Avonmouth Docks, Bristol
Flood Risk Sequential Test
For
Clayewater Group
Project Number:
13556
December 2020
Campbell Reith Hill LLP No. 1 Marsden House Manchester M2 1HW
T: +44(0)1161 819 3060 E: [email protected] W: www.campbellreith.com Avonmouth Docks, Bristol Flood Risk Sequential Test
Document History and Status
Revision Date Purpose/Status File Ref Author Check Review
P1 16/12/20 For Planning 13556 MB EH RBG
This document has been prepared in accordance with the scope of Campbell Reith Hill LLP’s (CampbellReith) appointment with its client and is subject to the terms of the appointment. It is addressed to and for the sole use and reliance of CampbellReith’s client. CampbellReith accepts no liability for any use of this document other than by its client and only for the purposes, stated in the document, for which it was prepared and provided. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of Campbell Reith Hill LLP. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document are not to be construed as providing legal, business or tax advice or opinion.
© Campbell Reith Hill LLP 2020
Document Details
Last saved 16/12/2020 11:24
Path 13556-CRH-ZZ-XX-RP-C-0001-P1_Sequential Test.docx
Author Matthew Bailey
Project Partner Chris Brady
Project Number 13556
Project Name Avonmouth Docks, Bristol
Structural Civil Environmental Geotechnical Transportation
13556-CRH-ZZ-XX-RP-C-0001_P1 i Avonmouth Docks, Bristol Flood Risk Sequential Test
Contents 1.0 EXECUTIVE SUMMARY ...... 1 2.0 INTRODUCTION ...... 2 3.0 SITE CONTEXT ...... 3 Site Location ...... 3 Site Characterisation ...... 4 Site Topography ...... 4 Existing Flood Zone Classification ...... 4 4.0 PLANNING POLICY ...... 6 National Planning Policy Framework ...... 6 Local Planning Policy ...... 6 5.0 METHODOLOGY ...... 11 Overview of Study Area ...... 11 Proposed Development Site ...... 11 Comparable Site Selection Methodology ...... 11 Sequential Assessment ...... 12 6.0 SUMMARY & RESULTS ...... 13
Appendices Appendix 1: Site Location Plan (Drawing no. 13556-CRH-XX-XX-FG-G-7000-P1) and Proposed Site Plan (Drawing no. 5592-1) Appendix 2: Topographic Survey (Drawing no. 661/5592/1) Appendix 3: Correspondence with Bristol City Council Appendix 4: Rightmove and Zoopla Property Search Results
Figures Figure 3.1: Site Location Plan (not to scale) ...... 3 Figure 3.2: EA Flood Map for Planning (not to scale) ...... 5 Figure 4.1: Avonmouth Village Regeneration Area extent (not to scale). Bristol Ward Map taken from Bristol City Council’s ‘Avonmouth & Lawrence Weston Statistical Ward Profile 2020’...... 9
13556-CRH-ZZ-XX-RP-C-0001_P1 ii Avonmouth Docks, Bristol Flood Risk Sequential Test
1.0 EXECUTIVE SUMMARY
1.1.1. The Site located off Gloucester Road, Avonmouth, Bristol, extends to approximately 0.3ha in area and is proposed to be redeveloped for residential end use for up to 28 units.
1.1.2. A review of Environment Agency Flood Map for Planning showed the Site to lie entirely within Flood Zone 2 with a medium risk of fluvial flooding. In accordance with the NPPF, new developments should be steered towards areas with the lowest risk of flooding (preferably Flood Zone 1), unless there are no reasonable available sites. Therefore, a Sequential Test was required to confirm if there were any potential sites with a lesser risk of flooding than the proposed development Site.
1.1.3. As such CampbellReith, consulted with the Local Planning Authority, Bristol City Council, to agree a methodology for the search criteria for locating potential sites within the Council’s region of authority.
1.1.4. Following consultation with Bristol City Council and from a review of their Flood Risk Sequential Test Practice Note, the search for comparable sites was limited to the Avonmouth Village regeneration area. The Council’s Strategic Housing Land Availability Assessment document and two online property agents were used to identify available comparable sites within the defined search area.
1.1.5. Using the methodology informed by consultation with Bristol City Council, at the time of writing this report, no available sites were identified in the SHLAA within the Avonmouth Village regeneration area.
