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Standard Life Investments UK Proposed Pod Unit at Interchange Retail Park, Bedford Flood Risk and Drainage Assessment 132014 - R1(0) - FRA eee eoi3 ee RSK GENERAL NOTES Project No.: 132014 - R1(0)- FRA Site Name: Proposed Pod Unit at Interchange Retail Park, Race Meadows Way, Bedford, Bedtordshire, MK42 7AZ Report Title: Flood Risk Assessment Client: ‘Standard Life Investments UK Date: June 2013, ef Technical Author R Armstrong Reviewer M Cheeseman Project ‘Manager MCheeseman J Cooling fe. Com— S.th Gols Date: June 2013 Date: dune 2013 ASK LDE Lid (FISK) has prepared this reprt forthe sole use ofthe client, showing reasonable kil and care, or the intended purposes as stated in the agreement under which this work was completed. The fepor may not be relad upon by any other arty without the express agreement of the clent and SK. No her warranty, expressed of implied, 1¢ made af 10 tho Droltesiona advice included inthe rapa Where any data supplied by the client or from other sources have been used, It has been assumed that the information is Correct. No responsiblity can be accepted by RK for inaccuracies inthe dala supple by ary other pary. The conclusions land recommendations in this report are based on the assumption that all relevant information has been supped by those bodies from whom itwas requested. No par of this report may be copled or duplicated without the express permission of ASK and the party for whom it was prepared, Where feld investigations nave been cari out, these have boon restricted toa level of detail required to achive tho stated ‘objectives ofthe work. This work has been undertaken in accordance withthe quality management system of RSK LDE Lid. ‘Standard Lie Investments UK Interchange Retal Park, Betors Flood Risk and Drainage Assessment 132014-81(0)-FRA CONTENTS INTRODUCTION. CONTEXT AND SCOPE OF WORK. ‘SITE DESCRIPTION DEVELOPMENT PROPOSALS.. LEGISLATION AND POLICY CONTEXT. SOURCES OF INFORMATION .. SOURCES OF FLOOD RISK.. PLANNING CONTEXT.. SURFACE WATER DRAINAGE ASSESSMENT. 10 FLOOD MITIGATION MEASURES....... 11, CONCLUSIONS AND RECOMMENDATIONS 12 REFERENCES. wervoanens FIGURES Figure 1 ~ Site Location Plan Figure 2 — Existing Site Layout Figure 3 — Proposed Site Layout Figure 4 — Environment Agency River and Sea Flooding Map Figure 5 — Environment Agency Reservoir Flooding Map APPENDICES ‘Appendix A - Service Constraints ‘Appendix B - Technical Guidance Notes ‘Appendix C - Development Proposals, ‘Appendix D — Environment Agency Correspondence ‘Appendix E ~ Bedford and River Iver intemal Drainage Board Correspondence ‘Appendix F — Strategic Flood Risk Assessment Maps ‘Appendix G — Preliminary Flood Risk Assessment Maps ‘Appendix H — Anglian Water Sewer Records ‘Appendix | ~ NPPF Technical Guidance: Flood Zones and Land Use Vulnerability ‘Appendix J - WinDes Calculations — iol Surface Water Runott ‘Appendix K - WinDes Calculations — Quick Storage ‘Standard Life Investments UK Interchange Retail Park, Bedtord Fiocd Risk and Drainage Assossment 132014-A1(0}FRA 1 INTRODUCTION RSK Land and Development Engineering Ltd were commissioned to carry out a Flood Risk Assessment (FRA) for Standard Life Investments UK (Client). The assessment is in support of a planning submission for the development of a new Costa Coffee pod unit (Site) at Interchange Retail Park (retail park), Bedford. A key element of project development is to prepare an FRA to establish the flood risk associated with the proposed development and to propose suitable mitigation, it required, to reduce the risk to a more acceptable level. ‘The assessment has been prepared in accordance with the National Planning Policy Framework (NPPF) ‘**"") and its accompanying technical guidance document “*"”), the Interim Code of Practice for Sustainable Drainage Systems (ICPSDS) “*'” and British Standards (BS) 8533-2011 Assessing and Managing Flood Risk in Development Code of Practice * *, with site-specific advice from the Environment Agency (EA), the Local Planning Authority (LPA), Indigo Planning Limited, RGP Architects and the Client. NPPF sets out the criteria for development and flood risk by stating that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. The key definitions are: * "Areas at risk of flooding” means land within Flood Zones 2 and 3; or land within Flood Zone 1 which has critical drainage problems and which has been notified to the local planning authority by the Environment Agency; and ‘+ “Flood risk” means risk from all sources of flooding - including from rivers and the sea, directly