East Riding of Yorkshire Council Flood Risk Note for the Planning Application process
July 2011
East Riding of Yorkshire Council County Hall Beverley East Riding of Yorkshire HU17 9BA East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
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Introduction
1. This Note has been prepared to provide assistance to developers, applicants, and Local Planning Authority officers on how to use the Council’s Strategic Flood Risk Assessment and how to apply national planning policy Planning Policy Statement 25 (PPS25): Development and Flood Risk in the East Riding of Yorkshire. It aims to promote transparency and consistency in the approach East Riding of Yorkshire Council will take to applying the PPS25 flood risk Sequential and Exception Tests.
2. PPS25, published in December 2006 (most recently updated in March 2010), introduced a number of requirements for Local Planning Authorities, including: preparation of Strategic Flood Risk Assessments to inform local planning decisions and provide a starting point for site-specific Flood Risk Assessments application of a Sequential Test to planning applications to ensure that new development is located in areas at lowest flood risk as far as possible, and application of an Exception Test for certain applications where development is proposed in a flood risk area (e.g. where alternative sites are not available in a lower flood risk area), in order to demonstrate that the development is justified and can be made safe.
3. PPS25 also introduced a requirement for developers/applicants to prepare site-specific Flood Risk Assessments (FRAs) to be submitted with certain planning applications or applications over a certain size.
4. This Note deals with each of these aspects, set out on a step-by-step basis as follows:
1) Identifying the level of flood risk 2) Identifying when the PPS25 Sequential Test and/or Exception Test is required 3) Compiling information for the Sequential Test 4) Applying the PPS25 Exception Test 5) Applying a Sequential Approach to Site Layout and Design 6) Preparing Site-Specific Flood Risk Assessments
It is emphasised that this Note does not substitute PPS25 in any way, and that PPS25 policies will always take precedence over this Note. Nor does the Note cover how the PPS25 Tests could be undertaken in every conceivable scenario. It aims to cover the most common situations with the aim that it will be relevant and helpful in the majority of circumstances. If you are in doubt about any stage of the process, please contact the Council’s Development Management department (01482 393666).
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This Note focuses only on flood risk considerations in relation to planning applications. There are of course many other factors that determine a planning application, and it is not intended that this Note is prescriptive or prioritises flood risk over other planning considerations. Its purpose is to help case officers maintain a degree of consistency in applying professional judgement. Planning applications will continue to be determined on a case-by-case basis. The applicability of the Note will be reviewed regularly – should there be any changes relevant to flood risk considerations, case officers will need to take these into account.
It should also be noted that the approach taken to the PPS25 Tests, such as defining the appropriate area of search for alternative sites, will be re-visited once the Core Strategy document – the main document of the Council’s Local Development Framework - has been adopted. The Core Strategy will set a settlement hierarchy and define levels of development appropriate to each location, and may therefore have a significant impact on the approach to the Sequential Test. The approach taken in this document in no way pre-empts or prejudices the approach to be taken once the Core Strategy is in place.
4 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process The Flood Risk / PPS25 Process for Applicants – A Summary
Is the site of the proposed development at risk of flooding? (see Step 1)
YES NO (Proposal is in Flood Zone 2, 3a or 3b (Proposal is in Flood Zone 1 and not and/or at potential significant surface water potentially at significant surface water and/or groundwater risk) and/or groundwater risk)
Is the proposal’s vulnerability Is the site 1 ha or greater in size? classification compatible with the Flood Zone? (see Step 1 and Appendix 1)
YES NO YES NO
Undertake a site-specific No further Contact the Council Flood Risk action required Assessment (see Step 6)
Is the PPS25 Sequential Test required? (see Step 2) Submit planning application
YES NO
Does the Consider whether a Sequential Sequential Test Approach can be applied at the site identify an level (see Step 5) alternative site and at lower flood undertake a site-specific Flood Risk risk? (see Step 3) Assessment (see Step 6)
YES NO
Contact the Council: the Is the PPS25 application Exception Test may be required? contrary to (see Step 2) PPS25
YES NO
Assemble information for the Exception Test (see Step 4) 5 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
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The Flood Risk / PPS25 process
Step 1 - Identifying the level of flood risk
5. The first step in this process is to identify whether the location of the proposed development is classified as having a high, medium or low probability of flooding from a river(s) and/or the sea, as per Table 1, by (i) accessing the Environment Agency’s national Flood Map and (ii) accessing the Council’s Strategic Flood Risk Assessment (SFRA).
6. Applicants will then need to check that their proposal is compatible with the Flood Zone in accordance with the PPS25 Vulnerability Classifications (these are listed at Appendix 1 of this document). PPS25 specifies certain vulnerability classifications that should not be permitted in certain ‘Flood Zones’ (see Table 1).
Flood Description Developments that Zone should not be permitted 1 Low Probability: None Less than a 1 in 1000 chance of river/sea flooding per year. 2 Medium Probability: None Between a 1 in 100 and 1 in 1000 chance of river flooding per year or between a 1 in 200 and a 1 in 1000 chance of sea flooding per year. 3a High Probability: Highly Vulnerable Uses A 1 in 100 or greater chance of river flooding or a 1 in 200 or greater chance of sea flooding per year. 3b Functional Floodplain Highly Vulnerable Uses Land where water has to flow or be stored in More Vulnerable Uses times of flood. Less Vulnerable Uses Table 1: Flood Zones and developments that should not be permitted (Source: PPS25 Table D1)
7. It is recommended that the Environment Agency’s (EA) Flood Map is accessed before the Council’s SFRA, because the EA Flood Map represents the best available information on areas of High, Medium, and Low Probability of flooding, given that it is reviewed regularly. It is possible that there may be slight inconsistencies between the Flood Map and the Council’s SFRA maps, although this should only be in a minority of cases. If, having accessed the maps, applicants are unclear as to which Flood Zone their site lies within, they should contact the Council (see Appendix 6 – Useful Contacts).
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(i) Environment Agency Flood Map
8. The EA’s Flood Map can be accessed online at www.environment- agency.gov.uk. Applicants can identify which flood risk classification applies to their site by entering the site’s post code.