1.1.6. An online property search was also conducted within the search area, returning a total of 12 available sites to purchase. All of the available sites within the search area were considered not to be comparable, on the basis that they are too small to accommodate the requirements of the proposed development (28 residential units).
1.1.7. It is therefore considered that the proposed residential development, located at the Site off Gloucester Road, passes the Sequential Test as defined in the National Planning Policy Framework.
13556-CRH-ZZ-XX-RP-C-0001_P1 1 Avonmouth Docks, Bristol Flood Risk Sequential Test
2.0 INTRODUCTION
2.1.1. CampbellReith was appointed by Dewar Planning Associates, on behalf of their client Clayewater Group, to produce a Flood Risk Sequential Test in support of a forthcoming full Planning Application.
2.1.2. The proposed development is located Off Gloucester Road, Avonmouth, Bristol, BS11 9AQ. The Site proposed for development is approximately 0.3 hectares (ha) in area and is currently utilised as a depot for truck part supplier, comprising of a hardstanding service yard and office building.
2.1.3. The proposed development is to consist of the construction of three residential apartment buildings, totalling 28 units, with associated car parking and landscaping.
2.1.4. The entire Site is located within Flood Zone 2. It is anticipated that the risk of flooding is associated with the Swash Channel and Mouth of the Severn, located approximately 450m to the southwest and 1.5km to the west, respectively.
2.1.5. As the proposed development is to be residential, located entirely within Flood Zone 2, a Sequential Test is required in line with the National Planning Policy Framework. The aim of the sequential test is to determine if there are any comparable sites in the immediate area that could be considered to be a more suitable location for development, outside of an area at risk of flooding.
2.1.6. A Site location plan (Drawing no. 13556-CRH-XX-XX-FG-G-7000) and proposed Site layout (Drawing no. 5592-1), provided by the Client, have been presented within Appendix 1.
2.1.7. Bristol City Council has been consulted throughout the production of this assessment.
13556-CRH-ZZ-XX-RP-C-0001_P1 2 Avonmouth Docks, Bristol Flood Risk Sequential Test
3.0 SITE CONTEXT
Site Location
3.1.1. The Site is located of Gloucester Road, Avonmouth, Bristol, BS11 9AQ at National Grid Reference X: 351447 Y: 178082, which is approximately 9km to the northwest of Bristol City.
Figure 3.1: Site Location Plan (not to scale)
13556-CRH-ZZ-XX-RP-C-0001_P1 3 Avonmouth Docks, Bristol Flood Risk Sequential Test
Site Characterisation
3.2.1. The Site extends to approximately 0.3ha. It is currently utilised as a depot for truck part supplier, comprising of a hardstanding service yard and office building. The Site is bound by Gloucester Road to the north, commercial development to the east and west, and green open space to the south.
3.2.2. The Site can be accessed at the north Site boundary, from Gloucester Road.
3.2.3. There is a number of watercourses or waterbodies located in the surrounding area. Avonmouth Dock is located approximately 150m to the southwest of the Site, the Swash Channel approximately 500m to the southwest, Royal Edward Dock approximately 550m to the northwest, and the Mouth of the Severn approximately 1.5km to the west of the Site.
Site Topography
3.3.1. A topographic survey for the Site, conducted by Anthony Brookers Surveys Ltd in August 2009 (Drawing no. 661/5592/1), was provided by the Client and has been presented within Appendix 2.
3.3.2. It should be noted that since that topographic survey was conducted, the central building (Bristol Harbour Centre) within the Site has been demolished. Therefore, the topographic survey is not entirely representative of the current conditions onsite, however, the levels taken for the general ground level, outside of the demolished building’s footprint, should still be reasonably accurate.
3.3.3. The topographic survey indicates that the Site is reasonably flat, with fall in levels of approximately 0.7m from the west to east Site boundaries.
Existing Flood Zone Classification
3.4.1. The Environment Agency (EA) Flood Map for Planning indicates that the entire Site lies within Flood Zone 2 – defined as land having between a 1 in 100 and 1 in 1000 annual probability of coastal or river flooding.
3.4.2. The Site currently has no flood defences installed, however the EA Flood Map indicates that some parts of the surrounding area are benefiting from existing flood defences.