from rainfall on the ground surface and rising groundwater, overwhelmed sewers and drainage systems, and from reservoirs, canals and lakes and other articial sources. For this Site, the key aspects that require assessment are: ‘©The EA's indicative flood map shows that the Site lies within Flood Zone 1, 2 and 3; Part of the Site is at ‘high’ risk of flooding from Elstow Brook; and ‘© To review the impact of other sources of flooding associated with surface water, sewer and groundwater flooding, ‘The comments given in this report and opinions expressed are subject to RSK Group Service Constraints provided in Appendix A. Standard Lie Investments UK Page t Interchange Retail Park, Bedford Flood Risk and Drainage Assessment 132014-F1(0)-FRA 2 CONTEXT AND SCOPE OF WORK The scope of work relating to an FRA is based on the guidance provided in Section 10 of NPPF ‘"*"") and its accompanying technical guidance "*", site-specific FRA must demonstrate that the development will be safe for its lifetime (in this case 60 years for commercial development), taking account of the vulnerability of its users without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. The scope of this assessment therefore comprises the following elements: ‘+ To review plans, planning information and other studies to determine the existing site conditions; ‘+ Toobtain the views of the EA, including scope, location and impacts; ‘+ To obtain information on the hydrology and hydrological regime in and around the Site; ‘+ Todetermine the extent of new flooding provision and the influence on the Site; ‘+ To review site surface water drainage based on the proposed layout and to determine the extent of infrastructure required; ‘+ To assess the impact on the Site from climate change effects and anticipated increases in rainfall over a 60 year period for commercial uses; and ‘+ To prepare a report including calculations and summaries of the source information and elements reviewed. Appendix B of this report provides clarity of the scope of site-specific FRA’s and includes extracts from NPPF technical guidance "*®, ICPSDS *" ® and BS 8533- 2011 4) ‘Standard Life Investments UK Page2 Interchange Retail Park, Bedtora Food Risk and Drainage Assessment 192014-81(0)-FRA SITE DESCRIPTION 3.4 Location Site Name: Interchange Retail Park, Bedford Site Address: Interchange Retail Park, Race Meadows Way, Bedford, Bedfordshire, MK42 7AZ Site National Grid Reference: 503936, 246729 Interchange Retail Park is a Sha retail park located in the southwest of Bedford approximately 3km from the town centre. The retail park is north of the A421 road and east of Wobum Road Industrial Estate. The retail park comprises 13 pod units, a fast food outlet, car parking, service areas and an access road from Polo Field Way. The Site is located in the eastern comer of the retail park close to Polo Field Way. Figure 1 shows a site location plan. 3.2 Site Land Use and Topography The Site is currently an area of landscaping and car parking. The approximate land use of the existing Site is as follows: ‘* Total Site Area: 500m’ (0.050ha) ‘+ Existing Hardstanding (car parking): 167m? (0.017ha) = 33% ‘+ Existing Permeable Area (soft landscaping): 333m (0.030ha) = 67% The Site topographic survey was undertaken by Site Surveying Services. The retail park falls in a south-westerly direction from a high point of 29.99 metres above ordnance datum (m AOD) in the northeast to a low point of 29.06m AOD in the southwest. Consultation with Site Surveying Services confirmed that levels are based on ordnance datum. Figure 2 shows the topographic survey and the existing site layout. 3.3 Site Geology Based on the British Geological Survey (BGS) online geological mapping viewer, the underlying superficial geology comprises Head Clay, Silt, Sand and Gravel. This is a poorly sorted and poorly stratified layer essentially made up of sand and gravel with ‘small pockets of clay and silt. The bedrock geology underlying the superficial layer consists of Peterborough Mudstone - a sedimentary, organic-rich layer - to depths of 63 metres below ground level (mbGL), Standard Life Investments UK Pages Interchange Retail Park, Bedtord Flood Risk and Drainage Assessment 132014-A1(0)-FRA 3.4 3.5 3.6 Hydrogeological information was obtained from the EA's online mapping service. The Mudstone bedrock is not designated an aquifer. The overlying superficial deposits are designated a Secondary A Aquifer (defined as a permeable layer capable of supporting water supplies at a local rather than strategic scale). This minor aquifer has a low