14th June 2026
Objection to Planning Application DC/097786 (Outline Planning Permission)
I wish to object to the above outline planning application on the grounds that it does not demonstrate that the proposed development can be safely, sustainably, or realistically delivered, particularly in relation to flood risk, ground stability, contamination, and necessary infrastructure works associated with Padden Brook.
1. Flood Risk and Padden Brook
The site’s proximity to Padden Brook raises significant concerns regarding flood risk, surface water management, and potential impacts both upstream and downstream.
At present, it is not clear that the Flood Risk Assessment adequately demonstrates:
- That the development will not increase flood risk elsewhere;
- That climate change allowances have been properly incorporated;
- That safe access and egress can be maintained during flood events;
- That any culverting or watercourse constraints have been properly assessed.
Given the sensitivity of development near a watercourse, I do not consider that the application currently provides sufficient evidence that flood risk can be safely managed.
2. Drainage and Surface Water Management
There is insufficient clarity on how surface water will be managed, particularly during periods of heavy rainfall. Concerns include:
- Potential exceedance of drainage capacity;
- Reliance on systems that may be difficult to maintain long-term;
- Lack of clarity on exceedance routing and overland flow paths.
Without robust and independently verified drainage solutions, the proposal risks increasing flood vulnerability in the surrounding area.
3. Ground Stability and Retaining Structures
It is understood that significant engineering works, potentially including retaining structures, may be required due to site levels and proximity to Padden Brook.
However, at outline stage:
- There is insufficient geotechnical evidence to confirm long-term slope stability;
- The design, ownership, and maintenance responsibilities for any retaining structures are unclear;
- The consequences of structural failure have not been adequately addressed.
These matters are fundamental to whether the development is actually deliverable.
4. Contamination Risk
Given the site’s history and proximity to watercourses, there is a reasonable concern that contamination may be present or could be mobilised during construction.
At present:
- There is no clear evidence that a full Phase 2 intrusive investigation has been completed or adequately assessed;
- The extent and cost of any remediation works are unknown;
- There is no certainty that contamination can be safely mitigated without risk to groundwater or Padden Brook.
5. Deliverability and Infrastructure Dependencies
A significant concern is that the application appears to rely on substantial future mitigation measures, including drainage works, retaining structures, and potential contamination remediation.
At outline stage, these are not yet fully defined in a way that provides certainty that the development can be delivered safely or completed in full.
While the financial position of the applicant is not, in itself, a determining planning factor, it is relevant insofar as the proposal depends on major and potentially costly engineering works. There is currently no robust mechanism demonstrated within the application to ensure that these works will be completed and maintained for the lifetime of the development, particularly in the event of financial failure of the developer.
6. Conclusion
In summary, I consider that the application has not demonstrated that the development can be safely or satisfactorily accommodated on this site.
Key matters relating to flood risk, drainage, ground stability, contamination, and infrastructure delivery remain insufficiently resolved at outline stage.
For these reasons, I respectfully request that the application is refused, or alternatively deferred, until comprehensive technical evidence is provided demonstrating that all identified risks can be appropriately mitigated and that the development is genuinely deliverable and safe.