13556-CRH-ZZ-XX-RP-C-0001_P1 4 Avonmouth Docks, Bristol Flood Risk Sequential Test
Figure 3.2: EA Flood Map for Planning (not to scale)
13556-CRH-ZZ-XX-RP-C-0001_P1 5 Avonmouth Docks, Bristol Flood Risk Sequential Test
4.0 PLANNING POLICY
National Planning Policy Framework
4.1.1. The National Planning Policy Framework1 (NPPF) was published on 20th March 2012 and last updated on 29th June 2019. The NPPF sets out the government’s planning policies for England and how these are expected to be applied, superseding the previous guidance; Planning Policy Statement 25 (PPS25): Development and Flood Risk.
4.1.2. The NPPF guidance specific to flood risk and coastal change2 was published on 6th March 2014 and advises how to take account of and address the risks associated with flooding and coastal change in the planning process. The NPPF outlines that the aim of the Sequential Test is to steer new developments to areas with the lowest probability of flooding.
Local Planning Policy
Bristol Avon Catchment Flood Management Plan
4.2.1. Catchment Flood Management Plans (CFMPs) are not specifically required by the Water Framework Directive and are prepared voluntarily by the EA (under Government supervision). A CFMP is a high-level plan for an area which aims to develop policies to manage flood risk over the next 50 to 100 years. These policies take into account the likely impacts of climate change and the effects of land-use and land management, and identify a range of benefits which contribute towards sustainable development. The CFMP’s policies establish whether action should be taken to increase, decrease or maintain the current level of flood risk.
4.2.2. The Bristol Avon CFMP3, produced by the EA in June 2012, divides the catchment into 10 distinct ‘sub-areas’ based on similar levels of flood risk and physical characteristics. The Site falls within the ‘Markham Brook and Avonmouth’ sub-area.
4.2.3. An estimated 60 properties, mainly residential, are currently at risk of flooding during a 1 in 100 annual probability event, though these are protected from flooding by existing defences. This number is expected to increase to 120 properties in the future due to climate change. To manage flood risk within each sub-area, the EA apply one of their six standard policies. The Markham Brook and Avonmouth sub-area is subject to policy 4:
“Areas of low, moderate or high flood risk where we are already managing the flood risk effectively but where we may need to take further actions to keep pace with climate change.
This policy will tend to be applied where the risks are currently deemed to be appropriately- managed, but where the risk of flooding is expected to significantly rise in the future. In this case we would need to do more in the future to contain what would otherwise be increasing risk. Taking further action to reduce risk will require further appraisal to assess whether there are socially and environmentally sustainable, technically viable and economically justified options.”
1 UK Government’s National Planning Policy Framework – Available from: https://www.gov.uk/government/publications/national- planning-policy-framework--2 2 UK Government’s NPPF Guidance: Flood Risk and Coastal Change – Available from: https://www.gov.uk/guidance/flood-risk-and- coastal-change 3 EA Bristol Avon CMFP – Available from: https://www.gov.uk/government/publications/bristol-avon-catchment-flood-management- plan
13556-CRH-ZZ-XX-RP-C-0001_P1 6 Avonmouth Docks, Bristol Flood Risk Sequential Test
4.2.4. The CFMP identifies the proposed actions aimed at achieving Policy 4, which are as follows:
Review emergency contingency planning, especially in the light of climate change.
Increase awareness of risk and response to flood warnings.
Discourage inappropriate development.
Encourage the production of surface water management plans for Pill and Shirehampton.
Consider future improvements for Pill pumping station.
Bristol City Council’s Development Framework – Core Strategy (Adopted June 2011)
4.2.5. The Bristol City Council Core Strategy was adopted in June 2011 and sets out the Council’s long- term strategy for future development within the area for the next 15 to 20 year after the adoption of the plan.
4.2.6. The Local Plan highlights the need to manage flood risk from all sources, especially from new development. The policy specific to flood risk and water management ‘Policy BCS16’ is as follows:
“Development in Bristol will follow a sequential approach to flood risk management, giving priority to the development of sites with the lowest risk of flooding. The development of sites with a sequentially greater risk of flooding will be considered where essential regeneration or where necessary to meet the development requirements of the city.
Development in areas at risk of flooding will be expected to:
Be resilient to flooding through design and layout, and/or
Incorporate sensitively designed mitigation measures, which may take the form of on-site flood defence works and/or a contribution towards or a commitment to undertake such off- site measures as may be necessary
In order to ensure that the development remains safe from flooding over its lifetime.
