As everyone in Callander is aware, the town's vulnerability to flooding is associated not only with the river but also with surface run-off of rainfall. To be fair, the Park has acknowledged flooding risks from the river to several of the proposed sites (Churchfields, Stirling Road and The Gart) but none of the sites have been removed from the Local Plan. Nor was the risk from run-off from the Crags or the Mollands even mentioned.

We feel that the Precautionary Principle, as stated in the Local Plan should apply: "Where the effects of the development proposal could potentially result in significant damage, or loss to, the special qualities of the Park, but where there is uncertainty or a lack of knowledge over the nature of the likely impacts, the Precautionary Principle will apply and such development will be restricted."

Of course, the precautionary principle doesn't apply only to "special qualities". It also applies to protecting life, limb and property against unnecessary risk. Where there is even a modicum of doubt as to whether flood risk can be ameliorated, sites at risk of flooding should not be built on.

It is well established that one of the principal causes of inundation in built-up areas is the fact that water can't drain away into the ground. SUDs (sustainable urban drainage systems) are all very well - but exactly how big would these systems have to be to handle the level of run-off that Callander experiences? If you don't know what these systems look like see SEPA's document on SUDs: Sustainable Urban Drainage Systems - Setting the Scene in Scotland.

It would be irresponsible to subject unwitting residents of these proposed developments to the hazard of flooding. Similarly, it would be irresponsible to increase the risk to existing properties and natural habitats by building on open areas that currently offer the town some protection against flooding.

The Scottish Parliament's Scottish Planning Policy, 2010*, paragraph 77, says:

"Location and Design of New Development

77. Planning authorities should set out a settlement strategy in the development plan to provide a long term context for development. Key considerations in a settlement strategy are:

• the efficient use of existing buildings, land and infrastructure,

• accessibility of homes, services, open space and employment opportunities by a range of transport options,

• co-ordination of housing land release with investment in infrastructure including transport and educational investment, and with other major proposals,

• the deliverability of the strategy, and

• the protection and enhancement of landscape, natural, built and cultural heritage, biodiversity and the wider environment, including consideration of flood risk."

We've quoted the whole paragraph because it is highly relevant to Callander's current situation.

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* Scottish Government (2010) Scottish Planning Policy. p16. Edinburgh, Scottish Government. Available online.