Is Another Wirral Flood Plain a Suitable Site for Building Development?
Our friends at the Stop Hoylake Golf Resort Action Group (SHGRAG) share our concerns about not only losing a huge swathe of green belt to an unwanted development, but also the viability of building (yet again) on another of Wirral’s flood plains. They have forwarded the following article to us and have given us permission to publish it on this website.
The Hoylake Flood Plain – an Ideal Place for a Wetland Resort or a Golf Resort and Housing Estate?
The director of the Nicklaus Joint Venture Group (NJVG) says, “We will conduct a thorough flood study plan as part of our Environmental Impact Assessment, which will not only protect the site from potential flooding but also help improve local water storage capability and flood water protection”
The Hoylake golf resort site is very low lying and has a very high ground water table and is waterlogged through large parts of the year. In addition, much of the site lies in Flood Zone 3, including the area where they propose to build the housing estate.
Flood Zone 3 means the site is likely to flood at a 1 in 100-year storm event. A ‘1 in 100 year event’ does not indicate that such an event will only happen once in a century but that, every year, there is a 1 in 100 (or 1%) chance of experiencing floods at this level.
But these flood events and levels are based on historic data – and with climate change, we are experiencing these extreme events more and more frequently.
New Developments Should Have a Low Flood Risk
Planning Policy Statement 25 (PPS25) ( Section 126.96.36.199 ) on development and flood risk aims 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. 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.”
When allocating land for development the Council should apply what is called ‘the Sequential Test’ to “steer development towards areas of low flood risk and to demonstrate that there are no reasonably available sites in areas with a lower probability of flooding”.
Arguably, the golf resort is not a necessary development and there are other sites in the Borough where you could build hotels and houses which are not in a flood risk zone. The Secretary of State or a judicial review will consider this argument should the project progress through the Planning stage.
The Developers will be required to produce a Flood Risk Assessment showing that the flood risk from the Golf Resort will not be made worse – but only up to the 1 in 100-year level (plus, a percentage for climate change).
The developers Flood Risk Assessment will be reviewed by the Environment Agency. However, if the flood risk assessment shows that flooding is not made worse up to the 1 in 100-year level then the EA are powerless to object. Furthermore, the Environment Agency have over stretched resources which potentially may mean that the Flood Risk Assessment may not be subject to thorough and proper scrutiny.
Above, are photos of the golf resort site, right where the housing estate is planned, and you can see that it is doing what a flood plain is supposed to do…it’s flooding! The site acts like a sponge. It stores water in times of heavy rain, holding back the flood water so that the flood flows or ‘run-off’ is held back – so it reduces the peak flood flows in the Birkett. And so, it reduces the Flood risk to Meols and Moreton.
It is absolutely clear that urbanisation increases the flood risk. It alters the natural flood processes and increases flood risk to properties further downstream. When you build on a flood plain you reduce its capacity to store the water. You also increase the speed of the ‘run-off’ of the water – because natural areas which soak up water are being concreted over
Large areas of the resort are going to be concreted over – large hotel, car parks, club houses, maintenance buildings, 40 apartments and 160 houses, driveways and patios and a new by-pass road (Wirral Council just love a good by-pass road! – Webmaster).
How Could the Developer Satisfy Planning Requirements for Flood Risk?
They will construct ‘Sustainable Urban drainage Systems’ to store water and these will be incorporated into the lakes that they will create for the golf resort. Planning policy will only require them to store the water of a 1 in 100-year storm.
They will build the floor levels of the hotel and houses and the road above the 1 in 100-year level plus a contingency for climate change. Although the existing land can be re-profiled for the golf course, it is unsuitable for building on so it is likely that 1000s of tonnes of fill will have to be imported.
The housing estate alone will cover 28 acres (or 113,000 m2). The houses will have to be built at least 600mm above the flood level and the ground will have to be excavated for foundations, so assuming a (conservative) 1m depth of imported fill that is 113,000 m3 of fill or over 200,000 tonnes. That is at least 4500 truck loads (HGV carrying the max 44 tonnes). There will be potentially 1000s more truck loads of fill required for the road and the hotel. But, if the developer proposes these sort of measure they can be deemed as satisfying planning requirements for flood risk – Remember they only have to design flood defences up to that 1 in 100-year level plus a contingency!
