MsnJessica Duffield
Barnsley Metropolitan Borough Council
Development Control
PO Box 604
Barnsley
South Yorkshire
S70 9FE

Our ref:	RA/2024/147502/03-L01
Your ref:	2024/0580

Date:		21 July 2025

Dear  Ms Duffield

(AMENDED PLANS SUBMITTED) HYBRID PLANNING APPLICATION COMPRISING A) FULL PLANNING APPLICATION FOR 256NO DWELLINGS INCLUDING 2, 2.5, AND 3 STOREY HOUSES TOGETHER WITH ATTENUATION BASIN AND TEMPORARY ACCESS ROUTE, LANDSCAPING AND ASSOCIATED WORKS AT AREA 1 AND B) OUTLINE PLANNING APPLICATION WITH ALL MATTERS RESERVED FOR UP TO 200NO. DWELLINGS ON AREA 2 (AMENDED DESCRIPTION AND PLANS).   
LAND SOUTH OF DONCASTER ROAD AND ADJACENT TO STRAWBRIDGES GARDEN CENTRE, DARFIELD, BARNSLEY, S72 5EZ      

Thank you for consulting the Environment Agency regarding the above mentioned proposed development received on the 4 July 2025. 

Environment Agency Position
We previously had no objections to the proposed development as the development was located in Flood Zone 1. Since our previous response to this planning consultation, our understanding of flood risk in this area has changed, and the flood map for planning has been updated. Based on best available data at this time, the development is now shown to be within Flood Zone 3. As such, the Flood Risk Assessment (FRA) should be updated to reflect this change. Further details of our objection and the information required to overcome it, is detailed further below.In the absence of an acceptable Flood Risk Assessment (FRA) we object to this application and recommend that planning permission is refused.
 
Reasons
The submitted FRA by Haigh Huddleston & Associates dated June 2024 with ref E20/7309/DRA01 does not comply with the requirements for site-specific flood risk assessments, as set out in paragraphs 20 to 21 of the Flood Risk and Coastal Change planning practice guidance and its site-specific flood risk assessment checklist. The FRA does not therefore adequately assess the flood risks posed by the development. In particular, the FRA fails to:

•	consider how a range of flooding events (including extreme events) will affect people and property.

•	assess the impact on off-site flood risk and detail necessary mitigation.

•	consider the requirement for flood emergency planning including flood warning and evacuation of people for a range of flooding events up to and including the extreme event.

•	take the impacts of climate change into account: 
o	There is no assessment of the impact of climate change using appropriate climate change allowances: 'Flood risk assessments: climate change allowances']

o	Flood risk mitigation measures to address flood risk for the lifetime of the development included in the design are inadequate because they will not make the development resilient to the flood levels for the 1% AEP plus climate change event. Consequently, the development may propose inadequate: 
•	Flood storage compensation
•	Raised finished floor levels
•	Resistance and resilience measures
•	Safe access and egress routes 

Overcoming our objection
To overcome our objection, the applicant should submit a revised FRA which addresses the points highlighted above.

If this cannot be achieved, we are likely to maintain our objection. Please consult us on any revised FRA submitted and we will respond within 21 days of receiving it.
 
Please see the following advise for the LPA/Applicant

Flood Zone Classification Outdated 
The FRA is based upon old Flood Map for Planning data. The new Flood Map for Planning indicates the site is within flood zone 3. Please update the FRA and reassess fluvial flood risk considering climate change.

Flood Risk & Climate Change Data 
Where flood risk data including climate change does not exist, it is the responsibility of developers to undertake this assessment using guidance in 'Flood risk assessments: climate change allowances'. Assessment of future flood risk can be undertaken using:

•	Freeboard allowances
•	Interpolation based on current flood risk models
•	New detailed modelling

Deciding which approach applies depends on the size, vulnerability and location of the development. It is envisaged that large scale developments (e.g. sustainable urban extensions, retail parks, large commercial developments) will need to adopt the detailed approach. Contact us to discuss this on a case-by-case basis. Please note we may charge for this advice.

Flood Resistance and Resilience 
Finished floor levels for more vulnerable development types should be 600 mm above the 1% AEP plus climate change level. Finished floor levels for less vulnerable development types should be 300 mm above the 1% AEP plus climate change level.
We strongly recommend the use of flood resistance and resilience measures. Physical barriers, raised electrical fittings and special construction materials are just some of the ways you can help reduce flood damage.