vulnerability to contamination. The Site does not overlay a Groundwater Source Protection Zone (SPZ). The nearest SPZ is a Total Catchment (Zone 3) SPZ approximately 2km to the north of the Sit. Site Hydrogeology Site Hydrology ‘A tributary of the River Great Ouse, known as Elstow Brook, flows in a north-easterly direction to the north of Site. The closest point to Site is approximately 100m to the north. Elstow Brook is maintained by Bedford and River Iver Internal Drainage Board (IDB), which is part of Bedford Group of Internal Drainage Boards. ‘The main channel of the River Great Ouse flows approximately 1.7km to the northwest of Site through the Kempston area of Bedford town. This is classified as a ‘Main River’ by the EA. Interchange Retail Park balancing pond, which is owned by Bedford IDB, is sited approximately 10m to the southeast of the Site. Numerous balancing ponds associated with flooding of the River Great Ouse are located in the Bedford Borough. ‘There are no British Waterway owned canals within the Bedford Borough. Site Drainage The Site topographic survey, shown in Figure 2, shows two surface water drains adjacent to the Site. One drain runs to the east of the Site within Race Meadows Way. The survey states that at the upstream manhole “invert can't fee! bottom” and at the downstream manhole it is “ull of water’. The second drain appears to run downslope from 29.13m AOD at the retail units to the west of Site to 29.08m AOD at the western corner of Site. ‘Standard Life Investments UK Page + Interchange Retail Park, Bedford Food Risk and Drainage Assessment 132014-81(0)-FRA 4 DEVELOPMENT PROPOSALS The proposed development is a Costa Coffee pod unit, including outside seating and car parking. The approximate land use of the proposed Site is as follows: ‘+ Total Site Area: 500m? (0,050ha) ‘+ Proposed Building Footprint: 149m? (0.015ha) = 30% ‘+ Proposed Hardstanding (outdoor seating area/car parking): 251m? (0,028ha) = 50% ‘+ Proposed Permeable Area (soft landscaping): 100m? (0.010ha) = 20% Figure 3 shows the proposed site layout. Full development details are contained in ‘Appendix C. Standard Lie Investments UK Page 5 Interchange Fetal Park, Bedford Flood Risk and Drainage Assessment 132014-A1(0)-FFAA 5 _ LEGISLATION AND POLICY CONTEXT 5.1 National Table 5.1: National Legislation and Policy Context Legislation National Planning Policy Framework (2012) Doar The aims of planning policy on development and flood risk are 10 ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at Tisk of flooding, and to direct development away from areas at highest risk. Where new development is, exceptionally, necessary in such areas, policy aims to make it safe without increasing flood risk elsewhere and where possible, reducing flood risk overall. Flood and Water ‘Management Act 2010 ‘The Flood and Water Management Act aims to implement the findings of the 2007 Pitt Review and co-ordinate control of drainage and flood issues. ‘There are a number of increased responsibiliies within the Act | that affect adoption of Sustainable Drainage Systems (SuDS) features and the role of the EA to expand on the mapping data they provide. The implementation of SuDS features has many beneficial impacts on the treatment of surface water during remediation works. Water Resources Act 1991 Section 24 - The EA is empowered under this Act to maintain and improve the quality of ‘controlled’ waters Section 85 - It is an offence to cause or knowingly permit pollution of controlled waters. ‘Section 88 - Discharge consents are required for discharges to controlled waters Water Framework Directive (2000) ‘The Water Framework Directive (WFD) requires all inland and ‘coastal waters to reach ‘good’ chemical and biological status by 2018. Flood risk management is unlikely to have a significant impact on chemical water quality except where maintenance works disturb sediment (such as de-siting) or where pollutants are mobilised from contaminated land by floodwaters. ‘The main impact of the WFD on flood risk management, both now and in the future, relates to the ecological quality of water bodies. Channel works, such as straightening and deepening, or flood risk management schemes that modify geomorphological Processes can change river morphology. The WFD aims to protect conservation sites identified by the EC Habitats Directive and Birds Directive that have water-related features, by designating them as ‘protected sites’ ‘Standard Life Investments UK Interchange Retail Park, Bedtord Flood Risk and Drainage Assessment 132014-81(0}FRA Page 6 5.2 The East of England