All development will also be expected to incorporate water management measures to reduce surface water run-off and ensure that it does not increase flood risks elsewhere. This should include the use of sustainable drainage systems (SUDS).”
Bristol City Council’s Development Framework – Strategic Housing Land Availability Assessment (2009)
4.2.7. The Strategic Housing Land Availability Assessment (SHLAA) was published in 2009 and forms part of the evidence base used to support the delivery of the Bristol Development Framework Core Strategy. This document aims to identify as many of the potentially developable housing sites in Bristol as possible. Developable sites within the assessment are defined as sites that are considered to be in a suitable location for housing development, and have a reasonable prospect of being developed before 2026.
4.2.8. The SHLAA identifies 101 potentially developable sites within the Bristol City Council Local Authority area, five of which are located within the Avonmouth and Laurence Weston Ward.
13556-CRH-ZZ-XX-RP-C-0001_P1 7 Avonmouth Docks, Bristol Flood Risk Sequential Test
Bristol City Council’s Flood Risk Sequential Test – Practice Note (2013)
4.2.9. The Flood Risk Sequential Test Practice Note was published in August 2013 and provides guidance on how the Sequential Test will be applied through the development management process in Bristol.
4.2.10. The Practice Note provides guidance on defining the required search area of a Sequential Test specific to proposed development sites. The guidance for defining the search area within the Practice Note is stated as follows:
“As set out in the PPS25 Practice Guide (Paras.4.17-4.18), the area of search for alternative sites will normally be the whole local authority area. However, Bristol contains a number of areas in need of regeneration in which it would be appropriate to carry out the Sequential Test over a smaller area. Development in the following areas will not be expected to look for alternative sites in other parts of the city as part of the Sequential Test:
Bristol City Centre, as defined in the emerging Central Area Plan, or, within the city centre, the regeneration areas of:
o Bristol Temple Quarter; o Bristol Shopping Quarter; o Newfoundland Way; o Nelson Street and Lewins Mead; o Redcliffe Way; o North Redcliffe; o Central Harbourside; and o Cumberland Basin. These regeneration areas reflect the areas identified by policy BCS2 of the Core Strategy as areas of focus for development and regeneration, city centre gateways in need of improvement or extensions to the city centre. South Bristol, defined as all wards south of the River Avon, or, within South Bristol, the regeneration area of:
o Knowle West, as defined by the Knowle West Regeneration Framework. Inner East Bristol, defined as those parts of Ashley, Easton and Lawrence Hill wards that are outside of the city centre. The Northern Arc, defined as the wards of Lockleaze, Henbury, Southmead, Knigsweston and Horfield and the part of the Avonmouth ward generally corresponding to the residential and mixed-use areas east of the A4. Avonmouth Village, defined broadly as the residential and mixed-use part of the Avonmouth ward west of the A4.
An alternative area of search may be acceptable where it can be demonstrated with evidence that there is a specific need for the proposed development in that area that cannot be met elsewhere.”
13556-CRH-ZZ-XX-RP-C-0001_P1 8 Avonmouth Docks, Bristol Flood Risk Sequential Test
4.2.11. The poposed development Site falls within the ‘Avonmouth Village regeneration area’. Figure 4.1 highlights the extent of the Avonmouth Village regeneration area within the wider Avonmouth and Lawrence Western Ward.
Figure 4.1: Avonmouth Village Regeneration Area extent (not to scale). Bristol Ward Map taken from Bristol City Council’s ‘Avonmouth & Lawrence Weston Statistical Ward Profile 20204’.
4 Bristol City Council’s Avonmouth & Lawrence Weston Statistical Ward Profile 2020, May 2020 – Available from: https://www.bristol.gov.uk/statistics-census-information/new-wards-data-profiles
13556-CRH-ZZ-XX-RP-C-0001_P1 9 Avonmouth Docks, Bristol Flood Risk Sequential Test
4.2.12. The Practice Note also provides guidance on whether alternative sites identified are classified as ‘reasonably available’, stating:
“A development proposal will only fail to pass the Sequential test if alternative sites are identified within the search area that are at a lower risk of flooding, would be appropriate for the proposed development and are ‘reasonably available’ for development. A site is only considered to be reasonably available if it is both ‘deliverable’ and ‘developable’ as defined by the NPPF (Para.47, footnotes 11-12).
