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What Thanet District Councillors have to say about the Pleasurama development in Ramsgate.

I am writing to you because I still have considerable concerns about the Pleasurama development in Ramsgate.
My main concern relates to the letter from the specialist environment agency officer strongly recommending a flood risk assessment and emergency escapes to the cliff top it is published at this web address I will also put the text of it at the bottom of this email.

The problem for me is that no one involved, developer, contractor or council, has any experience of building between the foreshore and a cliff face apart from the EAs technical expert.

She recommended various basic safety measures that the new plans are not compliant with, it is my belief that councillors should reject continuing with this project when they have the opportunity to ensure that Ramsgate gets a safe development appropriate for the site.
The reason that the development is coming before council is that the developer is unable to find an insurance company to issue a performance bond, normally a developer would get one of these for a fraction of its value rather in the same way that you or I would get car insurance for a fraction of the potential claim.

I donít know why SFP canít get a performance bond, the normal developers that I know are not experiencing any difficulties getting them.
It may because they havenít got any track record as they donít appear to have ever built anything, it may be that they canít produce a certificate of authenticity for money laundering purposes required under the new legislation.
However I think it most likely that it is because of the environment agency officers letter which means that the development if built will be blighted to a lesser or greater extent.

The council have already spent the best part of a million pounds on the repairs to the cliff face and as the new access road was laid without a flood risk assessment where wave overtopping occurs most winters and consists of lose slabs laid on sand on top of the sea defences I foresee further expense is likely.

KCC highways are aware of the problem but say they donít have any money to put it right.

I have also raised concerns about the condition of the arches that support the public transport access road and havenít been able get assurances that it will last for the expected life of the building, so this could mean further and considerable expense.

The developer has made changes to the plans on several occasions but I donít believe it would be possible for him to get the building safely above serious flood risk without making significant changes that would invalidate the planning permission.
It is ironic that although he would be allowed to build a potentially dangerous building if he came forward with plans for a safe building it would have to go through all the stages of planning again.

I should also point out that this is not some vague possible danger that may happen due to global warming, we have had serious incidents in this part of Ramsgate in past storms.

In the 1953 storm a 12 ton crane that had been working on the beach was thrown over the sea defence by the force of the waves onto the site where the building will be. In the 1897 storm pretty much everything down there apart from the shell of the railway station was demolished by the sea.
Please appreciate that I am not against developing this site, far from it, I have a business in the area and would and would like to see a thriving development there.

The ongoing saga of plans that wouldnít work safely in practice and therefore donít get built is damaging for Ramsgate, we are now on the third contractor and the sixth set of plans.

Please send me any views that you have about this, unless you mark them as otherwise I will assume they are fro publication.
Anyway read the EA letter and see what you think:
Creating a better place
Environment Agency
Our ref: KT/2007/104024/0101
Thanet District Council Your ref: TH/03/1200
P0 Box 9 Date: 08 February 2008

Thank you for forwarding plans for the proposed development at the former Pleasurama site in Ramsgate. I am sorry you have had to wait so long for a response but as we discussed in our recent meeting, I was under the impression that there were further amended plans to follow.
According to our records the Environment Agency was initially consulted on this application in October 2003. At that time our indicative flood risk maps did not identify the area to be at risk from tidal flooding.
The maps were based on a predicted 1 in 200Year (tide and ground levels along this part of the coast were shown to be above the ďat risk~ level. Therefore no specific flood risk comments were included in our response.

In hindsight this is regrettable as the proximity of the site to the frontage does mean that the area is likely to be susceptible to wave overtopping and could be subject to flooding in extreme storm conditions.

Since 2003 we have had both a policy change with the publication of Planning Policy Statement 25: Development and Flood Risk (PPS25) and, publication of our updated flood maps which now show part of the site to lie in Flood Zone 3a (High Probability). Although we might not object in principle to some form of development here, if we were to receive a similar application under the current guidelines, we would require a Flood Risk Assessment (FRA) to identify the risk, look at flood resilient construction and address the issue of safe, dry access. Without this information it is difficult to determine whether the development can be considered ďsafeĒ (PPS25 09 The Exception Test).

We are aware that there have been amendments to the original application but believe the Agency was not asked to comment following the initial consultation in 2003. It is difficult to say whether our response would have changed at the times of these amendments. We are certainly disappointed that access from the development to the top of the cliff, which we believe to have been in the original layout, has since been removed. In the event of the esplanade being impassable, access from the cliff-top would ensure a safe dry route to and from the residential units.

As the proposal stands, a serious flood could potentially leave residents stranded in their homes without a safe means of escape, for the duration of the event.

As a guide, we would currently recommend all residential accommodation in the Ramsgate area to be set at a minimum of 5.6m above Ordnance Datum Newlyn (ODN). This is following the predicted sea level rise allowances in PPS25 until the year 2110.

Unfortunately the plans do not show floor levels relative to ODN. however the site survey (Drawing No. PL 10-101) indicate average ground levels to be approximately 5,8m (although not shown I am assuming these levels to be ODN).

With the ground floor proposal for commercial use only, it can be concluded that the residential accommodation, all on the first floor and above, will be set well above the recommended 5.6m ODN. It should however be made clear that this is a static tide level which makes no allowances for wave action, This static level would be deemed safe some distance from the frontage where wave heights would be expected to dissipate. Areas immediately behind defences lie in the High Risk Rapid Inundation RIZ) and are particularly vulnerable due to the risk of the defences being overtopped or breached, resulting in fast-flowing and potentially deep water with little or no warning. Again, if this were a new application we would expect an FRA to identify the RIZ and predict potential wave heights.

For example the FRA undertaken by HR Wallingford for The Turner Centre application identified wave heights to be significantly different from the predicted ď200yearĒstatic tide level for Margate.

Whether this development is sufficiently set back to be outside the RIZ is difficult to say without further investigation in the form of a detailed FRA. Although the residential accommodation may well be set high enough above the static extreme tide level, we don't have sufficient information to confirm whether or not the site is vulnerable to waves of a much greater height and if so, if this could undermine the structural integrity of the proposed buildings. A site specific FRA would assess the potential for wave damage and recommend suitable mitigation measures.

It is appreciated that this proposal was submitted over 4 years ago, prior to the publication PPS2S and before our maps highlighted the area to be at risk, Certainly in terms of flood risk policy, things have some-what moved on. In light of those changes and without further information I regret it is impossible for the Agency to confirm whether or not the proposal as it stands is wholly consistent with current policy. And whilst we accept that this development already has planning permission, we would highly recommend that a full FRA is undertaken which could inform appropriate resilience and resistance measures. The assessment could also inform the production of a suitable flood warning and evacuation plan, for both the residential and commercial parts of the development. We would obviously recommend that all future residents and commercial units are registered with our free Flood Warning Service, I hope this letter has been able to clarify the Agency's position however should you wish to discuss the matter further please don't hesitate to contact me again.

Yours sincerely Meriel Mortimer

Development control technical specialist.
Environment Agency Orchard House, Endeavour Park, London Road, Addington, West Mailing, Ken, MEI9 5SH.

Best regards Michael