Plan (Regional Spatial Strategy for the East of England) Regional The Localism Act 2011 makes provisions for the abolition of regional strategies, however until secondary legislation has been introduced, regional strategies remain part of the development plan. The East of England Plan is therefore stil a material consideration when appraising the appropriateness of the development proposals ** ®) ‘The Plan sets out the long-term spatial planning framework until 2026. The policy within the plan that concerns flood risk management is: “Policy WAT 4: Flood Risk Management Coastal and river flooding is significant in parts of the East of England. The priorities are to defend existing properties from flooding and locate new development where there is litle or no risk of flooding. Local Development Documents should: + Use Strategic Flood Risk Assessments to guide development away from floodplains, other areas at medium or high risk or likely to be at future risk from flooding, and areas where development would increase the risk of flooding elsewhere; Include policies which identity and protect flood plains and land liable to tidal or ‘coastal flooding from development, based on the Environment Agency's flood maps and Strategic Flood Risk Assessments supplemented by historical and modelled flood risk data, Catchment Flood Management Plans and policies in Shoreline Management Plans and Flood Management Strategies, including managed re- alignment’ where appropriate; ‘Only propose departures trom the above principles in exceptional cases where suitable land at lower risk of flooding is not available, the benefits of development outweigh the risks from flooding, and appropriate mitigation measures are incorporated: and ‘+ Require that sustainable drainage systems are incorporated in all appropriate developments. Areas of functional floodplain needed for strategic flood storage in the Thames Estuary should be identified and safeguarded by local authorities." ‘Standard Life Investments UK Page 7 Interchange Retail Park, Bectors Flood Risk and Drainage Assessment 132014-R1(0}FRA 5.3 Local Bedford Development Framework The Site falls within the administrative area of Bedford Borough Council (BBC). The Bedford Development Framework (BDF) is a series of documents - formed of Local Development Documents (LDDs), Development Plan Documents (DPDs), ‘Supplementary Planning Documents (SPDs) and a Proposals Map - setting out the spatial strategy for Bedford to 2021. The policies within these documents will continually replace those of Bedford Borough Local Plan 2002. Policies not yet adopted under BDF will remain active under the Local Plan. The active documents and their policies relevant to flood risk management are outlined in the Table 5.2 below. Table 5.2: Local Policy Context eae Core Strategy and | CP26 - Climate Change and Pollution ural Issues Plan | “The Council will require development to limit any adverse effects on (adopted April | water quality, reduce water consumption and minimise the risk of 2006) "8 flooding.” This SPD gives detailed guidance on the implementation of Policy CP26. | “Minimum Standard: Climate Change ‘+ Use sustainable drainage systems (backed by management and and Pollution SPO ‘maintenance provisions) wherever practical, justilying the use of (adopted Conventional systems if they are not chosen. December 2008) + Avoid use of large areas of impermeable hard-surtacing. | Going Further: * Achieve 100% attenuation of the undeveloped site's surface water run-of.” POLICY NE16 - Flooding "The Borough Council will nt permit development where 1) it would intensity th risk of flooding; or il) it would be at an unacceptable risk from flooding: or il) it would prejudice existing flood defences or interfere with the ability to carryout flood control and maintenance work; or iv) it would adversely affect witife habitat in the floodplain unless, Local Plan the Borough Council, in consultation with the Environment een, ‘Agency and Internal Drainage Board as appropriate, is satisfied policies stil active that the developer wil provide appropriate mitigation, protection as of 2008) "*" ‘and compensatory measures." POLICY U2 - Floodplain “The Borough Council wil not permit development that compromises the capacity ofthe floodplain, balancing ponds, drainage pipes, channels and ‘other flood defences and works to alleviate flooding, or would be at risk of | being flooded, or would unacceptably increase the risk of flooding or | pollution through seepage or run of.” | ‘Standard Lite Investments UK Pages Intorchange Retail Park, Bedtora