9. The areas of Medium Probability (Flood Zone 2) are shown in ‘light blue’ and those of High Probability (Flood Zone 3) in ‘dark blue’ . These combined areas represent the extent of the natural floodplain if there were no flood defences or certain other manmade structures and channel improvements. The remaining area (with no colour) is classified as Low Probability (Flood Zone 1). Note that the Flood Map does not split the High Probability area into Zones 3a and 3b – this is done by the Council’s SFRA.
(ii) East Riding of Yorkshire Strategic Flood Risk Assessment
10. The Council’s Strategic Flood Risk Assessment (SFRA) can be accessed online at http://www.eastriding.gov.uk/corp-docs/forwardplanning/html/sfra.html. This comprises a ‘Level 1’ SFRA, which covers the whole East Riding, and an additional ‘Level 2’ SFRA for Goole. The SFRAs contain information that is more detailed and locally specific than the national Flood Map. The Level 1 SFRA provides flood risk mapping for all sources of flooding (e.g. the sea, river(s), surface water and groundwater) as well as information on historic flooding incidents, flood warning areas, and local geology and topography. The Level 2 SFRA provides detailed mapping of modelled defence breaches and overtopping scenarios in Goole.
Tidal and Fluvial Flood Risk
11. The Level 1 SFRA splits the High Probability area (Flood Zone 3) into ‘tidally dominated’ and ‘fluvially dominated’ flood risk zones. The majority of flood risk in the East Riding is tidally dominated (i.e. a tidal flood would have a greater impact than a fluvial flood). The Level 1 and Level 2 SFRAs further sub-divide the ‘tidally dominated’ zone into sub-zones to indicate potential flood hazard and flood warning times in the event of defence failures along the Humber Estuary and River Ouse (i.e. ‘worst case’ scenarios). The Level 1 SFRA presents this information at Appendix A (on a series of 32 ‘Small Maps’ of the main towns and villages and 61 ‘Large Maps’ of the entire area - see Appendix 2 for a list of the relevant map numbers for the main East Riding settlements). The Level 2 SFRA presents this in Figures M and N.
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Zone 3a High Probability: Land assessed as having a 1 in 100 or greater chance of river flooding and/or a 1 in 200 or greater chance of sea flooding per year.
Fluvially dominated Zone 3a: Parts of Zone 3a where the predominant risk of flooding is from rivers rather than the sea.
Tidally dominated Zone 3a: Parts of Zone 3a where the predominant risk of flooding is from the sea rather than rivers. This zone has been further sub-delineated as follows:
Areas of hazard/immediate risk following a defence failure (breach): Danger to All Danger to Most Danger to Some
Areas that will receive a warning following a defence failure (breach) Estimated warning times: Less than 6 hours 6-12 hours 12+ hours
1 in 25 year if undefended: Parts of Zone 3a which have been assessed as having a 1 in 25 year chance of flooding per year from rivers if defences and/or artificial pumping activity is withdrawn.
Zone 3b Functional Floodplain: Land where water has to flow or be stored in times of flood. This has been defined using the ‘1 in 25 year’ flood outlines for the main rivers in the Authority area, and also includes dedicated washland areas that are retained specifically for flood storage purposes (e.g. along the River Aire).
Box 1: SFRA’s flood risk classifications for High Probability Zone 31 Note: For Goole, flood risk is tidally dominated therefore the Level 2 SFRA only depicts the ‘Tidally dominated Zone 3a’ classifications. Also, a ‘Rapid Inundation Zone’ is identified at a notional 20 metres from the defences.
12. Applicants should note that the Recommendations Table in the Level 1 and Level 2 SFRAs (reproduced at Appendix 4) suggests restricting certain uses and types of buildings in the flood hazard categories (Danger to All etc.). If a compatibility issue is identified with the SFRA, please contact the Development Management section.
13. Figure 1 is an example of one of the Level 1 SFRA Flood Zone Maps. Note that the Zone 3a hazard categories (’Danger to all’ etc) overlay the estimated warning times (<6 hours etc). Hence not all of the Flood Zone categories are necessarily visible on each SFRA map. For example, on the map below, the ‘less than 6
1 A more detailed description of how the Level 1 SFRA assesses flood risk is set out in the Level 1 SFRA (available on the Council’s website).
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hours’ category is not visible as it is overlain by the ‘Danger to All’, ‘Danger to Most’ and ‘Danger to Some’ categories (except on the ‘Estuary’ side of the defence line, which is shown as ‘less than 6 hours’ on all of the SFRA maps), nor does this map have any areas of Zone 3b Functional Floodplain.
Figure 1: SFRA example Flood Zone map (Appendix A)
‘Other’ sources of flooding
Surface water flood risk 14. The Level 1 SFRA identifies areas that are potentially most at risk of surface water flooding following a period of prolonged/heavy rainfall, based on an assessment of the area’s topography. It expresses these as ‘High’, ‘Medium’ or ‘Low’ potential hazard based on the likely runoff flowing through a site, and the likelihood (and depth) of local runoff ‘ponding’ within a site. This information is provided at Appendix C of the SFRA (with the same map references as the Appendix A maps) – see example at Figure 2.
Groundwater flood risk 15. Appendix I of the SFRA identifies areas, taken from a national ‘Groundwater Emergence Map, that may be susceptible to elevated groundwater levels (and thus result in groundwater flooding), again following a period of prolonged rainfall. The groundwater emergence zone in the East Riding largely coincides with the underlying chalk geology.
