Sequential and Exception Tests for Housing Site Options Review 2020

Sequential and Exception Tests for Housing Site Options

Review 2020

Contents

Introduction ...... 1 Housing Requirement ...... 3 Sites...... 5 Methodology ...... 6 Results ...... 11 Conclusions ...... 26

Introduction

A sequential and exceptions test paper was prepared in 2018 to inform the selection of sites for inclusion in the emerging Castle Point Local Plan. Since that time, there have been some modest changes to the housing supply situation, and this paper therefore reviews the sequential and exceptions test and ensures that the site selection process remains in line with national policy regarding development and flood risk.

National Policy Context

The National Planning Policy Framework (NPPF) requires local planning authorities to take account of the risk of flooding when preparing their local plans. The NPPF sets out a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property, and to manage any residual risk. It is expected that the impacts of climate change are taken into account when considering flood risk, as properties built now are expected to last at least 100 years.

In order to direct development, where possible, away from areas at highest risk of flooding, the NPPF requires local planning authorities to carry out a ‘sequential test’ when preparing their local plans. National planning guidance contains information on the application of the sequential test including information on the different ‘flood risk zones’ and the types of development normally appropriate in each having regard to the vulnerability of future users.

The NPPF recognises that following the application of the sequential test, it is not always possible, consistent with wider objectives, for certain development proposals/requirements to be located in lower ‘flood risk zones’. It therefore also sets out a test that needs to be passed if certain types of development are to be exceptionally allocated in a local plan, or otherwise permitted. This is known as the Exception Test and comprises two elements:

• It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk; • 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.

National planning guidance details when it is required when applying the Exception Test.

Local Policy Context

The Thames Estuary 2100 Plan sets out specific policies in relation to the management of flood risk in and around the Thames Estuary. Whilst applying the general policy of directing development away from areas at higher risk of flooding, it recognises that there are some areas around the Thames Estuary that are already substantially developed, and may require additional development to occur in the future in order to support the creation of sustainable communities. Where substantial communities do exist, the Thames Estuary 2100 Plan sets out a policy of maintaining and enhancing the existing defences in order to respond to the

1 implications of climate change. This policy applies on Canvey Island. It does not however apply to the undeveloped area south of Hadleigh.

Evidence Base

The NPPF expects local authorities to prepare Strategic Flood Risk Assessments in areas where there is likely to be a risk of flooding. Due to Castle Point’s coastal location, it is appropriate for a Strategic Flood Risk Assessment to form part of the New Local Plan’s proportionate evidence base.

The South Essex Strategic Flood Risk Assessment Level 1 (SFRA) was prepared in 2018 and assessed tidal, surface, rivers, groundwater, sewers and other sources. The study found that tidal and fluvial flooding poses the most significant risk to Castle Point, in particular Canvey Island and Hadleigh Marshes. The topography and location of watercourses on Canvey Island means that the whole island is at risk from tidal and fluvial flooding. Although much of the island is protected by the presence of defences, the island is still at residual risk of flooding if the defences were to fail or to be overtopped. This risk is increased as a consequence of climate change and predictions around sea level rise.

On the mainland area of the Borough, the Prittle Brook and Benfleet Hall Sewer pose the most significant fluvial risk with the southern part of South Benfleet and Hadleigh located within Flood Zone 2 and 3 as well as a small area along the course of the Prittle Brook. High Ground and embankments protect the area from flooding however the area is still at residual risk.

A series of high level site specific assessments were undertaken as part of the draft SFRA Level 2 2018 to assist in the consideration of site options.

Housing Requirement

Based on the standard methodology of calculating housing need set out in the NPPF, there is a need for 5,295 new homes in Castle Point between 2018-2033. This equates to 353 homes per year. At April 2020, 271 homes net had been delivered leaving an outstanding requirement for 5,024 homes.

The NPPF requires a 5-year land supply of deliverable housing sites to be identified. Due to poor delivery in the past this should include a 20% buffer brought forward from later in the plan period. The deficit arising between 2018 and 2020 also needs to be addressed. This means it is necessary to identify deliverable sites that can deliver 2,553 homes within the five year period from 2020 to 2025. To ensure that 353 homes are delivered per annum for the period 2018-2033, developable sites need to be identified with a capacity to provide a further 2,471 homes after 5 years.

At April 2020, there were extant consents in place for 712 homes (net). These will contribute towards future housing supply, but do not form part of this assessment, as any requirement to undertake the Sequential and Exception Tests has already been addressed through the development management process. This includes allocations HO27, HO28, HO29 and HO30 in the Local Plan November 2019. It is anticipated that these consents will be delivered within the five-year period from 2020 to 2025, reducing the requirement to find for that period from 2,553 to 1,841.

To identify additional housing supply, it is necessary to turn to the Strategic Housing Land Availability Assessment SHLAA (2018) which identified 212 development sites that are suitable, available and achievable for the delivery of housing. Due to the passage of time some of these sites now benefit from planning consent.

At April 2020, there were 14 sites identified through the SHLAA 2018 which do not benefit from full planning consent and are included on the brownfield register. These sites have capacity for 184 homes. The majority of these are for sites located in flood risk zone 1. There are however four sites located on Canvey Island. Two of these sites benefit from outline planning consent and have consequently been tested against the sequential and exception tests. However, there are two, with a capacity of 25 homes which still require planning consent. There is therefore capacity from the brownfield land register of 159 homes in flood risk zone 1. The remaining capacity from the Brownfield Land Register (25 homes) will be tested through this paper.