Additionally, a site is only considered to be reasonably available if all of the following apply:
The site is within the agreed area of search.
The site is of comparable size and can accommodate the requirements of the proposed development.
The site is either:
o Owned by the applicant;
o For sale at a fair market value; or
o Is publically owned land that has been formally declared to be surplus and is available for purchase.
The site is not safeguarded in the Local Plan for another use.
Sites are not considered to be reasonably available if they fail to meet any of the above requirements or already have planning permission for a development that is likely to be implemented.”
13556-CRH-ZZ-XX-RP-C-0001_P1 10 Avonmouth Docks, Bristol Flood Risk Sequential Test
5.0 METHODOLOGY
Overview of Study Area
5.1.1. Avonmouth is a ward located in the extreme northwest region of Bristol. Kingsweston boarders Avonmouth to the east and is the only other ward within Bristol to boarder Avonmouth.
5.1.2. The Site lies within the Avonmouth Village regeneration area, which is described in the Bristol City Council’s Flood Risk Sequential Test Practice Note as the area defined broadly as the residential and mixed-use part of the Avonmouth ward west of the A4.
Proposed Development Site
5.2.1. The Site, located off Gloucester Road, extends to approximately 0.3ha in area and is proposed to be redeveloped for residential end use for three apartment builds, up to 28 units, with associated car parking and landscaping.
Comparable Site Selection Methodology
5.3.1. When determining which Sites may be considered as comparable to the proposed development Site, Bristol City Council’s Flood Risk Sequential Test Practice Note was reviewed to assist in the initial selection of the comparable Site search radius.
5.3.2. The Bristol City Council’s Flood Risk Sequential Test Practice Note states the following:
“The area of search for alternative sites will normally be the whole local authority area. However, Bristol contains a number of areas in need of regeneration in which it would be appropriate to carry out the Sequential Test over a smaller area. Development in the following areas will not be expected to look for alternative sites in other parts of the city as part of a Sequential Test:
…
Avonmouth Village, defined broadly as the residential and mixed-use part of the Avonmouth ward west of the A4.”
5.3.3. The Practice Note also advises that for major proposals of 10 or more dwellings, alternative sites can be identified from the council’s emerging Local Plan documents and the evidence produced to support them, particularly the SHLAA.
5.3.4. Therefore, for an initial search area for comparable Sites, the Bristol City Council’s SHLAA was reviewed and only the sites identified within the Avonmouth Village area were considered for comparison under this Sequential Test. The extent of both the Avonmouth Village and the wider Avonmouth and Lawrence Weston Ward areas are shown on Figure 4.1.
5.3.5. Whilst five potential sites were identified within the Avonmouth and Lawrence Weston Ward within the SHLAA, none of these sites were identified to be located within the Avonmouth Village regeneration area. As such, CampbellReith consulted with Bristol City Council stating that as the search within the Avonmouth Village regeneration area did not identify any comparable sites, the proposed development should therefore pass the Sequential Test.
5.3.6. Following consultation, Bristol City Council recommended that, as the SHLAA was produced in 2009, it would be worth contacting property agents to ascertain whether there are any alternative sites that could be considered. A contact within the Council’s Housing Specialist Team was
13556-CRH-ZZ-XX-RP-C-0001_P1 11 Avonmouth Docks, Bristol Flood Risk Sequential Test
provided who may provide information on any site’s within the Avonmouth Village area that may be due to be included in an upcoming new version of the SHLAA.
5.3.7. The contact within Bristol City Council’s Housing Specialist team was contacted twice (on 23rd November 2020 and 9th December 2020) in an attempt to receive any advice on additional upcoming comparable sites that would be relevant for be assessed as part of this Sequential Test. As of the writing of this report, no response has been received. All correspondence between CampbellReith and Bristol City Council has been provided within Appendix 3.
5.3.8. Following advice from Bristol City Council to contact property agents as part of the comparable site search, two online property agent websites were used to make a search of available properties and land within the Avonmouth Village Area. The two property agent websites used for the additional search were Rightmove5 and Zoopla6.
5.3.9. To keep the search area within the Avonmouth Village regeneration area, a ½ mile search radius was used from the postcode of the proposed development Site (BS11 9AQ).
5.3.10. Following the online search, eight potential results were identified using Rightmove and four potential results from Zoopla.
