Flood Risk Sequential Approach
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Kingswood Area Action Plan Flood risk sequential approach November 2015 Kingswood Area Action Plan - Flood risk sequential approach, Hull City Council, November 2015 1 Contents Introduction …………………………………………………………………..………………..… p.3 A. CONTEXT………………………………………………………………..…………….…….. p.4 Methodology and definitions………………………………………….…………………. p.4 Underpinning flood risk evidence base…………………………….……………….. p.7 Planning and flooding history…………………………………………….………………. p.8 B. SEQUENTIAL APPROACH………………………………………….………………. p.11 C. EXCEPTION TEST (part 1 of the test)..…………….……….…………..... p.15 Appendix 1 – SFRA map of Hull Appendix 2 – SFRA map extract of Kingswood Appendix 3 – SHLAA Table of available and/or developable sites in Hull Appendix 4 – SHLAA Table Kingswood sites Appendix 5 – SHLAA map extract of Kingswood Appendix 6 – Kingswood AAP: Areas of Change Kingswood Area Action Plan - Flood risk sequential approach, Hull City Council, November 2015 2 Introduction 1. This report sets out the Council’s flood risk sequential approach to the Area Action Plan (AAP) for Kingswood to 2030. The National Planning Policy Framework (NPPF) requires a flood risk sequential approach to be taken in selecting and allocating land for development in Local Plans. This includes the application of a Sequential Test and if necessary of Exception Tests as defined in the NPPF. The risks associated with flooding at Kingswood relate from potential overtopping or breach of river defences, or pluvial events resulting in overwhelmed land drainage and surface water systems rather than risks derived from the Humber. 2. The report determines whether housing development sites which are at high risk should be allocated at Kingswood, in light of a flood risk Sequential Test applied to the city-wide housing land supply, and if so, whether the sites pass the Exception Test. Part I of the Exception Test i.e. demonstrating wider sustainability benefits in outweighing flood risk is addressed in this report while Part II of the exception text relating to the mitigations to ensure that development will be safe for its lifetime, without increasing flood risk elsewhere and, where possible, reduce flood risk overall, is addressed in a separate document: Kingswood Flood Risk Assessment and Exception Test (Part II) although a summary of it is included in this report for completeness. 3. The report is structured in 3 main parts: A. Context: sets out the methodology, the planning and flooding history of Kingswood, and the policy context; B. Sequential Test: city-wide search for sites that are at the least risk of flooding; and C. Exception Test: ‘Part I’ of the test with a summary of ‘Part II’. Kingswood Area Action Plan - Flood risk sequential approach, Hull City Council, November 2015 3 A. CONTEXT Methodology and definitions 4. The methodology undertaken gives effect to best practice outlined in the National Planning Policy Framework (NPPF) and the Planning Practice Guidance relating to assessing and addressing flood risk. Potential for housing within the AAP is assessed by reference to land supply identified in the latest Strategic Housing Land Availability Assessment (SHLAA, 2015). The search area for the sequential approach is city-wide, corresponding to the whole local authority area, as advised by the Environment Agency. 5. The NPPF also makes reference to assessing ‘reasonably available sites’ when addressing the sequential approach. These are assumed to mean sites with reasonable prospect of being developed for housing within the plan period (15 years). This section describes in paragraphs 10-13 below the criteria used to select reasonably available sites for the purpose of the AAP sequential test. 6. The exceptions element of NPPF is also reviewed with emphasis given to a detailed flood risk assessment and mitigations measures which address the Exception Test Part II (Kingswood Flood Risk Assessment and Exception Test (Part II), available separately). Part I is addressed in this report and in the Sustainability Appraisal of the AAP (available separately). National policy and guidance 7. The National Planning Policy Framework (NPPF) states that Local Plans should apply a Sequential and Exception Test approach to locating development to avoid possible flood risk to people and property. Paragraph 100 states that: “Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere.” 8. It goes on to say that: “Local Plans should apply a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change, by: applying the Sequential Test; if necessary, applying the Exception Test; safeguarding land from development that is required for current and future flood management; using opportunities offered by new development to reduce the causes and impacts of flooding; and Kingswood Area Action Plan - Flood risk sequential approach, Hull City Council, November 2015 4 where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to facilitate the relocation of development, including housing, to more sustainable locations.” 9. Paragraph 101 states that: “The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test. A sequential approach should be used in areas known to be at risk from any form of flooding.” 10. Although there is no definition of what ‘reasonably available’ means, the national policy for housing suggests housing supply should be identified based on sites which are deliverable within 5 years and developable over 5-10 or 10-15 years. NPPF defines the 5-year deliverable sites supply as being: available now; suitable for housing; achievable with realistic prospects for housing to be delivered; and/or those with planning permission. 11. A developable sites supply beyond 5 years is defined in the NPPF as being: suitable for housing and there are reasonable prospects of the site being available or could be viably developed at the point envisaged. 12. These definitions have been use in the Council’s Strategic Housing Land Availability Assessment and all sites meeting these criteria are considered ‘reasonably available’ for the purpose of the Sequential Test. These sites are listed in Appendix 3, ordered according their Flood Zone and with indication of the period in which they are assumed to be able come forward – Period 1 (0-5 years), Period 2 (6-10 years) and Period 3 (11-15 years). 13. In order to arrive at a supply of reasonably available sites, the following sites were discounted in the first place: sites located in the functional flood plain, sites within the Register of Parks and Gardens of Specific Historic Interest, cemeteries, or graveyards, allotments, education land unless put forward through call for sites process. Then, among the remaining supply of sites, consideration was given whether sites were suitable or had prospect of being developed within the Plan period (15 years). A number of sites in Hull are unsuitable or don’t have a reasonable prospect of being developed within the Plan period. These sites don’t appear on the list of reasonably available sites (see Appendix 3). 14. In paragraph 102, the NPPF sets out the conditions to pass the Exception Test: “If, following application of the Sequential Test, it is not possible, consistent with wider sustainability objectives, for the development to be located in zones with a lower probability of flooding, the Exception Test can be applied if appropriate. For the Exception Test to be passed: Kingswood Area Action Plan - Flood risk sequential approach, Hull City Council, November 2015 5 it must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared; and a site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Both elements of the test will have to be passed for development to be allocated or permitted.” 15. This report refers to ‘Part I’ of the Exception Test to describe the first bullet point of paragraph 102 of the NPPF, and ‘Part II’ to describe the second bullet point. 16. Accompanying the NPPF, the recently updated Planning Practice Guidance (2014) provides further elaboration about applying the Sequential and Exception Tests in Local Plan making. The guidance suggests that a Level 2 Strategic Flood Risk Assessment should be used in considering options in the site allocation process, either as part of a sustainability appraisal or a free standing report. Where other sustainability criteria outweigh flood risk issues, the decision making process should be transparent with reasoned justifications for any decision to allocate land in areas at high flood risk. The guidance goes on further to suggest that in circumstances where some areas at lower flood risk may not be suitable for development for various reasons and therefore out of consideration, the Sequential Test should be applied to the whole local planning authority area to increase the possibility of accommodating development which is not exposed to flood risk. Local Planning Authorities should also make clear the criteria used in assessing the Exception Test, having regard to the sustainability appraisal framework objectives. Local Policy 17. The current adopted Development Plan for the city is the Local Plan, 2000. This is increasingly becoming out-of-date and a new Local Plan is under development, following the withdrawal of the Core Strategy in 2013.