Further comments from CAPC on Health Lane Bowling Green proposed development

Cold Ash Parish Council – Further Representation

Planning Application 25/00278/FULMAJ


Dear Ms Nutchey,

Re: Planning Application 25/00278/FULMAJ – Land West of Heath Lane and North of Bowling Green Road, Thatcham

Following the recent Environment Agency response dated 11 June 2026, Cold Ash Parish Council wishes to submit the following further comments and clarification of its position.

CAPC notes that the Environment Agency has reviewed the latest hydraulic modelling submission and has stated that it has no further comments on the additional information provided.

However, CAPC does not consider that this should be interpreted as confirmation that all flood risk, hydrological and planning concerns associated with the application have been satisfactorily addressed or resolved.

The Environment Agency’s response confirms only that it has no further comments to make on the latest submission and refers back to its previous correspondence. In CAPC’s view, a number of important matters remain outstanding and continue to warrant careful consideration by the Local Planning Authority before any determination is made.

CAPC remains concerned regarding:

1.           Groundwater emergence, subsurface flows, springs and wider site hydrology.
2.           The loss of natural water storage and attenuation associated with existing marshland and wetland features.
3.           Reliance on the continued operation and effectiveness of the Thatcham Flood Alleviation Scheme.
4.           The evidential basis for claims that the development will provide flood risk “betterment” and increased resilience.
5.           Whether all relevant hydrological pathways and flood mechanisms have been adequately represented.

Sequential and Exception Tests

CAPC remains unconvinced that the Sequential and Exception Test requirements have been satisfactorily demonstrated, particularly given the evolving understanding of the site’s hydrology, the presence of Flood Zone 3 within the site, and the continued reliance upon assumptions regarding flood storage, groundwater behaviour and the operation of the Thatcham Flood Alleviation Scheme.

The Parish Council continues to question whether sufficient consideration has been given to alternative sites and alternative approaches, particularly given the acknowledged flood risk constraints affecting parts of the application site and the evolving understanding of the site’s hydrology.

Further CAPC is also unaware of any meaningful engagement with local residents, flood wardens or others possessing long-term knowledge of the site’s behaviour and water management characteristics, despite the significant local evidence that has emerged throughout the application process.

Responsibility of the Local Planning Authority

CAPC recognises that the site forms part of the adopted Local Plan. However, allocation within the Local Plan does not remove the Local Planning Authority’s responsibility to ensure that all relevant planning policy requirements have been satisfied and that decisions are based upon robust and complete evidence.

The Parish Council remains concerned that if key assumptions regarding hydrology, groundwater behaviour, flood storage or flood defence performance subsequently prove to be incomplete or incorrect, the consequences would be borne not only by future residents of the development but also by existing communities and infrastructure that currently rely upon the Thatcham Flood Alleviation Scheme for protection.

Conclusion

For the avoidance of doubt, Cold Ash Parish Council maintains its objection to the application.

Whilst the Environment Agency’s latest response is noted, CAPC does not consider that it resolves the wider concerns outlined above and remains of the view that significant uncertainty persists regarding the site’s hydrology, long-term flood resilience and the robustness of the conclusions being advanced in support of the development.

Accordingly, CAPC respectfully requests that these matters continue to be given full weight and careful consideration before any determination is made.

Yours faithfully,

Cllr Pete Murray Vice Chairman
For and on behalf of Cold Ash Parish Council