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Figure 2: SFRA example Surface Water Hazard map (Appendix C)
16. Because the methods used to assess these ’other’ sources of flooding in the SFRA are relatively ‘broad brush’, it is not intended that the areas identified should be interpreted as a definitive representation of surface water / groundwater risk zones. Rather, the SFRA recommends that these should be investigated further through a site-specific Flood Risk Assessment (Step 6). The Council may consider a surface water/groundwater risk to be significant if it is found that the site meets any of the following criteria: The site’s average gradient is greater than 1% (1 in 100), as this is likely to generate overland flow There is a ditch(es) adjacent to the site The groundwater level is high (e.g. likely to impede the natural soakage of rainwater)2 There is a large impervious area next to the site (e.g. more than 50% of an adjacent site is impervious, using a 50m band width from all boundaries of the site) There is a history of surface water and/or groundwater flooding on the site (e.g. in June 2007)3
17. Applicants should specify in their Flood Risk Assessment whether any of these criteria apply to their site and provide justification if they do not believe the surface water/groundwater risk to be ‘significant’. It is highlighted that these criteria are not intended to be exhaustive – other factors may also be relevant.
2 Examples in the East Riding where this may be the case include Cottingham and Dunswell, where groundwater is encountered at or above ground level. 3 Appendix D of the Level 1 SFRA shows “Indicative Areas of Flooding” in the East Riding during June 2007. The Council’s Land Drainage Department may be able to further provide information in relation to particular sites. It is emphasised however that the accuracy and completeness of this data cannot be guaranteed, and that the Council accepts no liability for any loss, damage or inconvenience caused as a result of reliance upon or use of this data.
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18. Once the level of flood risk (from all sources) has been established, proceed to Step 2.
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Step 2 - Identifying when the PPS25 Sequential Test and/or Exception Test is required
DEFINITIONS
SEQUENTIAL TEST
The Sequential Test is a planning tool that Councils apply to ensure that developments in areas at risk of flooding are only approved if the applicant can successfully demonstrate that there are no reasonably available alternative sites at a lower risk of flooding, and that the proposed uses are suitable in terms of their vulnerability (as specified in Table D2 of PPS25). PPS25 paragraph D5 provides the following description of the Sequential Test:
“The overall aim of decision-makers should be to steer new development to Flood Zone 1. Where there are no reasonably available sites in Flood Zone 1, decision-makers… determining applications for development at any particular location should take into account the flood risk vulnerability of land uses and consider reasonably available sites in Flood Zone 2, applying the Exception Test if required. Only where there are no reasonably available sites in Flood Zones 1 or 2 should decision-makers consider the suitability of sites in Flood Zone 3, taking into account the flood risk vulnerability of land uses and applying the Exception Test if required.”
EXCEPTION TEST
“For the Exception Test to be passed:
a) it must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a SFRA where one has been prepared. If the DPD has reached the ‘submission’ stage, the benefits of the development should contribute to the Core Strategy’s Sustainability Appraisal;
b) the development should be on developable, previously developed land or if it is not on previously developed land, that there are no reasonable alternative sites on previously developed land; and
c) a FRA must demonstrate that the development will be safe, without increasing flood risk elsewhere, and where possible, will reduce flood risk overall.” (Paragraph D9, PPS25)
Box 2 – Definitions for the Sequential Test and Exception Test (Source: PPS25)
19. PPS25 introduces two ‘Tests’ to manage development in respect to flood risk. The Sequential Test is required for the majority of development proposals in Flood Zones 2 and 3, and also for proposals in areas of ‘significant’ surface water and/or groundwater flooding4. For some proposals, a further Exception Test is required,
4 PPS25 (paragraph 16) requires a sequential approach to be applied to ‘other’ types of flood risk. See Step 2 for identifying ‘significant’ surface water and/or groundwater flood risk.
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as specified in Table 2 below (that is, if the Sequential Test has not been successful in identifying an alternative site in a lower flood risk category).
Flood Zone Exception Test is required for… 2 Highly Vulnerable Uses 3a Essential Infrastructure More Vulnerable Uses 3b Essential Infrastructure Table 2: Developments that require an Exception Test. Source: Table D1, PPS25 Note:Where a proposal involves a mixture of vulnerability classes, regardless of whether this mix varies horizontally or vertically (i.e. across a site or within the same building), developments will be placed into the higher of the relevant classes of flood risk sensitivity (in line with Note 2 of Table D2 of PPS25).
20. Hence, if the proposal is in Flood Zone 1, and is not affected by a ‘significant’ risk from surface water and/or groundwater flooding, a Sequential Test is not required. If the site is less than 1 hectare, no further action is required in respect to flood risk. However, if the site is 1 hectare or greater, applicants are required to produce a site-specific Flood Risk Assessment to accompany the planning application (see Step 6).
21. Assistance on how to apply the Sequential Test and Exception Test is provided in Steps 3 and 4 respectively. Finally, there are certain types of proposal that can be exempted from the Sequential and/or Exception Test, even if they are in Flood Zone 2 or 3 – these are listed in Table 3 below.
EXEMPTIONS FROM THE PPS25 SEQUENTIAL AND EXCEPTION TEST
Minor Development5: Minor development is defined in PPS25 (footnote 7) as: - Minor non–residential extensions and industrial/commercial/leisure extensions (etc) with a footprint less than 250 square metres. - Alterations: development that does not increase the size of buildings (e.g. alterations to external appearance); - ‘Householder’ development (e.g. sheds, garages, games rooms etc) within the curtilage of the existing dwelling - in addition to physical extensions to the existing dwelling itself.
Changes of use6: Changes of use that do not involve operational developments or changes of use to residential that would not result in an increased footprint (e.g. an extension).
5 From PPS25 paragraphs D15-D17 6 From PPS25 paragraphs D15-D17 and Practice Guide paragraphs 4.42-4.45
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Subdivision of Dwellings: Although the sub-division of houses into flats is specifically excluded from the definition of minor development, where no significant external alterations are required it would be viewed as a Change of Use application, and Change of Use applications are excluded from the Sequential and Exception Test. So the sub- division of a dwelling into two or more dwellings does not require a Sequential Test as long as it does not involve significant external alterations/extensions. Developments partially within Flood Zone 2 or 3: When development is proposed on a site where only a small part of the site lies within Flood Zone 2 or 3, the Sequential Test will not be required provided: The area of Flood Zone 2 and/or 3 will be used only for soft landscaping; AND Safe access and egress during flooding can be achieved without having to use the area of Flood Zone 2 and/or 3.