Recent Flooding Blamed on ‘Extreme’ Events
Residents bought their homes at the 2009-built Glasdir Estate in Ruthin, North Wales, assumingly safe in the knowledge that their flood levels were actually at the 1 in 1000-year level, plus an extra 200mm. In 2012, 122 houses suffered internal flooding.
In 2015 Carlisle’s £38million flood defences were breached, despite being built at a 1 in 200-year level, plus half a metre to allow for climate change – Storm Desmond was a 1 in 1300-year storm!
During the very recent heavy rain fall in June 2019, the Birket and the Arrowe Brook came perilously close to over-topping their banks and flooding neighbouring houses. Although the rain was heavy this month, it was not particularly intense or extreme when compared to rainfall previously experienced and will likely continue to be experienced, as climate change continues.
Section 4.2.8 of Wirral’s Preliminary Flood Risk Assessment report states:
“A major factor influencing the flooding that has occurred is the flood defences on the main river network, in particularly the Birket and Fender, which in places have been constructed higher than the surrounding area. Although, this allows the Main Rivers to carry and store additional flows it prevents many of the directly piped outfalls and critical and ordinary watercourses from discharging into them. This inevitably leads to flows backing up and subsequent flooding, which due to the low-lying nature of the area, can stretch well into the upstream catchments.” (Moreton, Meols & Hoylake)
If (when) the Wirral is hit with further storms in excess of a 1 in 100-year storm, will the golf resort flood storage areas be able to cope with such high volumes of water? The water quickly running off the concrete areas will add to the flood flows in the already full to capacity river Birket and increase the problems of drainage systems being unable to discharge into the river.
If you have one event followed by another, followed by another, (which we are seeing more and more often) the ground is already soaked, the rivers are already full and it is likely that the golf resort storage lakes will already be full – so where does the water running off those large concrete areas go?
Machynys Flooding Issues
Carmarthenshire Council initially gave The NJVG’s previous golf ‘resort’ project full planning permission for a Hilton Hotel, but the hotel was never built because of flooding concerns. Jim Anderson states “because of external technical difficulties the council had with the local main sewerage system, the hotel development could not progress at that time.”
The Golf Course opened in 2005 yet just 3 years later, there was a requirement for a new £500,000 flood defence scheme. The Wales Online website reported, “During times of peak flow the Afan Dafen river that runs through the course has often failed to hold its water volume.”
And again, in 2018, the Welsh Government had to provide funds to Carmarthenshire County Council for a £2million flood defence scheme to protect the 175 houses in the Nicklaus Joint Venture Groups Nicklaus Pentre Village from tidal flooding.
Residents raised their concerns and asked why the development of new homes went through before flood defences had been finalised. The AM for Llanelli said “given the risk of flooding it is absurd that hundreds of houses have been built before these defences were in place.”
Given the flooding issues at Machynys, for years after the completion of the golf course and the housing estate, can the NJVG’s Flood Risk Assessment for Hoylake be relied on to ensure that flood risk will be properly mitigated? Or will Hoylake (and the Birket’s) complex hydrology mean that further significant public investment will be required to alleviate flood risk in the years after the golf resort is completed, particularly as the effects of climate change take effect?
We are only just beginning to see the effects of climate change and we simply don’t yet know what the effects will be over the coming decades. When you meddle with a flood plains ability to cope with flood water you are potentially storing up massive problems for the future generations who live in the flood zones – problems which will come back and bite us in 10, 20 or 50 years’ time. Houses in flood zones often struggle to get insurance, having major impacts on the health and well-being of the most vulnerable in our society. It’s a highly risky, and some would say reckless, strategy to build on a flood plain.
The Hoylake site would be far more suited to an ECO / Wetlands resort working in partnership with, and securing funding from, credible partners such as the Environment Agency, Wildfowl and Wetlands Trust, RSPB etc. It would be a much more acceptable scheme for the local community and would still bring jobs, tourism and financial benefits to local businesses and the Council as well as providing flood risk benefits and massive environmental gains. The Government has declared a Climate Change Emergency and Wirral Council is proposing to do the same. Impending climate change requires Civic Leaders to urgently make the right decisions. 2019 is the Liverpool City Region Year of the Environment. The most positive impact that the Council can make to help the Environment in 2019 is to abandon the plans for the Hoylake Golf Resort.
Stop Hoylake Golf Resort Action Group – June 2019
Our thanks to the members of the SHGRAG for their time in preparing and submitting this article.