Flood Risk and Drainage Assessment 132014-81(0)-FRA SOURCES OF INFORMATION 61 6.2 6.3 Environment Agency The EA Flood Zone mapping study for England and Wales is available on their website at: httpy/www.environment-agency.gov.uk/homeandleisuresfioods! The relevant guidance note from the Environment Agency is available online through the following link: http:/www.environment-agency.gov.uk/research/planning/93498.aspx The latest flood zone maps, flood related information (including flood levels) and opinion con the application development area was formally requested from the EA. Their full response to both the flood data request and pre-planning enquiry, including map provided, can be found in Appendix D. Pre-Application Enquiry Response The EA confirmed that the Site falls within Flood Zones 1, 2 and 3 but, as the Site falls within the jurisdiction of the Bedford and River Iver Interal Drainage Board, consultation should be undertaken with the IDB. The response also provides guidance on the use of SuDS features and potential contamination on Site. Flood Zone Map and Flood Data The EA provided Flood Zone maps and flood levels for nodes around Site that further confirmed that the Site lies within Flood Zones 1, 2 and 3a. This indicates the undefended Site is therefore at ‘high’ risk of fluvial flooding. Flood levels in relation to Site are explored in detail in Section 7. Bedford and River Iver Internal Drainage Board In their initial response, the Bedford IDB highlights a recorded instance ot flooding close to the Site associated with Elstow Brook. The IDB also provide flood levels from their Elstow Brook modelling. Due to discrepancies between EA and IDB flood levels, further consultation with the IDB was held. Their full response is contained in Appendix E. Flood levels in relation to Site are explored in detail in Section 7. Relevant Studies Strategic Flood Risk Assessment Title: Bedford Borough Strategic Flood Risk Assessment Level 1, July 2008“ ® ‘The principle aim of the Strategic Flood Risk Assessment (SFRA) is to map all forms of flood risk in order to provide an evidence base to locate new development. It also aims to provide appropriate policies for the management of flood risk and identity the level of detail required for site-specific FRAs. The SFRA contains information and maps detailing flood sources and risks. ‘Standard Life Invesiments UK Page 9 Interchange Retail Park, Bectord Flood Risk and Drainage Assessment 132014-81(0)}FRA The principle source of flood risk in the Bedford Borough is fluvial flooding associated with the River Great Ouse and associated watercourses and ditches maintained by Bedford IDB. Flood maps from the SFRA Level 1 report could not be found; it is ‘assumed that the maps have been superseded by those of the SFRA Level 2 report (see below). Hydraulic modelling is not detailed in the SFRA Level 1 report Significant flood events that have affected the Bedford Borough occurred in 1947, 1987, 1992 and 1998, primarily due to intense rainfall events and fluvial flooding. None of these events affected the Site. Neither the EA, BBC nor IDB have records of historical groundwater flooding incidents in the Borough. However, the IDB have some concerns in the Kempston area, where there have been recent problems of waterlogged gardens. This area is sited on permeable river terrace deposits in the River Great Ouse valley. Title: Bedford Borough Strategic Flood Risk Assessment Level 2, October 2009 *" ' The SFRA (Appendix 10 Flood Risk Detailed Map H) has the Site falling within Flood Zones 2 and 3a. itis not possible to determine the exact extent of each Flood Zone due to the large scale of the map. All relevant SFRA maps are contained in Appendix F. ‘A number of hydraulic modelling studies have been undertaken along stretches of the River Great Ouse and its tributaries. The most recent, and most applicable to Site, is a modelling study undertaken at Elstow Brook by Bedford IDB. This data was not available when the SFRA was written and may instead be used to inform future EA ‘modelling. Recent discussion with the EA confirmed that this has in fact been the case (see Section 7.2). Preliminary Flood Risk Assessment Title: Upper River Great Ouse Tri Lead Local Flood Authority Preliminary Flood Risk ‘Assessment for Bedford Borough Council, Central Bedfordshire Council and Milton Keynes Council, June 2011"? A Preliminary Flood Risk Assessment (PFRA) is the first part of the planning cycle for flood risk management as set out in the Flood Risk Regulations (2009), which implement the requirements of the