EXEMPTIONS FROM THE PPS25 SEQUENTIAL TEST ONLY
Redevelopment of existing properties7 (e.g. replacement dwellings):
Such proposals will not require a Sequential Test provided they: Will not be placed at an unacceptable level of flood risk, irrespective of the risk posed to the existing dwelling Do not increase the number of dwellings in an area of flood risk (i.e. replacing a single dwelling with an apartment block); and Do not increase the net footprint of the building(s)
The principles for replacement dwelling(s) will also be applied to new residential applications on sites that have existing unimplemented permissions (i.e. it is still valid), and for applications to renew existing residential permissions. For proposals on sites with lapsed permissions a Sequential Test will be required.
Note: If the Exception Test is applicable (e.g. the re-development is for a ‘More Vulnerable’/residential use in Flood Zone 3a), a pragmatic approach will be taken in respect to compliance with part ‘b’ of the Exception Test, on a case-by-case basis.
EXEMPTIONS FROM THE PPS25 SEQUENTIAL TEST AND PART OF THE EXCEPTION TEST Wind Turbines: Paragraph 4.39 of the PPS25 Practice Guide states that “…the PPS25 sequential test should not be applied to proposals for new wind turbines.” Note: applicants will still need to demonstrate that parts ‘a’ and ‘c’ of the Exception Test are passed – part ‘b’ is exempted because PPS22 states that LPAs should not give priority to the re-use of previously developed land for renewable energy technology developments8 Table 3 – Exemptions from the PPS25 Sequential and/or Exception Tests
If the Sequential Test is required, proceed to Step 3.
If the Sequential Test is not required but all or part of the Exception Test is, proceed to Step 4.
If neither the Sequential Test nor Exception Test is required, proceed to Step 6.
7 From paragraph 4.40 of the PPS25 Practice Guide 8 See paragraph 4.39 of the Practice Guide
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Step 3 - Compiling information for the Sequential Test
22. If a Sequential Test is applicable to the development proposal, applicants are required to assemble the relevant information with their planning application to enable the Council to assess whether the Sequential Test has been satisfactorily undertaken. The Council will need evidence of: (i) the area of search that has been used to assess alternative sites (ii) the alternative sites identified within the area of search, and (iii) assessment and explanation of whether alternative sites are at lower flood risk and are ‘reasonably available’
23. If the information does not adequately demonstrate that the proposal passes the Sequential Test, it is unlikely that the Council will approve the planning application, unless material considerations indicate otherwise.
(i) The area of search
24. The PPS25 Practice Guide advises that the geographical area over which to conduct a search of alternative sites should normally be applied to the whole local authority area, but that this can vary depending on local circumstances and also taking into account a development’s catchment.
25. The East Riding Authority area is very large (approximately 930 square miles), hence it is not expected that development proposals should be assessed against alternative sites throughout the entire Authority area. Rather, the area of search should be related to the type, scale, size, nature and character of the proposed development, and should be agreed with the Council (case officer) on a case-by-case basis. Examples of what the Council considers may be acceptable areas of search for the most common development types are detailed below.
Developments with a catchment
26. The Practice Guide suggests that some developments will have a specific, clearly- defined catchment which would justify a reduction in the search area for the Sequential Test. These development types may include the following: Schools Hospitals and doctors’ surgeries Fire/Ambulance Stations
27. In such circumstances, evidence must be assembled by the developer, drawing from bodies such as the Local Education Authority, Primary Care Trust or Emergency Services, to justify what the catchment area should be.
Development with a specific locational requirement
Extensions to existing businesses 28. Where a proposed development will be operationally linked to an existing business (including agriculture) the area of search could be that land within which the operational link can be maintained.
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29. Such proposals may include additional buildings or extensions to provide such things as an extension to a production line, a staff canteen, additional car parking, or goods storage. However, proposals for additional, separate uses will need to undertake a Sequential Test.
Note: Applicants will still need to demonstrate that the Exception Test is passed if applicable).
Large-scale storage and/or distribution 30. Where a development is proposed which relies on its proximity to the strategic transport network (such as motorways and rail routes) in order to function effectively, the area of search could be those areas within the Local Authority boundary which benefit from similar access to the strategic transport network.
31. The Joint Structure Plan for Hull and East Riding identifies a number of strategic employment areas (e.g. in saved policies EC1(d) EC2) for large-scale employment proposals. For instance, it identifies areas within the “East-West Multi-modal Freight Transport Corridor” (e.g. Junction 36 at Goole, Melton, and Priory Park) specifically for major manufacturing, storage and/or distribution purposes (i.e. uses that generate large freight movements). These sites are also of key importance in respect to their potential to make a significant contribution to regeneration needs at those locations. As such, the area of search for proposals at Junction 36 could be limited to that area, and proposals elsewhere within the corridor could be limited to other sites within this corridor.
Docks/Marinas/Wharves 32. Where a development is proposed which relies directly on its proximity to a deep- water estuarial channel such that it can function as, or link directly to, a dock, marina or wharf, the area of search could be defined by that area(s) within the Local Authority boundary which benefits from similar access to a deep-water channel.
33. This could apply for any development proposals at the Hedon Haven/Paull strategic site, which is in Flood Zone 3a, and is reserved specifically for uses that require access to the deep-water estuarial channel.
Areas requiring re-development or regeneration9 34. Where redevelopment is ongoing as part of an existing regeneration strategy in Flood Zones 2 or 3, it has to be accepted that the redevelopment cannot go anywhere else. In such circumstances the boundary of the identified Redevelopment/Regeneration area can be used for the area of search. This includes formally defined areas such as housing market renewal areas (e.g. Advance Goole) and areas benefiting from public funding in order to provide wholesale re-development.
Note: Applicants will still need to demonstrate that the Exception Test is passed (if applicable)
9 From paragraphs 4.36-4.38 of the Practice Guide
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Housing
35. The Yorkshire and Humber Plan (Regional Spatial Strategy (RSS)), adopted in May 2008, set an annual housing target for the East Riding of Yorkshire of 1,190 (gross) dwellings per annum. Although central government intends to revoke RSS, East Riding of Yorkshire Council’s Cabinet has resolved to maintain this figure in the short term until a new local target is established through the preparation of the Core Strategy.
