they mean to go ahead with this very ambitious operation.

Interesting times . . . in the Chinese interpretation.

A new flood hazard for Seaton

Many of us are worried about flooding along Harbour Road in Seaton - one of the lowest streets in the town.  What is more, we consider that building an eight-foot embankment between the road and the marshes will only make things worse.  Tesco's solution is to cut a channel - a monsoon drain - in the embankment half-way along Harbour Road leading to the marshes to drain the flood water away from the road.

The trouble with this solution is that the flood water will have to flow from both ends along Harbour Road towards the middle to reach the drain.  Their engineers admit this flow would be fast enough to knock someone off their feet - which seems to us to be a serious disadvantage .

However, East Devon District Council saw no problem, and the monsoon drain has been adopted as the solution to flooding in Harbour Road.  We might be knocked off our feet, but the water level will drop, sooner or later, so hold on tight to something or other and there will be nothing to worry about !

Since then, we have heard about the sea-borne infill plan to raise the level of the land by the eight feet required.  Tesco want to build a twelve foot wall around the whole site, pump in a slurry of sea-water and silt, let it settle and pump the water back into the bay.  This is a very ambitious - some say impractical - operation with a long list of disadvantages.  To this list we must now add one more - a major increase in the flooding risk.

Tesco's twelve foot wall has no monsoon drain: it runs without a break round the whole site so that the slurry can spread to all parts and find it's own level.  So, if a flood comes while the wall is up, Harbour Road will lack even the inadequate protection of a monsoon drain to the marshes.

We have asked the Environment Agency to look at this problem.  We will let you know what they say.

Heritage denied ?

Here in Seaton it is easy to forget that we live on top of important ancient remains - and the Regeneration Area is no exception.

Devon Archeology wrote to East Devon District Council in December last year warning that the Tesco ziggurat might damage some early post-medieval salt panning remains and suggesting that the land be surveyed before any work is done.  We are urgently seeking confirmation of the position, but we understand that EDDC have refused to listen to this advice.

If their refusal is confirmed, this is but the first nail in the coffin of Seaton's heritage.  We recognise that the needs of tomorrow must, in the end, take precedence over the remains of our ancestors, but that is no excuse for gross vandalism.  The archeologists would not stop the work, only delay it until a record is taken.  The TV programme Time Team has shown how popular archeology has become, so this could represent an important increase in Seaton's tourist offering.

PPG16 Archeology and Planning advises : "No development shall take place within the area indicated (this would be the area of archaeological interest) until the applicant has secured the implementation of a programme of archaeological work in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the Planning Authority."  

Unfortunately, PPG16 can only advise, not direct; so local authorities can choose to ignore it.  How EDDC makes this choice will tell us a great deal about how much they value the traditions and heritage of the Axe Valley, and how much they value a lickspittle compliance with Tesco hurry-up tactics.   If they are rushing this minor operation, how will they respond when something really serious comes along - such as designing the wall around their great lake of seawater and silt.

This infill project is fast becoming one of the most radical, most expensive and most ridiculous operations of recent planning history. 

Pyramid approval - and the dominance of the Net

Tesco's plan to build a test pyramid on the Regeneration Area has been approved - subject to a number of conditions, some of them important.  The Decision Notice setting out these conditions is dated 7 February, which is a Sunday; so it seems the busy little elves of East Devon's Planning Department are working right through the weekend to see Tesco right.

By the magic of the World Wide Web this document is available for all to see - as long as they have a computer with internet access . . . but what happens if they do not ?  One of the Environment Team is in this position, so I tried to order a paper copy of the PPS25 Practice Guide (see previous post) at a cost of £22.  Three different people representing the Department of Communities and Local Government told me it was not available in print, in spite of the promise given on their website.  It seems we have to download it and then print it out for ourselves.

This seems a step too far.

New Flooding Regulations - and a call to Tesco shareholders

Building on a flood plain - which Tesco are trying to do in Seaton - is governed by Planning Policy Statement 25 (PPS 25 to its friends) entitled "Development and Flood Risk". 

PPS25 was published in December 2006 and came as a terrible shock to Liatris, who owned the site before Tesco.  It takes account of sea-level rise and requires the site to be able to resist floods for 75 years in the future.  Liatris planned to do this by dumping a million tons of rubble on the site, so raising the level by 8 feet - totally ignoring other, greener ways of developing the site.  Tesco seem to have adopted the same intransigent attitude.

PPS25 is not a straightforward document and its interpretation has been a point of controversy. A Practice Guide was published to assist this, but still East Devon District Council and the Environment Agency supported the view favoured by the Developer, ignoring that presented by Seaton Development Trust and the community. 

Now, the overall planning decision has been made and Tescowatch is not trying to rewrite history . . . but the Government has decided to rewrite the Practice Guide.  Dating from December 2009, the Guide now includes several important changes which make the infill process even more ridiculous and expensive.  Tescowatch will see that these changes are fully honoured - in the observance rather than the breach - in the coming infill planning proposal.

A small sub-committee of the Environment Team is considering the changes and will report back in due course.  In the meantime, we invite all Tesco shareholders to ask the Directors at the next AGM in June why their management is spending so much of investors' money building the most expensive Tesco supermarket in the world on a floodplain in a little seaside town served only by narrow country roads.