At April 2020, there were 102 sites identified through the SHLAA 2018 that are located within the urban areas and are policy compliant. These sites have the capacity for 275 homes. 139 of these homes can be secured on sites in flood risk zone 1. However, there 136 homes which are on otherwise policy compliant sites within the existing urban area of Canvey Island. This capacity on Canvey Island will be tested through this paper.

Overall, there is identified capacity for 1,010 homes (712 extant consents; 159 brownfield land register; 139 policy compliant) to be secured on identified sites within Castle Point

3 outside flood risk zones 2 or 3 outside of any allocations in the Local Plan. This leaves a requirement for a supply of a further 4,014 homes to be identified. This paper will test the potential for sites in Castle Point to meet the sequential and exception test to fulfil this requirement. This will include testing of potential brownfield capacity and existing urban sites, as well as potential strategic allocations.

There are clear constraints on Castle Point that affect the ability to achieve such high levels of growth. However, both the Government and neighbouring authorities will expect Castle Point to go as far as is reasonably possible to achieve housing growth.

Table 1: Housing Requirement Calculation based on Objectively Assessed Housing Need of 342 homes per annum

Required Identified1 Outstanding Delivery Requirement 2018 – 2033 5,295 1,281 4,014

Sites

The following allocated strategic sites, which do not currently benefit from planning consent or a resolution to grant planning permission subject to a Section 106 Agreement, are the subject of this sequential, and where appropriate exception test.

Table 2: List of sites

Allocated Sites Brownfield Land Register Policy Compliant SHLAA Sites HO9 Land west of Benfleet, Benfleet HO10 Land between Felstead Road and Catherine Road, Benfleet HO11 Land off Glyders, Benfleet HO12 Former WRVS Hall, Richmond Avenue, Benfleet HO13 Land east of Rayleigh Road, Hadleigh HO14Land at Brook Farm, Daws Heath HO15 Land south of Scrub Lane, Hadleigh HO16 Land at Oak Tree Farm, Hadleigh HO17 Hadleigh Island Site, Hadleigh HO18 Land north of Grasmere Road and Borrowdale Road, Thundersley HO19 Land at Glebelands, Thundersley HO20 Land at The Chase, Thundersley HO21 Land fronting Rayleigh Road, Thundersley HO22 Land at Thames Loose Leaf, Thundersley HO23 Land east of Canvey Road, Canvey HO24 Land west of Canvey Road, Canvey HO25 Land at Thorney Bay, Canvey HO26 Land at The Point, Canvey HO27 Kings Park, Canvey

The sustainability appraisal identifies some reasonable alternative sites. These have been tested through the sustainability appraisal process; however, the allocation sites have been found to be the most appropriate for the purposes of accommodating housing development. This assessment does not therefore consider specific alternative sites. However, commentary is provided as part of the assessment as to the implications for the inclusion of alternative sites on the outcomes of the sequential test for those sites located in Flood Risk Zone 3a, primarily on Canvey Island.

Methodology

For the purposes of this assessment, all sites will be considered on the basis that they are proposed for residential development comprising bricks and mortar dwellings or residential institutions. These uses are identified in Table 2 of the National Planning Practice Guidance as being ‘more vulnerable’.

Sequential Test

Table 1 of the National Planning Practice Guidance identifies four different flood risk zones. These will be used when applying the sequential test. These zones are:

• Zone 1 – low probability. All uses of land are appropriate in this zone. • Zone 2 – medium probability. Essential infrastructure, water compatible, less vulnerable and more vulnerable uses area appropriate in this zone. Highly vulnerable uses are only appropriate in this zone if the exception test is passed. • Zone 3a – high probability. Water compatible and less vulnerable uses are appropriate in this zone. Highly vulnerable uses should not be permitted. The more vulnerable uses and essential infrastructure should only be permitted in this zone if the Exception Test is passed. • Zone 3b – functional floodplain. Only water compatible uses and essential infrastructure that has to be there should be permitted in this zone. Essential infrastructure should pass the Exception Test.

Each site has been allocated to a zone having regard to the Environment Agency Flood Risk Zone mapping. Having regard to the restrictions set out above, any site located within zone 3b has been eliminated from consideration at this stage because ‘more vulnerable’ uses are not permitted in this zone.

Information from the SHLAA 2018 has then been used to determine the availability of each site. Sites have been identified taking into account their availability, suitability, and likely economic viability.

All deliverable sites were then organised sequentially, with the sites in zones of lower probability of flooding listed above those in zones of higher risk. No other factors were applied to organise/rank the sites at this stage, and therefore all sites within a particular flood risk zone should be considered equally from a flood risk perspective.

The capacity of the sites within the zones at lowest risk of flooding were then accumulated in order to determine whether those sites at higher probability of flooding were needed to ensure a five year housing land supply.

Where the cumulative capacity of sites in the lower flood risk zone was insufficient to ensure a five year housing land supply, all sites in the next lowest flood risk zone were considered to pass the sequential test. Where there was sufficient supply in lower flood risk zones, sites in higher flood risk zones were not considered to pass the sequential test.

Where a deliverable site in a zone at higher risk of flooding was not considered to meet the requirements of the sequential test for inclusion in the five-year housing land supply, it was moved onto the list of developable sites. Additionally, any spare capacity in relation to sites in lower probability zones was also carried forward to the developable site calculation. The process set out in the previous paragraph was then repeated for developable sites. Where a sites at higher probability of flooding were required to ensure an ongoing supply of housing land to meet objectively assessed housing needs, they were considered to pass the sequential test. Where they were not required, they were not considered to pass the sequential test.

Exception Test

The National Planning Guidance is clear in Tables 1 and 3 that the exception test should be applied where a ‘more vulnerable’ type of development is located in flood risk zone 3a, and passes the sequential test.