European (EU) Floods Directive (2007). The EU Floods Directive aims to provide a consistent approach to managing flooding across Europe. Bedford Group of Internal Drainage Boards prepared a joint PFRA on behalf of BBC, Central Bedfordshire Council and Milton Keynes Council. The PFRA is aimed at providing a high level overview of flood risk from local flood sources (surface water, groundwater, ordinary watercourses and ditches, and canals) to identity areas of significant risk as Indicative Flood Risk Areas across England where 30,000 people or ‘more are at risk from flooding. Accordingly, there are no Indicative Flood Risk Areas within Bedford Borough. ‘The PFRA does however acknowledge the “high” risk of flooding across BBC. No past flood events are considered to have had “significant harmful consequences” though evidence suggests that flooding is exacerbated in areas adjacent to a Main River, as ‘Standard Lite Investments UK Page 10 Interchange Retall Park, Bectord Flood Risk and Drainage Assessment 132014-81(0)-FRA elevated water levels in the Main River also elevate levels in the adjoining systems which can't discharge. Relevant maps from the PFRA are contained in Appendix G. Catchment Flood Management Plan Title: Great Ouse Catchment Flood Management Plan, January 201 1%) Catchment Flood Management Plans (CFMP) give an overview of the flood risk from inland sources across each river catchment and recommend ways of managing those risks now and over the next 50-100 years. The EA is responsible for producing CFMPs. Within the CFMP the Site falls within Sub-area 24 ‘St. Neots/Little Paxton, Bedford/Kempston and Leighton Buzzard’. The policy applicable to this sub-area is Policy 5 ‘Areas of moderate to high flood risk where we can generally take further action to reduce flood risk’. “This policy will tend to be applied to those areas where the case for further action to reduce flood risk is most compelling, for example where there are ‘many people at high risk, or where changes in the environment have already increased risk. Taking further action to reduce risk will require additional appraisal to assess whether there are socially and environmentally sustainable, technically viable and economically justified options.” ‘Currently, 4,903 properties in Bedford/Kempston are at risk from the 1 in 100 year river flood event. This is predicted to rise to 6,417 by 2110. “In this densely populated urban sub-area the existing flood risk is too high. We need to investigate options to reduce the probability of river flooding. In particular we should consider storing water on the flood Plains upstream of communities at risk. Organisations must also work together to ‘manage the risk off surface water flooding in St Neots and Bedtord/Kempston. We should also consider taking action to manage the consequences of flooding by adapting urban environments to make them more resilient to flooding. For example, as commercial sites are redeveloped, the location and lay-out of buildings could be designed to help reduce flood risk.” Surface Water Management Plan Bedford Borough Surface Water Management Plan (SWMP) is currently in writing. The Bedford Borough SWMP will seek to mitigate surface water flooding by promoting the implementation of SuDS. This approach should also be used for site-specific drainage strategies and catchment wide drainage strategies “*"""), Flood Risk Management Strategy Bedford Borough Council are currently collaborating with the EA, Bedford Group of Internal Drainage Boards and Anglian Water to develop the Local Flood Risk Management Strategy. This strategy will set out a long-term plan to manage flood risk (involving flooding from surface water, ordinary watercourses and groundwater) across the Bedford Borough. The strategy document is due to be developed by Summer 2013. ‘Standard Lie Investments UK Page 11 Interchange Retail Park, Bedtord Flood Risk and Drainage Assessment 132014-A1(0}FRA Title: Bedford Borough and Central Bedfordshire Northern Area Detailed Water Cycle ‘Study, April 2012 °° 14) Other Studies In terms of flood risk management, one of the original objectives of this detailed water cycle study (WSC) was to develop site-specific policies for sites allocated in both authorities site allocations DPDs. This required a detailed understanding of surface water flood risk assessment. The EA, in their consultation response to the scope of this, WCS, identified that it was not appropriate for the WSC to undertake this assessment. It is presumed that this assessment will form part of the scope of the SWMP. 6.4 Drainage