36. This housing figure is currently distributed across four Sub Areas (see Figure 3) in accordance with the Hull and East Riding Joint Structure Plan (2005) and Interim Planning Policy on the Managed Release of Residential Development Sites (2003).
Figure 3: Joint Structure Plan Sub Areas
37. The Council’s agreed planning policy approach10 establishes that the Council will continue to treat Cottingham, Anlaby, Willerby, Kirk Ella and Hessle (with Hull) as fulfilling the role of a Regional City and Beverley, Bridlington, Driffield and Goole as fulfilling the role of Principal Towns (this approach is consistent with the recently published Preferred Approach Core Strategy, was accepted by the Council during the preparation of RSS and is backed up by the evidence base supporting the RSS). The approach to other settlements in the East Riding remains unaffected. Saved policy DS3 in the Joint Structure Plan (JSP) continues to identify a number of ‘Towns’11 and the approach to development in the Smaller Settlements continues to be as set out in
10 available on-line at: http://www.eastriding.gov.uk/public_reports/TheCabinet/07September2010/Agenda.pdf 11 Note that this now excludes Driffield, which was re-designated as a Principal Town in the RSS,
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the report to Cabinet on 28 April 200912. In the medium term a new settlement network will be established through the Core Strategy.
Haltemprice settlements (adjoining Hull) and Principal Towns 38. For residential development proposed within one of the Haltemprice settlements (that forms part of the Regional City) or a Principal Town, the search area for the Sequential Test could be limited to the same Haltemprice settlement or Principal Town.
39. The three Haltemprice ‘settlements’ are: Cottingham Anlaby/Willerby/Kirk Ella Hessle
40. The four Principal Towns are Beverley, Bridlington, Driffield, and Goole.
Towns 41. For ‘non-major’13 residential developments proposed within a Town (defined in JSP policy DS3), the search area for the Sequential Test could be limited to the same settlement. For ‘major’ developments14, the search area for the Sequential Test could be within any relevant Principal Towns and other Towns within the same JSP Sub- Area.
42. The Towns are Elloughton/Brough, Hedon, Hornsea, Howden, Market Weighton, Pocklington, Snaith and Withernsea.
Smaller Settlements 43. For residential developments of 5 or fewer dwellings proposed in any Smaller Settlement (under the provisions of JSP policy DS4 and as defined in the Council’s Position Statement on Housing Development in Rural Areas15), the Sequential Test search area could be limited to the same settlement. For developments of greater than 5 dwellings, the search area for the Sequential Test could be within any relevant Principal Towns, Towns, or other Smaller Settlements within the same JSP Sub-Area. If the proposal is for sole affordable housing however, intended to meet a specific need for affordable housing in a settlement, it may be appropriate to limit the search area to the same settlement.
Countryside (including very small settlements) 44. For residential developments in any other settlement or the open countryside, the search area could be within the same settlement, provided it accords with the Council’s Position Statement on Housing Development in Rural Areas16.
12 Available online at: http://www.eastriding.gov.uk/cs/planning-and-development-control/planning--development- control/housing-development-rural-areas/
13 Less than 10 dwellings or less than 0.5 hectares if the number of dwellings is not specified, but greater than householder (minor) development (defined in The Town and Country Planning (Development Management Procedure) (England) Order 2010 (DMPO)) 14 10 or more dwellings or 0.5 or more hectares if the number of dwellings is not specified (defined in The Town and Country Planning (Development Management Procedure) (England) Order 2010 (DMPO)) 15 Available online at: http://www.eastriding.gov.uk/cs/planning-and-development-control/planning--development- control/housing-development-rural-areas/ 16 Available online at: http://www.eastriding.gov.uk/cs/planning-and-development-control/planning--development- control/housing-development-rural-areas/
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Employment
45. For ‘major’17 employment proposals (developments within the B Use Classes) that do not have a specific locational requirement (see paragraphs 28 and 29), the search area could be the same JSP Sub-Area. For ‘non-major’18 employment proposals, this could be the same settlement (having regard to saved JSP and Local Plan policies with locational considerations for employment proposals). If the proposal is outside a settlement (e.g. in the countryside), applicants should contact the Council for advice on the appropriate search area (see Appendix 6 for contact information).
Retail/town centre uses
46. For retail proposals within defined retail areas, the applicants could search within the same retail area (e.g. Town Centre boundaries or other Local Plan retail designations), provided the proposal accords with saved JSP policy EC1 and PPS6. For proposals at ‘edge of town centre’ or ‘out of town centre’ locations, or in settlements without a defined retail area, the search area could be the catchment area that the development is intending to serve (i.e. the target catchment), having regard to the ‘sequential approach’ advocated in PPS6.
Mixed use developments
47. For mixed use proposals, applicants should consider whether the different uses could be disaggregated (and apply appropriate areas of search accordingly). Alternative sites capable of accommodating an equivalent mix of uses should also be looked at.
Other
48. For other types of proposal, applicants are advised to contact the Council when considering the area of search over which to apply the Sequential Test (see contact information at Appendix 6).
17 floorspace of 1000m2 or more or a site area of 1 hectare or more (defined in The Town and Country Planning (Development Management Procedure) (England) Order 2010 (DMPO)) 18 floorspace of less than 1000m2 or a site area less than 1 hectare(defined in The Town and Country Planning (Development Management Procedure) (England) Order 2010))
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(ii) Identifying ‘reasonably available’ alternative sites
49. The PPS25 Practice Guide suggests that ‘reasonably available alternative sites’ are those that meet the functional requirements of the proposed development, at a lower flood risk level (refer to Table 4 below). As such, the Council would expect applicants to consider sites that are capable of accommodating the proposed use or equivalent mix of uses, unless they would result in additional development costs (e.g. infrastructure) that would render the development unviable (and provided they are not contrary to other planning policies).