Sites which meet the above criteria must pass two tests. Sites must pass both elements in order to be appropriate for allocation.

Firstly, they must demonstrate that the development would provide wider sustainability benefits to the community that outweigh flood risk.

Each of these sites would have been assessed in terms of flood risk in the Sustainability Appraisal. The sustainability appraisal has been used to determine whether other sustainability objectives will be achieved. Where several other sustainability objectives will be achieved, a site has been considered to have passed this element of the Exception Test. Where a site is unlikely to achieve other sustainability objectives, it fails this element of the Exception Test.

Secondly, a site specific flood risk assessment must demonstrated 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.

Where available, the site specific flood risk assessments set out in the Strategic Flood Risk Assessment have been considered. Risk is a culmination of the likelihood of a flood event occurring and the extent of hazard that event would cause. Due to the presence of substantial sea defences on Canvey Island, the likelihood of a tidal flood event on Canvey Island is very low, despite its location. However, breach modelling and overtopping modelling undertaken as part of the Strategic Flood Risk Assessment indicates that there is a residual risk of flooding occurring, and the hazard arising from such an event would be high. As part of this assessment, consideration has been given to the level of hazard at each site, considering the appropriate estimated flood event in 2110. These represent the worst-case scenario, taking into account climate change. Advice is set out in these assessments about mechanisms for reducing the risk of flooding at these sites.

Consideration has also been given to the policies in the Thames Estuary 2100 Plan in order to determine whether interventions are likely that will prevent any increase in hazard from occurring, or potentially reduce the level of hazard. Where it is likely that the risk of flooding will not increase, or will reduce as a result of development and/or policy control, this element of the Exception Test will be passed. Canvey Island is covered by policy P4 of the Thames Estuary 2100 Plan. Policy P4 states that there is a need to ‘take further action to keep up with climate and land use change so that flood risk does not increase’. To this end, recommendations 6,7, and 11 for action zone 7, in which Canvey Island is located, seek to maintain, enhance, improve or replace the river defence walls and active structures throughout the period to 2100.

Surface Water Flooding

The NPPF expects local planning authorities to assess the risk from all sources of flood risk, and the Strategic Flood Risk Assessment describes the risks from this source.

The Council in partnership with Basildon Borough Council, Rochford District Council and Essex County Council has had a Surface Water Management Plan prepared for South Essex. This modelled surface water flood risk at a local level, and maps potential surface water flooding hotspots, and the areas that drain to these hotspots - known as Critical Drainage Areas (CDAs). The risk of flooding within each CDA was modelled for a 1 in 100-year event, taking into account climate change impacts. Since that time, Essex County Council as the Lead Local Flood Authority (LFFA) has reviewed the Critical Drainage Areas using the hydraulic catchments. The revised CDAs cover different extents to the original CDAs, and consequently some sites which were located in CDAs are now not, and others are now captured.

Each of the sites has been assessed against the updated Critical Drainage Areas to determine whether:

a) It is in a critical drainage area; and b) It is within a potential surface water flooding hotspot.

Where a site is outside a critical drainage area, it is considered appropriate for development, in terms of surface water flood risk.

Where a site is within a critical drainage area, consideration has been given to the potential to use source and pathway methods of surface water management to prevent flooding elsewhere. Reference has been had to the updated South Essex Surface Water Management Plan Action Plan in determining whether it is viable to use source and pathway methods in the location of the site. For most of the CDAs property level flood resilience is identified as a potential action, however this is considered to be a last resort action to alleviate existing flood risk issues for existing properties. It is not felt that mitigation of this nature should be used to off-set the impact of new development. A site has only been considered appropriate for development, in terms of surface water flood risk, where it is viable to install surface water management techniques, excluding property level flood resilience.

Where a site is within, or contains, a surface water flooding hotspot, consideration has been given to the potential to avoid the area of the site likely to be flooded in the first instance, and then where this does not resolve the issue, the potential to employ flood resistance and resilience techniques that manage surface water flood risk. A site has only been considered appropriate for development, in terms of surface water flood risk, where it is possible to avoid, or at very least manage surface water flood risk through resistance and resilience measures.

Groundwater Flooding

As with surface water, it is necessary to assess the risk of flooding from groundwater sources in order to meet the requirements of the NPPF, and the Strategic Flood Risk Assessment describes the risks from this source.

The South Essex Surface Water Management Plan did however include an intermediate assessment of groundwater flooding susceptibility using data from the British Geological Society. This intermediate assessment shows where groundwater flood issues have the potential to be an issue. It does not however include modelling of the likely extent or depth of flooding, which would need to be done on a site by site basis.

The South Essex Surface Water Management Plan includes a map showing the susceptibility of Castle Point to Groundwater flooding. This has been compared to those deliverable and developable sites contained within this assessment. This has allowed identification of those sites where groundwater is a potential issue, and where the use of certain types of infiltration SUDS will be limited by an existing high water table.

Where a site is not within an area susceptible to groundwater flooding, it will be considered appropriate for development in this regard.

Where a site is within an area susceptible to groundwater flooding, it will only be considered appropriate if alternative options for managing surface water, in addition to infiltration SUDS, are an option for the site, and the development does not contain basement dwellings.

Results

Sequential Test

Deliverable Sites

The following Table 3 sets out the result of the sequential test for the deliverable allocation sites. There is a need for sites with a capacity of 1,841 homes to be identified from this list to ensure a five-year housing land supply based on the objectively assessed housing need of 353 homes per annum. The overall cumulative capacity of sites in Flood Risk Zone 1 on this list is 874 homes. Therefore, in order to meet the agreed target, there is a need to include those sites in Flood Risk Zone 3a within the five-year housing land supply.