To find out which measures will be effective for this development, please contact your building control department. If you’d like to find out more about reducing flood damage, visit the Flood Risk and Coastal Change pages of the planning practice guidance. Further guidance on flood resistance and resilience measures can also be found in:
Government guidance on flood resilient construction https://www.gov.uk/government/publications/flood-resilient-construction-of-new-buildings

CIRIA Code of Practice for property flood resilience
https://www.ciria.org/CIRIA/Resources/Free_publications/CoP_for_PFR_resource.aspx
British Standard 85500 – Flood resistant and resilient construction
https://shop.bsigroup.com/ProductDetail/?pid=000000000030299686

Contaminated Land 
This development site appears to have been the subject of past industrial activity, mainly use as a historic landfill, which may pose an uncertain risk of pollution to the environment and controlled waters.
 
However, we are unable to provide site-specific advice relating to land contamination as we have recently revised our priorities so that we can focus on:
•	Protecting and improving the groundwater that supports existing drinking water supplies
•	Groundwater within important aquifers for future supply of drinking water or other environmental use
We recommend that you refer to our published ‘Guiding Principles for Land Contamination’ which outlines the approach which should be adopted when managing this site’s risks to the water environment.
 
We also advise that you consult with your Environmental Health/ Environmental Protection Department for advice on generic aspects of land contamination management. Where planning controls are considered necessary, we recommend that the environmental protection of controlled waters is considered alongside any human health protection requirements. This approach is supported by paragraph 180 of the National Planning Policy Framework.
 
We would like to refer the applicant to our groundwater position statements in ‘The Environment Agency’s approach to groundwater protection’, available from gov.uk. This publication sets out our position for a wide range of activities and developments, 
including major development:

•	Waste management
•	Discharge of liquid effluents
•	Land contamination
•	Ground source heat pumps
•	Cemetery developments
•	Drainage
 
Water Efficiency
Increased water efficiency for all new developments potentially enables more growth with the same water resources. Developers can highlight positive corporate social responsibility messages and the use of technology to help sell their homes. For the homeowner lower water usage also reduces water and energy bills.
 
We endorse the use of water efficiency measures especially in new developments. Use of technology that ensures efficient use of natural resources could support the environmental benefits of future proposals and could help attract investment to the area. Therefore, water efficient technology, fixtures and fittings should be considered as part of new developments.
 
Residential Developments
All new residential developments are required to achieve a water consumption limit of a maximum of 125 litres per person per day as set out within the Building Regulations &c. (Amendment) Regulations 2015.
 
However, we recommend that in areas of serious water stress (as identified in our report Water stressed areas - final classification) a higher standard of a maximum of 110 litres per person per day is applied. This standard or higher may already be a requirement of the local planning authority.
 
Sustainable Drainage Systems (SuDS) 
Support for the use of SuDS to ensure development does not increase flood risk elsewhere is set out in paragraph 173 of the National Planning Policy Framework.
 
Approved Document Part H of the Building Regulations 2010 establishes a hierarchy for surface water disposal, and encourages a SuDS approach. The first option for surface water disposal should be the use of SuDS, which encourage infiltration such as soakaways or infiltration trenches. In all cases, it should be established that these options are feasible, can be adopted and properly maintained and would not lead to any other environmental problems. For example, using soakaways or other infiltration methods on contaminated land carries groundwater pollution risks and may not work in areas with a high-water table. Where the intention is to dispose to soakaway, these should be shown to work through an appropriate assessment carried out under Building Research Establishment (BRE) Digest 365.
 
Water Framework Directive
In line with the Water Environment Regulations, we recommend that the proposed development is used as an opportunity to restore more natural processes to the watercourse. We would not advocate or support the construction of culverting and instead would strongly support the use of nature-based solutions to effectively manage surface water. Measures such as these could also offer a significant environmental gain.

Advice to the LPA – local plan policies
We have also extracted adopted Local Plan Policies that we consider should be considered if the LPA is minded to consent the hybrid planning application:

Green Infrastructure and Greenspace
Policy GI1 Green Infrastructure

We will protect, maintain, enhance and create an integrated network of connected and multi-functional Green Infrastructure assets that:
•	Provides attractive environments where people want to live, work, learn, play, visit and
•	invest;
•	Meets the environmental, social and economic needs of communities across the borough
•	and the wider City Regions;
•	Enhances the quality of life for present and future residents and visitors;
•	Helps to meet the challenge of climate change;
•	Enhances biodiversity and landscape character;
•	Improves opportunities for recreation and tourism;
•	Respects local distinctiveness and historical and cultural heritage;
•	Maximises potential economic and social benefits; and
•	Secures and improves linkages between green and blue spaces

We note and draw attention to the specific paragraph 17.4 that states, “Green Infrastructure will have an important role to play in helping Barnsley to adapt to climate change. For example by moderating urban temperatures, contributing to flood risk management through storing excess rainfall and increasing surface porosity to ease drainage, such as may be delivered through policy CC4 Sustainable Drainage Systems (SuDS), the positive impacts of tree planting in terms of CO2, and opportunities for the provision of renewable energy.”