Sequential Assessment
5.4.1. An assessment was made to determine if any of identified potential sites are classed as ‘readily available’ under the requirements set out within the Bristol City Council’s Sequential Test Practice Note. The requirements for a site to be classified as ‘readily available’ has been provided within paragraph 4.2.12. of this report.
5.4.2. Of the 12 potential sites identified from the online property agent search none of the sites were considered to be ‘readily available’, on the basis that none of the sites can accommodate the requirements of the proposed development (28 residential units).
5.4.3. All of the available properties within the online Avonmouth Village area were single building houses or flats available to buy. No land was available to purchase with the search area at the time of writing this report.
5.4.4. The results from the online property search as of the writing of this report have been provided within Appendix 4.
5 Rightmove website: https://www.rightmove.co.uk/ 6 Zoopla website: https://www.zoopla.co.uk/
13556-CRH-ZZ-XX-RP-C-0001_P1 12 Avonmouth Docks, Bristol Flood Risk Sequential Test
6.0 SUMMARY & RESULTS
6.1.1. The Site located off Gloucester Road, Avonmouth, Bristol, extends to approximately 0.3ha in area and is proposed to be redeveloped for residential end use for up to 28 units.
6.1.2. A review of Environment Agency Flood Map for Planning showed the Site to lie entirely within Flood Zone 2 with a medium risk of fluvial flooding. In accordance with the NPPF, new developments should be steered towards areas with the lowest risk of flooding (preferably Flood Zone 1), unless there are no reasonable available sites. Therefore, a Sequential Test was required to confirm if there were any potential sites with a lesser risk of flooding than the proposed development Site.
6.1.3. As such CampbellReith, consulted with the Local Planning Authority, Bristol City Council, to agree a methodology for the search criteria for locating potential sites within the Council’s region of authority.
6.1.4. Following consultation with Bristol City Council and from a review of their Flood Risk Sequential Test Practice Note, the search for comparable sites was limited to the Avonmouth Village regeneration area. The Council’s Strategic Housing Land Availability Assessment document and two online property agents were used to identify available comparable sites within the defined search area.
6.1.5. Using the methodology informed by consultation with Bristol City Council, at the time of writing this report, no available sites were identified in the SHLAA within the Avonmouth Village regeneration area.
6.1.6. An online property search was also conducted within the search area, returning a total of 12 available sites to purchase. All of the available sites within the search area were considered not to be comparable, on the basis that they are too small to accommodate the requirements of the proposed development (28 residential units).
6.1.7. It is therefore considered that the proposed residential development, located at the Site off Gloucester Road, passes the Sequential Test as defined in the National Planning Policy Framework.
13556-CRH-ZZ-XX-RP-C-0001_P1 13 Avonmouth Docks, Bristol Flood Risk Sequential Test
Appendix 1: Site Location Plan (Drawing no. 13556-CRH-XX-XX-FG-G-7000-P1) and Proposed Site Plan (Drawing no. 5592-1)
13556-CRH-ZZ-XX-RP-C-0001_P1 Appendix © Campbell Reith Hill LLP 2020
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Appendix 2: Topographic Survey (Drawing no. 661/5592/1)
13556-CRH-ZZ-XX-RP-C-0001_P1 Appendix
Avonmouth Docks, Bristol Flood Risk Sequential Test
Appendix 3: Correspondence with Bristol City Council
13556-CRH-ZZ-XX-RP-C-0001_P1 Appendix Fw: Sequential Test Methodology - The Harbour Centre, Avonmouth Mark.Dowling, Development Matthew Bailey to: 09/12/2020 13:53 Management Cc: Elanna Herod
Hi Mark,
I've tried to reach you today on the phone but couldn't get through.
I was just contacting you to see if you had made any progress with the below query? Essentially are you aware of any new Sites that are going to be added to the upcoming new SHLAA that are located within the Avonmouth Village regeneration area?
If you'd like to call to discuss you can reach me on 07572878528.
Thanks
Matthew Bailey Graduate Civil Engineer
No. 1 Marsden Street Manchester M2 1HW
Tel: +44 (0)161 817 2395 www.campbellreith.com ----- Forwarded by Matthew Bailey/CRH on 09/12/2020 13:50 -----
From: Matthew Bailey/CRH To: [email protected] Cc: Elanna Herod/CRH@Campbellreith, "Susannah Pettit"
Hi Mark,
I've been given your details from the below email regarding a sequential test that I am conducting as part of a flood risk assessment.