Table 3: Sequential Test Results for Deliverable Sites

Flood Risk Capacity Zone Site Availability Zone Years 1-5 Capacity Land west of Benfleet, Benfleet 1 Deliverable 200 Land between Felstead Road and Catherine Road, Benfleet 1 Deliverable 29 Land off Glyders, Benfleet 1 Deliverable 30 Land East of Rayleigh Road, Hadleigh 1 Deliverable 165 Land at Brook Farm 1 Deliverable 100 Land south of Scrub Lane, Hadleigh 1 Deliverable 25 Hadleigh Island Site, Hadleigh 1 Deliverable 12 Land at Glebelands, Thundersley 1 Deliverable 155 Land at The Chase, Thundersley 1 Deliverable 85 Brownfield Land Register Sites – Benfleet, Hadleigh and 1 Deliverable 67 Thundersley Policy compliant SHLAA Sites – Benfleet, Hadleigh and 1 Deliverable 6 Thundersley 874 Land at Oak Tree Farm, Mainly 1 (90%) Hadleigh Partial 2 (3%) Deliverable 30 30 Partial 3a (7%) Land at Thorney Bay, Canvey 375 gross 3a Deliverable Island 105 net 173 Land east of Canvey Road, Canvey Island 3a Deliverable 62

Policy Compliant SHLAA Sites – Canvey Island 3a Deliverable 6

Total 1,077

Alternative Deliverable Sites

There are alternative sites that the Council has excluded from allocation in the Local Plan for various reasons, many related to their impact on environmental assets or the landscape. These are detailed in the Sustainability Appraisal. The promoters of some of these sites may indicate that these sites are deliverable.

Whilst some of these sites are in Flood Risk Zone 1, and potentially represent an alternative to those proposals allocated on Canvey Island, their allocation as an alternative to a site on Canvey Island is not justified based on the five-year land supply position, as the deficit is such that their allocation would be in addition to any site on Canvey Island in order to achieve a five-year supply. Any such decision could only therefore be taken in respect of the sites own merits having regard to those constraints identified in the Sustainability Appraisal, and not in relation to the site as an alternative to an allocation on Canvey Island.

Developable Sites

The following Table 4 sets out the results of the sequential test for developable sites. In order to meet the objectively assessed need for 5,295 homes in total over the period 2018 to 2033, there is a need for sites with a capacity of 3,235 homes to be identified from this list (this includes accounting for under provision in the period to 2025). The overall cumulative capacity of sites in Flood Risk Zone 1 on this list is 1,775 homes. There is therefore a need to identify sites at higher risk of flooding to meet the agreed housing target.

Table 4: Sequential Test Results for Developable Sites

Flood Risk Capacity Zone Site Availability Zone Years 6-15 Capacity Land west of Benfleet, Benfleet 1 Developable 650 Land between Felstead Road 1 Developable 60 and Catherine Road, Benfleet Land East of Rayleigh Road, Hadleigh 1 Developable 290 Land at Brook Farm, Daws Heath 1 Developable 73

Land south of Scrub Lane, 1 Developable 30 Hadleigh Hadleigh Island Site, Hadleigh 1 Developable 40

Land north of Grasmere Road 1 Developable 30 and Borrowdale Road

Land at The Chase, Thundersley 1 Developable 255 Land fronting Rayleigh Road, Thundersley 1 Developable 60

Land at Thames Loose Leaf, 1 Developable 12 Thundersley 244 – 258 London Road, Hadleigh (Garston Block) 1 Developable 50

Brownfield Land Register Sites – Benfleet, Hadleigh and 1 Developable 92 Thundersley Policy compliant SHLAA Sites – Benfleet, Hadleigh and 1 Developable 133 1,775 Thundersley Land at Oak Tree Farm, Mainly 1 (90%) Hadleigh Partial 2 (3%) Developable 35 35 Partial 3a (7%) Former WRVS Hall, Richmond Mainly 3 (93%) Avenue, Benfleet Partial 2 (5%) Developable 39 39 Partial 1 (2%) Land at The Point, Canvey 3a Developable 100 Island Land at Thorney Bay, Canvey 299 gross 3a Developable Island 84 net

Land west of Canvey Road, 3a Developable 196 Canvey Island Land east of Canvey Road, Canvey Island 3a Developable 238 Brownfield Land Register Sites

– Canvey Island 3a Developable 25

Policy compliant SHLAA Sites – 773 Canvey Island 3a Developable 130

Total 2,622

Alternative Deliverable Sites

Whilst some of these sites are in Flood Risk Zone 1, and potentially represent an alternative to those proposals allocated on Canvey Island, their allocation as an alternative to a site on Canvey Island is not justified based on the housing supply position, as the deficit is such that their allocation would be in addition to any site on Canvey Island in order to achieve a sufficient supply. Any such decision could only therefore be taken in respect of the sites own

13 merits having regard to those constraints identified in the Sustainability Appraisal, and not in relation to the site as an alternative to an allocation on Canvey Island.

Windfall Allowance

It is noted that this paper identifies a deficit against the housing target. This paper does not however include the windfall allowance, as by its nature it is not possible to test that figure against the sequential and exception tests at this time. A separate paper has been preparing detailing a windfall allowance of 660 homes, which when combined with the supply identified above secures delivery of 5,367 homes net against the housing target. There is therefore a sufficient supply of land identified within the Local Plan to meet the Borough’s housing needs in the period 2018 to 2033.