Public Sewers ‘Sewer details have been referenced from the sewer record plan obtained from Anglian Water, presented in Appendix H. The pian indicates that a network of public surface and foul water sewers serve Interchange Retail Park. In close proximity to the Site are surface water sewers. A surface water sewer runs from the retail units to the northwest of Site, below the area of Site and discharges into Interchange Retail Park balancing park. A surface water sewer from the south of Site also joins manhole 9650 before discharging into the balancing pond. Foul water sewers 150mm in diameter connect at manhole 9801 to the northwest of Site. There is also a 225mm diameter foul sewer serving the retail units to the north of Polo Field Way. Private Drainage No private drainage details were available. Standard Life Investments UK Pago 12 Interchange Retail Park, Bedtord Flood Risk and Drainage Assessment 132014-A1(0)-FRA SOURCES OF FLOOD RISK et 7.2 724 Criteria In accordance with NPPF *'") and advice from the EA, a prediction of the flood sources and levels is required along with the effects of climate change from the present to the design life of the development (in this case assumed to be 60 years). To consider the effects of climate change, Table 5 of NPPF Technical Guidance "*'*! recommends consideration of a 20% increase in rainfall intensity and 20% increase in peak river flows over the developments design life. ‘The flood risk elements that need to be considered for any site are defined in BS 8533- 2011 "*"* as the "Forms of Flooding” and are listed as: ‘+ Flooding from Rivers (fluvial flood risk); ‘+ Flooding from the Sea (tidal flood risk); + Flooding from the Land (surface water flood risk); + Flooding from Groundwater; + Flooding from Sewers (sewer and drain exceedance, pumping station failure etc); + Flooding from Reservoirs, Canals and other Artificial Structures. This section reviews each of these with respect to the Site. Fluvial Flood Risk Environment Agency The Flood Map (Figure 4) and Undetended Flood Outlines Map (Appendix D) provided by the EA indicate that the northern part of Site lies within Flood Zone 1 (defined as having less than a 1 in 1000 year annual probability (<0.1%) of fluvial flooding from Elstow Brook). The western and southern parts of Site lie within Flood Zone 2 (defined as having a 1 in 1000 year annual probability (0.1%) of fluvial flooding from Elstow Brook. The western and southern corners of Site fall within Flood Zone 3a (defined as having a 1 in 100 year annual probability (1%) of fluvial flooding from Elstow Brook). River levels obtained from the EA's Mid Great Ouse-Elstow Brook Model (May 2012) have been supplied by the EA for a number of nodes within the vicinity of the site (Appendix D). The closest node to Site is node EA0522993336 to the northeast (603990, 246795). The river level for the 1 in 100 year (1%) plus climate change annual probability flood event is 29.01m AOD. This data highlights that the Site will not be impacted by floodwaters during this event. The river level for the less than 1 in 1000 year (<0.19%) annual probability flood event is. 29.31m AOD. This data indicates that the western and southem corners of Site will be flooded to a maximum depth of 0.25m AOD. ‘Standard Life Investments UK Page 13, Interchange Retail Park, Bedtord Flood Fisk and Drainage Assessment 132014-81(0}FRA 7.2.2 723 724 725 Bedford Internal Drainage Board Bedford IDB's consultant is currently modeling flood levels associated with Elstow Brook. It is understood that the study is not yet complete, however, Bedford IDB provided a flood level of 29.63m AOD for the 1 in 100 year plus climate change annual probability flood event at the Site. This data suggests that the majority of the Site (apart from the northern part) would flood during such a flood event. Bedford IDB highlighted a recorded instance of flooding at Elstow Brook approximately 100m to the northwest of Site. No further data is available. Following this initial consultation, the discrepancy between the EA climate change flood level of 29.01m AOD (see Section 7.2.1) and the IDB flood level of 29.63m AOD was discussed further with the IDB, The IDB's second response states: “Having discussed this with our consultant the level of 29.63 relates to a 26 hour event which may not be considered suitable as short durations generally give the worst case scenario for this location. As such the shorter durations indicate a level (in the adjacent lagoon) of around 29.33 which is about top of bank. This flood level includes climate change and