50. Alternative sites should not be dismissed simply on the basis that they are larger than the proposed site, or that they are smaller (as a series of smaller sites accommodating an equivalent quantum may also be considered). Nor should sites be dismissed because they would not generate the same sustainability benefits as the proposed site, and/or because they already have planning permission (but where development has not begun or is only partially complete). In regard to ownership, the Council does not consider the fact that an applicant personally has no alternative site within their ownership (at a lower flood risk level) to have a bearing on the application of the policies of PPS25.
51. To identify alternative sites, the PPS25 Practice Guide recommends that applicants refer to Local Authority assessments/monitoring reports of housing/employment land supply, and other relevant studies. A list of such documents / sources of information for the East Riding of Yorkshire is provided in Table 5. Applicants are also advised to undertake a Market Search, particularly if no or few reasonably available alternative sites are identified from these documents.
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Rankings (1=lowest Flood Risk Levels & 18=highest) Zone 1 Low Probability 1 Zone 2 Medium Probability 2 Zone 1 Low Probability + Significant Other Sources 3 Zone 2 Medium Probability + Significant Other Sources 4 Zone 3a High Probability - Fluvially Dominated 5= Zone 3a High Probability - Tidally Dominated 12+ hours warning 5= Zone 3a High Probability - Fluvially Dominated 6= + Significant Other Sources Zone 3a High Probability - Tidally Dominated 12+ hours warning 6= + Significant Other Sources Zone 3a High Probability - Tidally Dominated 6-12 hours warning 7 Zone 3a High Probability - Tidally Dominated 6-12 hours warning 8 + Significant Other Sources Zone 3a High Probability - Tidally Dominated Less than 6 hours warning 9 Zone 3a High Probability - Tidally Dominated Less than 6 hours warning 10 + Significant Other Sources Zone 3a High Probability - Tidally Dominated Danger to Some 11 Zone 3a High Probability - Tidally Dominated Danger to Some 12 + Significant Other Sources Zone 3a High Probability - Tidally Dominated Danger to Most 13 Zone 3a High Probability - Tidally Dominated Danger to Most 14 + Significant Other Sources Zone 3a High Probability - Tidally Dominated Danger to All 15 Zone 3a High Probability - Tidally Dominated Danger to All 16 + Significant Other Sources Zone 3b Functional floodplain 17 Zone 3b Functional floodplain + Significant Other Sources 18 Table 4 – Ranked Levels of Flood Risk Note: This Table represents the Council’s interpretation of how sites should be ranked using the SFRA flood zones and taking into account ‘significant’ risks from ‘other’ sources of flooding, in order to identify sequentially preferable sites for the Sequential Test process. It is highlighted that the SFRA does not assess flood hazard in Fluvially Dominated Zone 3a, therefore for sites located near to flood defences in this zone (e.g. parts of Beverley and Stamford Bridge) the site-specific Flood Risk Assessment will need to calculate the flood hazard19 of defence failure, and rank the risk level accordingly (e.g. on parity with Tidally Dominated Zone 3a rankings 11- 16).
19 Flood hazard is classified as ‘Danger to All’; ‘Danger to Most’; and ‘Danger to Some’. Refer to Guidance Note S3.2 Risks to people behind defences. Flood Risk Assessment Guidance for New Development Phase 2 R&D Technical Report FD2320 (Defra, 2005) for guidance on how to undertake this.
23 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
Housing
The Strategic Housing Land Availability Assessment (SHLAA) incorporating the Managed Release Interim Planning Guidance and Housing Land Position Statement (updated annually) identifies potential housing sites with a minimum size threshold of 0.25ha (or 5 dwellings), and indicates whether they are ‘developable’/’deliverable’ i.e. currently available and capable of being delivered within 5 years. The sites include unimplemented planning permissions, remaining Local Plan allocations, and also sites that have been submitted to the Council for consideration as potential future allocations within the next development plan (the Local Development Framework - Allocations Document). Many of the latter sites are currently contrary to Local Plan policy (e.g. in the open countryside - outside existing development limits) and thus should NOT be treated as reasonably available alternative sites for Sequential Test purposes.
This document also calculates the East Riding’s housing land supply position, assessing whether there is enough land to meet a 5-year supply of housing in each Joint Structure Plan Sub-Area. The document identifies sites that are to be ‘released’ if additional land is needed to maintain the 5-year supply position. This document can be accessed at: http://www.eastriding.gov.uk/corp-docs/forwardplanning/html/evidencebase.html
Employment The Employment Land Monitoring Report (updated annually) identifies all undeveloped and unoccupied sites over 0.1 ha in size, which either have an unimplemented planning permission or a Local Plan allocation for B1 (business), B2 (general industrial) or B8 (storage and distribution) uses. This can be accessed at: http://www.eastriding.gov.uk/corp-docs/forwardplanning/html/evidencebase.html
Also, the Industrial and Commercial Property Database, held by the Council’s Inward Investment Team (Tel: 01482 391612), contains information on available industrial and commercial property. Not all of these sites/premises should be treated as reasonably available alternatives however as they may be contrary to Local Plan policy.
Retail/town centre uses/other
There are no specific land use monitoring reports for retail or other types of development, but other sources of information published by the Council which may help to identify alternative sites include: Undeveloped site allocations in the existing Local Plans (http://www.eastriding.gov.uk/environment-and-planning/planning/forward- planning/local-plans/) National Land Use Database (NLUD) Survey of Previously Developed (Brownfield) Land (2010) (http://www.eastriding.gov.uk/corp- docs/forwardplanning/html/evidencebase.html) Town Centres and Retail Study (March 2009 and March 2010 update) (http://www.eastriding.gov.uk/corp-docs/forwardplanning/html/evidencebase.html)
Table 5 – Sources of information for identifying alternative sites
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Step 4 - Applying the PPS25 Exception Test
52. For some proposals the PPS25 Exception Test is applicable – either fully or in part (see Tables 2 and 3). The criteria of the Exception Test are: a) It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk; b) the development should be on developable, previously developed land or if it is not on previously developed land, that there are no reasonable alternative sites on previously developed land; and c) a FRA must demonstrate that the development will be safe, without increasing flood risk elsewhere, and where possible, will reduce flood risk overall.