Exception Test

When considered against the objectively assessed need of 353 homes per annum, sites within flood risk zones 2 and 3 are required in order to deliver sufficient homes on Castle Point.

Table 5: Exception Test Results

Site Test Part 1 – Wider Test Part 2 – Flood Risk Pass or sustainability benefits Management and safety Fail Oak Tree This site has significant positive As the majority of this site (90%) is Pass Farm, impacts related to the within Flood Risk Zone 1, it is Hadleigh sustainability objective possible, through design to avoid concerning the provision of those parts of the site at risk of housing, including affordable flooding. housing. This site has minor positive impacts related to the sustainability objectives concerning landscape character, flooding, air quality, social exclusion and use of resources and infrastructure to support sustainable development. Former This site has significant positive Fluvial modelling will be required to Pass WRVS Hall, impacts related to the further understand the extent of Richmond sustainability objective fluvial risk to the site. To mitigate the Avenue, concerning the provision of risk of flooding more vulnerable uses Benfleet housing, including affordable should be preferentially located away housing. This site has minor from areas within the 1% AEP flood positive impacts related to the extent (1 in 100 year) for the main sustainability objectives river including an allowance for concerning biodiversity, climate change. Residential uses will landscape character, flooding, air be accommodated for on the first quality, social exclusion, health floor or above with less vulnerable inequalities, and use of uses located on the ground floor resources and infrastructure to level. Due to the extent of flood risk support sustainable on the site, a Flood Warning and development. Evacuation Plan should be prepared and implemented to ensure occupants of the site are aware of the risks and have suitable access and egress arrangements in place. The Emergency Planning Team has not raised an issue with the principle of this allocation. Land at The This site has significant positive Effective surface water management Pass Point, impacts related to the measures must be implemented, Canvey sustainability objective including careful site and building Island concerning the provision of layout and the incorporation of housing, including affordable SuDS, in order to reduce flooding housing. This site has minor both on the site and routing of flood positive impacts related to the water to other areas. Floor levels sustainability objectives should be set above 600mm above

Site Test Part 1 – Wider Test Part 2 – Flood Risk Pass or sustainability benefits Management and safety Fail concerning townscape character, the modelled floor level for the 0.5% flooding, air quality, social AEP (1 in 200 year) breach event, exclusion and use of resources with less vulnerable uses located at and infrastructure to support ground level. A Flood Warning and sustainable development.t Evacuation Plan (FWEP) must be prepared for the site in consultation with the Emergency Planning Team and Castle Point Borough Council, detailing how flood warning will be provided as well as how the safety of occupants and access to/from the development will be ensured. The Emergency Planning Team has not raised an issue with the principle of this allocation. Land at This site has significant positive Effective surface water management Pass Thorney Bay, impacts related to the measures must be implemented, Canvey sustainability objective including careful site and building Island concerning the provision of layout and the incorporation of housing, including affordable SuDS, in order to reduce flooding housing. This site has minor both on the site and routing of flood positive impacts related to the water to other areas. Floor levels sustainability objectives should be set to the higher of concerning landscape character, 300mm above the modelled flood flooding, air quality, accessibility level for the fluvial watercourses to services, social exclusion, adjacent to the site, or 600mm above improving health and reducing the modelled floor level for the 0.5% inequalities and use of resources AEP (1 in 200 year) breach event. and infrastructure to support Less vulnerable uses should be sustainable development. located at ground level. A Flood Warning and Evacuation Plan (FWEP) must be prepared for the site in consultation with the Emergency Planning Team and Castle Point Borough Council, detailing how flood warning will be provided as well as how the safety of occupants and access to/from the development will be ensured. The Emergency Planning Team has not raised an issue with the principle of this allocation. Kings Park, This site has significant positive Effective surface water management Pass Canvey impacts related to the measures must be implemented, Island sustainability objective including careful site and building concerning the provision of layout and the incorporation of housing, including affordable SuDS, in order to reduce flooding housing. This site has minor both on the site and routing of flood positive impacts related to the water to other areas. Floor levels sustainability objectives concerning biodiversity, should be set to the higher of landscape character, flooding, air 300mm above the modelled flood

Site Test Part 1 – Wider Test Part 2 – Flood Risk Pass or sustainability benefits Management and safety Fail quality, social exclusion and use level for the fluvial watercourses of resources and infrastructure to adjacent to the site, or 600mm above support sustainable the modelled floor level for the 0.5% development. AEP (1 in 200 year) breach event. Less vulnerable uses should be located at ground level. A Flood Warning and Evacuation Plan (FWEP) must be prepared for the site in consultation with the Emergency Planning Team and Castle Point Borough Council, detailing how flood warning will be provided as well as how the safety of occupants and access to/from the development will be ensured. The Emergency Planning Team has not raised an issue with the principle of this allocation.