Policy BI01 Biodiversity and Geodiversity 
Development will be expected to conserve and enhance the biodiversity and geological features of the borough by: 

•	Protecting and improving habitats, species, sites of ecological value and sites of geological value with particular regard to designated wildlife and geological sites of international, national and local significance, ancient woodland and species and habitats of principal importance identified via Section 41 of the Natural Environment & Rural Communities Act 2006 (for list of the species and habitats of principal importance) and in the Barnsley Biodiversity Action Plan. 
•	Maximising biodiversity and geodiversity opportunities in and around new developments. 
•	Conserving and enhancing the form, local character and distinctiveness of the boroughs natural assets such as the river corridors of the Don, the Dearne and Dove as natural floodplains and important strategic wildlife corridors. 
•	Proposals will be expected to have followed the national mitigation hierarchy (avoid, mitigate, compensate) which is used to evaluate the impacts of a development on biodiversity interest. 
•	Protecting ancient and veteran trees where identified. Encouraging provision of biodiversity enhancements
Again, we note and highlight at paragraph 17.22 that, “Biodiversity and geodiversity provides ecosystem services and is integral to Green Infrastructure which itself has an important role to play in climate change as acknowledged in GI1 Green Infrastructure.”

Climate Change
Policy CC1 Climate Change
We will seek to reduce the causes of and adapt to the future impacts of climate change by:

•	Giving preference to development of previously developed land in sustainable locations;
•	Promoting the reduction of greenhouse gas emissions through sustainable design and
•	construction techniques;
•	Locating and designing development to reduce the risk of flooding;
•	Promoting the use of Sustainable Drainage Systems (SuDS);
•	Promoting and supporting the delivery of renewable and low carbon energy; and
•	Promoting investment in Green Infrastructure to promote and encourage biodiversity gain.

Policy CC2 Sustainable Design and Construction
At paragraph 19.6 we particularly support the policy support that, “…will encourage and plan for sustainable decentralised zero or low carbon energy generation, such as biomass-fuelled district heating or combined heat and power (CHP) schemes. Where a heat network is not available or viable, a contribution ensuring connection to a future district heating scheme is required on suitable developments. Developments not connected and unsuitable for future connection to a heat network will rely on energy generated from renewables, like solar panels, photovoltaics and heat pumps.”

Policy CC3 Flood Risk
Despite the development p[proposal not presenting any high risk fluvial flooding, we consider it necessary to underline a need for the applicant to consider surface water as, “Development which would increase the risk of flooding by increasing the rate or volume of surface water must be the subject of measures that will reduce the risk of flooding. In cases where development would increase the risk of flooding by increasing surface water, developers will have to take action to reduce flooding so the development can go ahead, for example, by creating balancing ponds and other facilities for holding water.”

Policy CC4 Sustainable Drainage Systems (SuDS) 
We would expect this policy to be applied, especially with direct reference to paragraphs 19.17-19.21 inclusive, and the potential win-win outcomes with corresponding policies related to green infrastructure and climate change.

Policy CC5 Water Resource Management
We would draw specific attention to this policy and reinforce an important request that the applicant strongly considers the measures it will comply with, “…the key objectives of the Water Framework Directive and Humber River Basin Management Plan, specifically those of the latter which relate to the Don and Rother catchment, the catchment in which the borough lies.”

Community Infrastructure
Policy 1 Infrastructure and Planning Obligations 
Development must be supported by appropriate physical, social, economic and communications infrastructure, including provision for broadband. Development must contribute as necessary to meet all on and off-site infrastructure requirements to enable development to take place satisfactorily. Where the necessary provision is not made directly by the developer, contributions will be secured through planning obligations. Where appropriate, pooled contributions will be used to facilitate delivery of the necessary infrastructure. 

We would particularly draw the LPA’s attention to the defined examples of and need for infrastructure at paragraph 25.3, “These include a need for new or improved provision of roads and other services, public transport, Green Infrastructure, recreation and open space facilities and infrastructure that will make Barnsley a better place such as public realm improvements, educational accommodation, affordable housing and also adequate community facilities.”

Should you require any additional information or clarification, please do not hesitate to contact me on the details below.

Yours sincerely

Ms CLAIRE DENNISON
Sustainable Places - Planning Advisor

Direct e-mail claire.dennison@environment-agency.gov.uk
Team e-mail sp-yorkshire@environment-agency.gov.uk