53. The Environment Agency has advised that the logical order for applicants to work through the Exception Test is to start with part ‘c’, then part ‘a’, followed by part ‘b’. If applicants are not able to demonstrate that part ‘c’ can be met, there is no point in addressing the other parts of the Test, as it would be difficult to undertake part ‘a’ of the test without the level of information on flood risk provided by part ‘c’. The Exception Test must be addressed satisfactorily for the proposal to be considered acceptable, subject to other material considerations.
54. Part ‘c’ requires applicants to demonstrate through their site-specific Flood Risk Assessment (Step 6) that their proposed development can be made safe without increasing flood risk elsewhere, and where possible, will reduce flood risk overall. The Level 1 SFRA (and Level 2 SFRA for Goole) specifies a number of design measures to ensure that this part of the Test can be met (see Appendix 4). Appendix 5 provides a list of other useful documents that applicants may wish to refer to, on designing buildings in flood risk areas and preparing flood evacuation plans.
55. Part ‘a’ requires applicants to demonstrate evidence that will enable the Council to decide whether their proposal delivers wider sustainability benefits that outweigh the flood risk implications of developing the site. To do this, it is recommended (as per paragraph 4.48 of the PPS25 Practice Guide) that applicants refer to the Council’s Sustainability Appraisal Scoping Report for the Allocations DPD (May 2010)20 which contains a list of objectives against which the sustainability of that DPD will be assessed. These are listed at Appendix 3. Applicants can use these to inform their explanation of how their proposal will deliver wider sustainability benefits. The information contained in the Flood Risk Assessment should form an integral part of this process.
56. Part ‘b’ requires applicants to confirm that the proposed development is on previously developed (brownfield) land, or if it is not, that there are no reasonably alternative previously developed sites. In most cases (e.g. where the Sequential Test has been undertaken), applicants will have already searched for alternative sites. There may be instances however, in the case of greenfield sites, where a brownfield site(s) has been discounted during the Sequential Test process on the basis that it is
20http://www.eastriding.gov.uk/environment-and-planning/planning/forward-planning/local-development- framework/allocations-dpd/
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at the same level of flood risk as the greenfield site. If this is the case, it may be necessary to substitute the brownfield site for the greenfield site in order to satisfy the Exception Test. See Step 3(ii) for assistance on how to identify alternative sites (greenfield and brownfield).
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Step 5 - Applying a Sequential Approach to site layout and design
57. If the Sequential Test and/or Exception Test determines that the proposed development is to be located in a flood risk area, applicants should also apply a sequential approach within the site, steering the most vulnerable uses towards the lowest risk parts of the site, and the least vulnerable uses, such as amenity spaces, towards the highest risk parts of the site. This approach should take into account flood risk from all sources. The sequential approach should also be applied vertically, e.g. designed so that the most vulnerable elements of the development (e.g. housing) are placed on upper floors, wherever possible.
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Step 6 – Preparing Site Specific Flood Risk Assessments
58. PPS25 specifies that site-specific Flood Risk Assessments (FRAs) must be carried out for all development proposals situated within Flood Zone 2 or 3, and also for development proposals on sites greater than 1ha within Flood Zone 1. The Council also expects applicants to undertake a FRA if their site coincides with a surface water and/or groundwater risk zone identified in the Level 1 SFRA (see Step 1 – ‘Other sources of flooding’). The FRA should be submitted as an integral part of the planning application.
59. Detailed guidance on how to undertake FRAs for the different Flood Zones is provided in the Level 1 SFRA (at Section 6.6), and Annex E of PPS25. As noted under Table 4, for sites located near to flood defences in Fluvially Dominated Zone 3a, it will be necessary for the FRA to assess the flood hazard associated with a defence failure21.
60. In particular, applicants are encouraged to demonstrate that their proposal will deliver a positive reduction in flood risk overall, whether that be by reducing the frequency or severity of flooding (for example, through the introduction of SuDS), or by reducing the impact that flooding may have on the community (for example, through a reduction in the number of people within the site that may be at risk). Section 6.4.2 of the Level 1 SFRA provides guidance on this. Before drainage measures are considered however, applicants should normally carry out a percolation test to inform how surface water runoff can most appropriately be managed.
61. The FRA should also specify whether the site meets any of the criteria that have been identified in this Note as potentially constituting a significant surface water/groundwater risk, and if so, provide justification if it is not considered that these present a ‘significant’ risk. The criteria are: The site’s average gradient is greater than 1 in 100, as this is likely to generate overland flow There are ditches adjacent to the site The groundwater level is high (e.g. likely to impede the natural soakage of rainwater)22 There is a large impervious area next to the site (e.g. more than 50% of an adjacent site is impervious, using a 50m band width from all boundaries of the site) There is a history of surface water and/or groundwater flooding on the site (e.g. in June 2007)23
62. Also, the FRA should refer to the development control measures specified at Section 6.4.4 of the Level 1 SFRA or, in the case of Goole, at pages 7-8 in the Level 2 SFRA (reproduced at Appendix 4) to demonstrate how design features have been
21 Flood hazard is classified as ‘Danger to All’; ‘Danger to Most’; and ‘Danger to Some’. Refer to Guidance Note S3.2 Risks to people behind defences. Flood Risk Assessment Guidance for New Development Phase 2 R&D Technical Report FD2320 (Defra, 2005) for guidance on how to undertake this. 22 Examples in the East Riding where this may be the case include Cottingham and Dunswell, where groundwater is encountered at or above ground level. 23 Appendix D of the Level 1 SFRA shows “Indicative Areas of Flooding” in the East Riding during June 2007. The Council’s Land Drainage Department may be able to further provide information in relation to particular sites. It is emphasised however that the accuracy and completeness of this data cannot be guaranteed, and that the Council accepts no liability for any loss, damage or inconvenience caused as a result of reliance upon or use of this data.
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incorporated to ensure that the specific requirements of PPS25 can be met.
63. If it is impossible/difficult on-site to provide an overall reduction in flood risk, consideration needs to be given to whether a contribution to flood risk management infrastructure may be appropriate, supporting the area in which the development takes place (to be determined on a case-by-case basis).