Land west of This site has significant positive Effective surface water management Pass Canvey impacts related to the measures must be implemented, Road, sustainability objective including careful site and building Canvey concerning the provision of layout and the incorporation of Island housing, including affordable SuDS, in order to reduce flooding housing. This site has minor both on the site and routing of flood positive impacts related to the water to other areas. A Flood sustainability objectives Warning and Evacuation Plan concerning biodiversity, landscape character, flooding, air (FWEP) must be prepared for the quality, sustainable travel, site in consultation with the accessibility to services, social Emergency Planning Team and exclusion and use of resources Castle Point Borough Council, and infrastructure to support detailing how flood warning will be sustainable development. provided as well as how the safety of occupants and access to/from the development will be ensured. The Emergency Planning Team and Environment Agency has not raised an issue with the principle of this allocation. Land East of This site has significant positive This site is considered to fulfil Pass Canvey Road impacts related to the sustainability criteria; in relation to sustainability objective flood risk, after engagement with the concerning the provision of Emergency Planning Team this site housing, including affordable is considered to pass the Exceptions housing. This site has minor Test in regards to flooding. Effective positive impacts related to the surface water management sustainability objectives concerning biodiversity, measures must be implemented, landscape character, flooding, air including careful site and building

Site Test Part 1 – Wider Test Part 2 – Flood Risk Pass or sustainability benefits Management and safety Fail quality, sustainable travel, layout and the incorporation of accessibility to services, social SuDS, in order to reduce flooding exclusion and use of resources both on the site and routing of flood and infrastructure to support water to other areas. A Flood sustainable development. Warning and Evacuation Plan (FWEP) must be prepared for the site in consultation with the Emergency Planning Team and Castle Point Borough Council, detailing how flood warning will be provided as well as how the safety of occupants and access to/from the development will be ensured. The Emergency Planning Team and Environment Agency has not raised an issue with the principle of this allocation.

Surface Water Flood Risk Assessment

All the deliverable and developable sites assessed in terms of their risk of surface water flooding were found to be appropriate for development, at least in this respect.

Six sites were found to be beyond critical drainage areas, and therefore requiring no mitigation to alleviate existing risk.

The majority of sites were however within a critical drainage area, and therefore in most cases surface water management is required to manage and reduce the risk of surface water flooding to people and properties nearby.

There were three sites located within potential Surface Water Flooding Hotspots that are in Flood Risk Zone 1. At Land between Felstead Road and Catherine Road, there is an issue with potential flows across the northern part of the site. This can be alleviated through the creation of flood storage on-site and improvements to drainage infrastructure in the vicinity of the site. Surface water management can be approached through flood storage on-site for land off The Glyders.

Land at The Chase has a flow path travelling through the site. Due to the relatively flat gradient of the land in this location there is a risk of siting surface water on this site. There is therefore a need to avoid those areas of the site at risk of surface water flooding as well as installing surface water management techniques such as Sustainable urban Drainage Systems (SuDS), flood storage and on-site improvements to drainage infrastructure. Due to the size of this site, it is feasible to bring forward development whilst avoiding those parts of the site at risk of flooding.

Table 6: Surface Water Risk Assessment Within a Appropriate Within a potential Surface Surface water management development site in Site CDA? Water Flooding options terms of Surface Hotspot? Water Flooding? Land west of Yes – part No 1. Work with Environment YES – site is not Benfleet, within Agency to ensure adjacent to the Main Benfleet NCAST_001 maintenance, access and River. Therefore, mitigation is carried out measures which where appropriate along manage conveyance to the Main River within the the Main River from CDA. this site would be 2. Appropriate development appropriate. control over land adjacent to the Main River. Land Yes – No 1. Work with Environment YES – site is not between NCAST_001 Agency to ensure adjacent to the Main Felstead maintenance, access and River. Therefore, Road and mitigation is carried out measures which Catherine where appropriate along manage conveyance to Road, the Main River within the the Main River from Benfleet CDA. this site would be 2. Appropriate development appropriate. control over land adjacent to the Main River. Land off Yes – No Investigate specific surface YES – with appropriate Glyders, NCAST_004 water flood risk mitigation to Surface Water Benfleet manage overland flow and Management reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in land to east of Essex Way. Former Yes – Yes – parts of site 1. Work with Environment YES – if surface water WRVS Hall, NCAST_001 are flow paths for Agency to ensure management options Richmond surface water maintenance, access and are applied, as this site Avenue, mitigation is carried out is nearby the Main Benfleet where appropriate along River. the Main River within the CDA. 2. Appropriate development control over land adjacent to the Main River. Land East of Yes – No 1. Investigate specific surface YES – with appropriate Rayleigh ROCH_001 water flood risk mitigation Surface Water Road, to manage overland flow Management. Hadleigh and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in the land to the south of A1015. 2. Appropriate maintenance of Ordinary Watercourse within CDA, including control of development adjacent to watercourse.

Within a Appropriate Within a potential Surface Surface water management development site in Site CDA? Water Flooding options terms of Surface Hotspot? Water Flooding? 3. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Eastwood Brook Main River. Land at Yes – No 1. Investigate specific surface YES – with appropriate Brook Farm, ROCH_002 water flood risk mitigation Surface Water Hadleigh to manage overland flow Management and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in open space such as land adjacent to Belfairs Golf Course, land to the west of Daws Heath Road and Westcliff School. 2. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Prittle Brook Main River. Land south Yes – No 1. Investigate specific surface YES – with appropriate of Scrub ROCH_002 water flood risk mitigation Surface Water Lane, to manage overland flow Management Hadleigh and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in open space such as land adjacent to Belfairs Golf Course, land to the west of Daws Heath Road and Westcliff School. 2. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Prittle Brook Main River. Land at Oak Yes – No 1. Investigate specific surface YES – with appropriate Tree Farm, ROCH_002 water flood risk mitigation Surface Water Hadleigh to manage overland flow Management and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in open space such

