Flood Risks

Planning Policy Statement 25 (PPS25) is intended to govern and control development plans nationally. PPS 25 states “The aims of planning policy on development and flood risk are to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk.”

The developers commissioned a flood risk assessment in which the site has been clearly identified as being located in a high risk flood zone (Zone 3). The hotel/apartment usage is classified as being in the category of “More Vulnerable” in flood risk terms. As such, PPS 25 Table D.2 clearly states that these “More Vulnerable” land uses should not be permitted in this flood zone.

PPS 25 advocates an approach in which more vulnerable land uses are directed to developable areas which have a low probability of flooding. It states “The risk-based Sequential Test should be applied at all stages of planning. Its aim is to steer new development to areas at the lowest probability of flooding (Zone 1).”

The Local Planning Authority (LPA) are responsible for applying the Sequential Test.

This proposed development does not appear to pass the Sequential Test, and should thus not be permitted to bypass the government-set policy on development within a flood zone.

PPS25 specifically requires developers to “demonstrate that it is consistent with the policies in this PP” and “identify opportunities to reduce flood risk, enhance biodiversity and amenity, protect the historic environment .... etc”. The proposal creates flood risk where there is none at present, replaces a green bank and natural foreshore with an out of character structure and actively and seriously damages a historic environment.

Previous similar planning applications in the area:-

A proposal for a development of very similar nature and scale, on the same site at the Greenbank Hotel foreshore, was denied permission in 1988/89. It went to appeal, and the Planning Inspectorate refused the development on 25th April 1989. The appeal documents are not available online, but the grounds of the ruling by the Planning Inspectorate were that "...unacceptable harm would be done to the character and appearance of the area". The Falmouth residents Association and The Foreshores Group have copies of the documents.

A proposal for 14 apartments to the north of the proposed site, on existing land, was refused by the Planning Inspectorate on appeal in October 2007 on grounds of flood risk - see appeal decision document

A proposal for development of mixed-use hotel/residential/commercial development on an existing non-listed quay further upriver, at Falmouth Wharves, was turned down on appeal in August 2008 on various grounds, but particularly including flood risk - see appeal decision document