I have had a look on two online property agents (Rightmove and Zoopla) for available sites for purchase within the Avonmouth Village regeneration area (1/2 mile radius from postcode of current proposed site) and I could not find any suitable and/or available sites that were comparable to our current proposed site.
The only available properties to purchase were existing single dwellings, and one plot of land was available on Zoopla that currently has approved planning permission for a two bedroom property and is therefore too small to be suitable for out proposed development of 35 units.
Are you aware of any other sites that might be available within the Avonmouth Village regeneration area that are due to be included in an updated SHLAA document? If so, can you please provide me with any details of ones that you may find comparable to a 0.3ha site with a proposed scheme of 35 residential units.
Kind regards,
Matthew Bailey Graduate Civil Engineer No. 1 Marsden Street Manchester M2 1HW
Tel: +44 (0)161 817 2395 www.campbellreith.com ----- Forwarded by Matthew Bailey/CRH on 23/11/2020 13:08 -----
From: "Susannah Pettit"
Dear Matthew
The sequential test should be submitted with the application (within the FRA) and it will be determined through that process. In terms of identifying sites, in view of the date of the SHLAA it would be worth contacting property agents as well to ascertain whether there are any alternative sites that should be considered. Mark Dowling (copied in to this email) may also be able to assist with any update on SHLAA or available sites, as he works in the Housing specialist team within DM and is now the case officer for this application.
All the best, Susannah
From: [email protected]
Hi Susannah,
Thank you for providing me with the BCC guidance on performing sequential tests.
I've had a read through the guidance and believe that our Site falls within the 'Avonmouth Village' regeneration area. As I understand, the sequential test search should therefore be limited to only the Avonmouth Village regeneration area.
As there are no alternative Sites highlighted in the BCC SHLAA within the Avonmouth Village regeneration area, our Site located at The Harbour Centre should therefore immediately pass the sequential test.
Can you please confirm that this is correct?
Kind regards. Matthew Bailey Graduate Civil Engineer
No. 1 Marsden Street Manchester M2 1HW
Tel: +44 (0)161 817 2395 www.campbellreith.com
From: "Susannah Pettit"
Dear Matthew
Please refer to BCC guidance on performing sequential tests: https://www.bristol.gov.uk/documents/20182/34524/Flood%20Risk%20Sequential%20Test%20Prac tice%20Note%20(August%202013).pdf/a46ef145-da9a-409d-bd42-105fc5bc6c81
Regards Susannah
From:[email protected]
Hi, We have been requested by our Client to provide a Sequential Assessment for a site located at The Harbour Centre, 100 Gloucester Road, Avonmouth, Bristol (BS11 9AQ) to support a forthcoming Detailed Planning Application. Previous planning applications for the site include 07/00557/P (outline) and 09/04258/M (reserved matters).
The Site is wholly located within the FZ2 and it is proposed to be redeveloped into a residential development with 35 units.
Based on the National Planning Policy Framework guidance for Flood Risk and Coastal Change, as the site is located within Flood Zone 2 and the development type is classed as 'more vulnerable', a sequential test is required but an exception test is not.
Below is described the methodology we are proposing for the required Sequential Assessment:
By using the Strategic Housing Land Availability Assessment 2009 (SHLAA) document available on the Bristol City Council website, we have determined comparable sites within a 6km radius from the site, and this has identified there are 8 sites listed within the SHLAA that we are to assess in terms of flood risk classification. We have determined the comparable sites based on the location (within 6km radius) and either a site capacity of 20 units - 50 units and/or site area of 0.1ha - 0.5ha.
Our comparison search only includes sites located within the Bristol City Council ward and therefore the Bristol City Council SHLAA. Therefore our search does not include any sites to the south within the North Somerset council ward.
I have attached the SHLAA extract with the identified sites highlighted in green.
Would you be able to confirm that the above principles are acceptable to Bristol City Council, so we can proceed with the Sequential Testing, please?
If any more information required regarding the site or the proposed methodology, please don't hesitate to contact me on 07572878528.
Many thanks,
Matthew Bailey Graduate Civil Engineer
No. 1 Marsden Street Manchester M2 1HW
Tel: +44 (0)161 817 2395 www.campbellreith.com
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13556-CRH-ZZ-XX-RP-C-0001_P1 Appendix
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