Within a Appropriate Within a potential Surface Surface water management development site in Site CDA? Water Flooding options terms of Surface Hotspot? Water Flooding? as land adjacent to Belfairs Golf Course, land to the west of Daws Heath Road and Westcliff School. 2. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Prittle Brook Main River.. Hadleigh No No N/A YES Island Site, Hadleigh Land north of YES – No Installation of SuDS measures YES – with appropriate Grasmere ROCH_005 throughout CDA to reduce Surface Water Road and surface water flooding depths Management Borrowdale and durations. Road Land at Yes – No Installation of SuDS measures YES – with appropriate Glebelands, ROCH_005 throughout CDA to reduce Surface Water Thundersley surface water flooding depths Management and durations. Land at The Yes – Yes – parts of site 1. Investigate specific surface YES – with appropriate Chase, ROCH_002 are flow paths for water flood risk mitigation Surface Water Thundersley surface water to manage overland flow Management and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in open space such as land adjacent to Belfairs Golf Course, land to the west of Daws Heath Road and Westcliff School. 2. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Prittle Brook Main River.. Land fronting YES – No 1. Investigate specific surface YES – with appropriate Rayleigh ROCH_002 water flood risk mitigation Surface Water Road, to manage overland flow Management Thundersley and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in open space such as land adjacent to Belfairs Golf Course, land to the west of Daws Heath Road and Westcliff School.

Within a Appropriate Within a potential Surface Surface water management development site in Site CDA? Water Flooding options terms of Surface Hotspot? Water Flooding? 2. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Prittle Brook Main River.. Land at Yes – No 1. Investigate specific surface YES – with appropriate Thames ROCH_002 water flood risk mitigation Surface Water Loose Leaf, to manage overland flow Management Thundersley and reduce risk of surface water flooding through considering the construction of basins and associated bunds and NFM in open space such as land adjacent to Belfairs Golf Course, land to the west of Daws Heath Road and Westcliff School. 2. Work with Environment Agency to ensure maintenance, access and mitigation is carried out where appropriate along the Prittle Brook Main River.. Land east of No No N/A YES Canvey Road, Canvey Island Land west of No No N/A YES Canvey Road, Canvey Island Land at No No N/A YES Thorney Bay, Canvey Island Land at The No No N/A YES Point, Canvey Island Kings Park, Yes – No Ensure any future YES – with appropriate Canvey NCAST_002 development within the CDA Surface Water Island prioritises surface water flood Management risk and provides betterment to greenfield runoff rates where possible and incorporates attenuation and mitigation. 244-258 No No N/A YES London Road, Hadleigh

Groundwater Risk Assessment

All the deliverable and developable sites assessed in terms of their risk of groundwater flooding were found to be appropriate for development, at least in this respect. Four sites were found to be at least partially on land susceptible to groundwater flooding.

Land west of Glebelands is an area of high susceptibility and will need to employ source control SUDS and drainage improvements to manage the interaction between surface water and groundwater in order to manage groundwater flooding of the site. Additionally, buildings will need to be constructed to be resistant and resilient to flooding.

Oak Tree Farm is located adjacent to the Prittle Brook and contains areas of land with very high susceptibility to groundwater flooding. As with Land West of Glebelands, source control SuDS and drainage improvements will be needed to manage the interaction between surface water, fluvial and groundwater flooding of this site. Additionally, buildings will need to be constructed to be resistant and resilient to flooding.

Land east of Downer Road North has a small area of land that is susceptible to groundwater flooding. As this makes up a small proportion of the site properties should be designed to be resistant and resilient to ground water flooding.

Land east of Rayleigh Road is susceptible to ground water flooding on the northern periphery of the site and due to the size of this site it is possible to avoid ground water risk through location of development.

Table 7: Groundwater Flood Risk Assessment

Within an area Appropriate development susceptible to Potential to manage Site site in terms of Groundwater Groundwater groundwater flood risk Flooding? Flooding? Land west of No N/A YES Benfleet, Benfleet

Land between No N/A YES Felstead Road and Catherine Road, Benfleet Land off Glyders, No N/A YES Benfleet

Former WRVS No N/A YES Hall, Richmond Avenue, Benfleet

Within an area Appropriate development susceptible to Potential to manage Site site in terms of Groundwater Groundwater groundwater flood risk Flooding? Flooding? Land East of Partially Area at risk peripheral to site. YES, but: Rayleigh Road, Therefore possible to avoid. a) Avoid development in Hadleigh Potential to create flood areas at risk of storage elsewhere on site. groundwater flooding b) Installation of flood storage on-site within areas away from susceptibility. Land at Brook No N/A YES Farm, Hadleigh Land south of No N/A YES Scrub Lane, Hadleigh

Land at Oak Partially Area at risk peripheral to site. YES, but: Tree Farm, Source control SUDS and a) Source control SUDS and Hadleigh drainage improvements drainage improvements required to manage required. interaction between surface b) Properties should be water and groundwater. designed to be resistant and resilient to groundwater flooding. No basement dwellings should be permitted. Hadleigh Island No N/A YES Site, Hadleigh Land north of No N/A YES Grasmere Road and Borrowdale Road Land at Yes – entire site Cannot avoid as entire site YES, but: Glebelands, is highly susceptible. a) Source control SUDS and Thundersley susceptible Source control SUDS and drainage improvements drainage improvements required. required to manage b) Properties should be interaction between surface designed to be resistant water and groundwater. and resilient to groundwater flooding. No basement dwellings should be permitted. Land at The No N/A YES Chase, Thundersley Land fronting No N/A YES Rayleigh Road, Thundersley Land at Thames No N/A YES Loose Leaf, Thundersley

Within an area Appropriate development susceptible to Potential to manage Site site in terms of Groundwater Groundwater groundwater flood risk Flooding? Flooding? Land east of No N/A YES Canvey Road, Canvey Island Land west of No N/A YES Canvey Road, Canvey Island Land at Thorney No N/A YES Bay, Canvey Island Land at The No N/A YES Point, Canvey Island Kings Park, No N/A YES Canvey Island 244-258 London No N/A YES Road, Hadleigh (Garston Block)

Conclusions

Table 8, below, summarises the findings of the sequential and exceptions test alongside the findings of the surface water and groundwater assessments. Colour-coding has been used to identify the extent of any flood risk issues within each of the separate assessments.