is suggested as the appropriate level for the FRA. You should also give consideration to the finished floor levels of the existing adjacent retail development of this site.” Overview of flood levels ‘As a result of conflicting flood levels, it is considered that there is some uncertainty regarding the exact predicted flood level on Site. The latest IDB response indicates that 29.33m AOD is an appropriate level for assessment within the FRA. Therefore, this level has been used to assess the site, Relevant Studies The SFRA and PFRA state that fluvial flooding is the main flood risk in the Borough. There are historic instances of fluvial flooding, though none appear to have impacted Site and none were deemed to have had “significant harmful consequences". Modelling studies referred to within the SFRA have since been superseded by modelling undertaken by the EA and IBD. Defences ‘The SFRA provides details of flood defences in the Bedford Borough. Bedford IDB own flood defences associated with their watercourses, as shown in Appendix 11 Asset and Structures Detailed Map H of the SFRA (Appendix F). The IDB, amongst others, maintain Interchange Flood Relief Channel to the northeast of Site and Woburn Road (earth) Embankment to the southwest of Site. Interchange Flood Relief Channel comprises weirs and a concrete spillway that provides flood storage and flood flow. These defences are considered "the most note worthy structures maintained by the IDB, i.e. the structures which should they fail result in the greatest consequences’. ‘These structures have a residual life of at least 30 years and there is no urgency for repair work (according to information provided by the IDB, contained within the SFRA). Standard Life Investments UK Page 14 Interchange Retail Park, Bedtord Flood Fisk and Drainage Assessment 132014-81(0)-FRA @eexeeoevneeveeeeeoeeeeoeeaeveeeeeeeeeeeee 8 7.3 74 75 ‘The EA's Defended Flood Outlines Map indicates that the Site is defended up to a 1.33% annual event probability (Appendix D), Fluvial flooding is likely to increase as a result of climate change. A greater intensity and frequency of precipitation is likely to raise river levels and increase the likelihood of a river overtopping its banks. Overall, the fluvial flood risk is considered to be moderate. Tidal Flood Risk The Site is not considered to be at risk from tidal flooding due to its inland location. Surface Water Flood Risk ‘The Site and wider retail park is relatively flat and largely impermeable. The topographic survey (see Section 3.2) does however indicate drains (exact type unknown) adjacent to Site, which could reduce the risk of surface water flooding impacting the Site. Within the SFRA, details of Anglian Water's DGS register (as of 2009) reveal only two recorded instances of surface water flooding in the MK42 7 postcode area. ‘The SFRA (Appendix 13 Surface water susceptibility) has the Site in an area susceptible to surface water flooding. It is not possible to determine the exact susceptibility classification to Site due to the large scale of the map (Appendix F). Similarly, the PFRA designates the Site area as at risk from surface water flooding to a depth of 0.3 m during a 1 in 200 year flood event (Appendix G), ‘The EA identified that it was not appropriate for the detailed WSC (as of 2012) to undertake a surface water assessment. Bedford Borough SWMP is currently in writing, Surface water flooding is likely to increase as a result of climate change in a similar ratio to fluvial flooding. Increased intensity and frequency of precipitation is likely to lead to reduced infiltration and increased overland flow. Overall, the surface water flood risk is considered to be low. Flooding from Groundwater ‘The Site is underlain by superficial geology of Head Clay, Silt, Sand and Gravel. This indicates a degree of permeability that could encourage groundwater to rise to the surface. However, there is no record of groundwater being encountered during BGS borehole activities. The EA, BBC and Bedford IDB have no records of historical ‘groundwater flooding. As stated in the SFRA, the Bedford Borough is given the lowest indicative groundwater flood risk category mapped (BFIHOST <0.7) though the SFRA acknowledges that pockets of higher risk areas are present throughout the Borough. Groundwater flooding is hard to predict and as such was not strategically mapped as part of the SFRA process. Standard Lite Investments UK Page 15, Interchange Retail Park, Boctora Flood Fisk and Drainage Assessment 132014-81(0}FRA

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