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         creating a better place
                                          Our ref:  KT/2007/104024/0101
         Thanet District Council          Your ref: TH/03/1200
         P0 Box 9                         Date:     08 February 2008
         Margate                                    PLANNING DEPARTMENT

         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 in200Yea( tide and ground levels along this part of the coast were
         shown to be above the “at 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
         “safe” (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 resident'
         stranded in their homes without a safe means of escape, for the duration of the
         As a guide, we would currently recommend all residential accommodation ~n 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
         Zone (RIZ) and are particularly vulnerable due to the risk of the defences being over-
         topped 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 “200year”static 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.
         Environment Agency
         Orchard House, Endeavour Park, London Road, Addington, West Mailing, Ken, MEI9 5SH.