A flood risk preference ranking has then been applied, using the standard sequential test as a basis, and then using the findings of the surface water and groundwater assessments to distinguish between those sites within the Environment Agency Flood Risk Zones.

Table 8: Summary of Flood Risk Assessment Findings including Preference Ranking

Standard Flood Risk Exceptions Surface Site Sequential Groundwater Preference Test Water Test Ranking Land west of Zone 1 – low N/A Risk identified No risk 2 Benfleet, risk but on-site identified Benfleet avoidance possible Land between Zone 1 – low N/A Risk identified No risk 2 Felstead risk but on-site identified Road and avoidance Catherine possible. Road, Benfleet Land off Zone 1 – low N/A Risk identified No risk 2 Glyders, risk but on-site identified Benfleet avoidance possible. Former Mainly Zone 3 Risk identified No risk 6 WRVS Hall, (93%) – high but on-site identified Richmond risk avoidance Avenue, Partial Zone 2 Passes possible. Benfleet (5%) – exceptions medium risk test. Partial Zone 1 (2%) – low risk Land east of Zone 1 – low N/A Risk identified Risk identified 3 Rayleigh risk but on-site but on-site Road, avoidance avoidance Hadleigh possible. possible. Land at Brook Zone 1 – low N/A Risk identified No risk 2 Farm, risk but on-site identified Hadleigh avoidance possible. Land south of Zone 1 – low N/A Risk identified No risk 2 Scrub Lane, risk but on-site identified Hadleigh avoidance possible.

Standard Flood Risk Exceptions Surface Site Sequential Groundwater Preference Test Water Test Ranking Land at Oak Mainly Zone 1 Passes Risk identified Risk identified 4 Tree Farm, (90%) – low exceptions but on-site but on-site Hadleigh risk test. avoidance avoidance Partial Zone 2 possible. possible. (3%) – medium risk Partial Zone 3a (7%) – high risk Hadleigh Zone 1 – low N/A No risk No risk 1 Island Site, risk identified identified Hadleigh Land north of Zone 1 – low Risk identified No risk 2 Grasmere risk but on-site identified Road and avoidance Borrowdale possible. Road Land West of Zone 1 – low N/A Risk identified Risk identified 4 Glebelands, risk but on-site and on-site Thundersley avoidance and mitigation possible. required. Land at The Zone 1 – low N/A Risk identified No risk 2 Chase, risk but on-site identified Thundersley avoidance possible. Land fronting Zone 1 – low N/A Risk identified No risk 2 Rayleigh risk but on-site identified Road, avoidance Thundersley possible.

Land at Zone 1 – low N/A Risk identified No risk 2 Thames risk but on-site identified Loose Leaf, avoidance Thundersley possible. Land east of Zone 3 – high Passes No on-site No risk 5 Canvey Road, risk exceptions risk identified identified Canvey Island test. Land west of Zone 3 – high Passes No on-site No risk 5 Canvey Road, risk exceptions risk identified identified Canvey Island test. Land at Zone 3 – high Passes No on-site No risk 5 Thorney Bay, risk exceptions risk identified identified Canvey Island test. Land at The Zone 3 – high Passes No on-site No risk 5 Point, Canvey risk exceptions risk identified identified Island test. Kings Park, Zone 3 – high Passes Risk identified No risk 6 Canvey Island risk exceptions but on-site identified test. avoidance possible.

Standard Flood Risk Exceptions Surface Site Sequential Groundwater Preference Test Water Test Ranking 244-258 Zone 1 – low N/A No on-site No risk 1 London Road, risk risk identified identified Hadleigh (Garston Block)

Table 9, below, summarises the capacity of each preference ranking group to accommodate growth. There is good capacity within sites with limited flood risk issues to accommodate growth. However, it is not possible to meet the entire housing need in low preference groups.

Table 9: Capacity of Preference Ranking Groups

Preference Ranking Group Capacity 1 102 2 1,589 (plus a residential care home) 3 455 4 220 5 786 net (plus a residential care home) 6 89

The following conclusions have emerged from this sequential and exception test and assessment of flood risk from other sources:

1) Based on the OAHN of 353 homes per annum, there are not sufficient deliverable housing sites within Flood Risk Zone 1 in Castle Point and additional sites located within Flood Risk Zone 3a have therefore been appropriately identified. 2) During the remainder of the plan period there are not sufficient developable sites within flood risk zone 1 to meet the OAHN, therefore sites within Flood Risk Zones 2 and 3a have been appropriately identified. 3) The exception test has been carried out for all sites in Flood Risk Zone 3a to show their relative merits. The Exception Test indicated that all sites presented bring about wider sustainability benefits to the community, would be able to remain safe over their lifetime through the design of development to be flood resistant and resilient, and also through the implementation of the Thames Estuary 2100 Plan. 4) In terms of surface water, risks can largely be avoided through the installation of sustainable urban drainage techniques which prevent an increase in flood risk both within the site and to properties nearby. There are however three sites in Flood Risk Zone 1, where efforts will need to be made to avoid flood risk through the location of development within the site. 5) In terms of groundwater, there are only three sites which are susceptible to groundwater flooding. It is possible to avoid risk on two of these sites through the location of development within the site or design. The remaining site, located within Flood Risk Zone 1, is susceptible to groundwater flooding across the entire site and requires mitigation and flood resistant and resilient design to go ahead.