Consultation
64. To assist local planning authorities, the Environment Agency has produced standing advice to inform on their requirements regarding the consultation process for planning applications on flood risk matters. Full details of their Flood Risk Standing Advice can be found on the website www.environment-agency.gov.uk.
65. The Environment Agency advises the Council on FRAs (although they do not normally comment on the Sequential Test for smaller developments). It is strongly recommended that a draft of the detailed FRA is provided to the EA for review and comment before being submitted with the Planning Application, thereby reducing potentially costly delays to the planning process.
66. Applicants are also advised to liaise early with the other relevant organisations including Yorkshire Water, Internal Drainage Boards, and the Council’s Land Drainage Team to ensure that any potential adverse impacts on the existing drainage infrastructure can be mitigated through appropriate design solutions. If access and egress is an important element of a development’s safety, applicants may also need to liaise with Emergency Planning.
67. The Environment Agency is a valuable source of information to inform the development of the detailed FRA. Their External Relations team should be contacted as early as possible to source information relating to (for example) historical flooding, hydraulic modelling and topography (LiDAR). It is emphasised that the information provided within the SFRA is the best available at the time of writing. More up to date information may be available, and contact should always be made with the EA at an early stage to ensure that the detailed site based FRA is using the most current datasets, avoiding unnecessary re-work.
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Appendix 1 – Table D2 from PPS25 – Flood Risk Vulnerability Classification
Essential Infrastructure Essential transport infrastructure (including mass evacuation routes) which has to cross the area at risk Essential utility infrastructure which has to be located in a flood risk area for operational reasons, including electricity generating power stations and grid and primary substations; and water treatment works that need to remain operational in times of flood. Wind turbines. Highly Vulnerable Police stations, Ambulance stations and Fire stations and Command Centres and telecommunications installations required to be operational during flooding. Emergency dispersal points. Basement dwellings. Caravans, mobile homes and park homes intended for permanent residential use. Installations requiring hazardous substances consent19 (Where there is a demonstrable need to locate such installations for bulk storage of materials with port or other similar facilities, or such installations with energy infrastructure or carbon capture and storage installations, that require coastal or water-side locations, or need to be located in other high flood risk areas, in these instances the facilities should be classified as ‘Essential Infrastructure’20.) More Vulnerable Hospitals. Residential institutions such as residential care homes, children’s homes, social services homes, prisons and hostels. Buildings used for: dwelling houses; student halls of residence; drinking establishments; nightclubs; and hotels. Non–residential uses for health services, nurseries and educational establishments. Landfill and sites used for waste management facilities for hazardous waste21 Sites used for holiday or short-let caravans and camping, subject to a specific warning and evacuation plan. Less Vulnerable Police, ambulance and fire stations which are not required to be operational during flooding. Buildings used for: shops; financial, professional and other services; restaurants and cafes; hot food takeaways; offices; general industry; storage and distribution; non–residential institutions not included in ‘more vulnerable’; and assembly and leisure. Land and buildings used for agriculture and forestry.
19 See Circular 04/00: Planning controls for hazardous substances (paragraph 18) at: www.communities.gov.uk/publications/planningandbuilding/circularplanningcontrols 20 In considering any development proposal for such an installation, local planning authorities should have regard to Planning Policy Statement 23, ‘Planning and Pollution Control’.
21 See Planning for Sustainable Waste Management: Companion Guide to Planning Policy Statement 10 for definition. www.communities.gov.uk/index.asp?id=1500757
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Waste treatment (except landfill and hazardous waste facilities). Minerals working and processing (except for sand and gravel working). Water treatment works which do not need to remain operational during times of flood. Sewage treatment works (if adequate measures to control pollution and manage sewage during flooding events are in place).
Water Compatible Flood control infrastructure. Water transmission infrastructure and pumping stations. Sewage transmission infrastructure and pumping stations. Sand and gravel workings. Docks, marinas and wharves. Navigation facilities. MOD defence installations. Ship building, repairing and dismantling, dockside fish processing and refrigeration and compatible activities requiring a waterside location. Water-based recreation (excluding sleeping accommodation). Lifeguard and coastguard stations. Amenity open space, nature conservation and biodiversity, outdoor sports and recreation and essential facilities such as changing rooms. Essential ancillary sleeping or residential accommodation for staff required by uses in this category, subject to a specific warning and evacuation plan.
Notes: 1) This classification is based partly on Defra/Environment Agency research on Flood Risks to People (FD2321/TR2)22 and also on the need of some uses to keep functioning during flooding. 2) Buildings that combine a mixture of uses should be placed into the higher of the relevant classes of flood risk sensitivity. Developments that allow uses to be distributed over the site may fall within several classes of flood risk sensitivity. 3) The impact of a flood on the particular uses identified within this flood risk vulnerability classification will vary within each vulnerability class. Therefore, the flood risk management infrastructure and other risk mitigation measures needed to ensure the development is safe may differ between uses within a particular vulnerability classification.
22 See website for further details. www.defra.gov.uk/science/Project_Data/DocumentLibrary/FD2320_3364_TRP.pdf
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Appendix 2 Level 1 SFRA Level 1 SFRA East Riding settlement/location Appendix A/C Appendix A/C Small Map No.(s) Large Map No.(s) Aldbrough ~ 40 Beeford ~ 18/19 Beverley 16/17/18/19 29/30/37 Brandesburton ~ 24 Bridlington 31/32 6/7/13 Bubwith ~ 33 Driffield 30 11 Easington 26 59 Elloughton-cum-Brough 7 44 Flamborough ~ 7 Gilberdyke 5 43 See Level 2 SFRA Goole (Figures M & N) 50 Haltemprice - Anlaby/Kirk Ella/Willerby 13 45 Haltemprice - Cottingham 14 45 Haltemprice - Hessle 12 53 Hedon 22 46/54 Hedon Haven ~ 54 Hornsea 27 25 Howden 8 42 Hull boundary - Orchard Park 15 37/38 Hutton Cranswick ~ 17 J37 Howdendyke 8 42 J38 (Newport/North Cave) 6 43 Kelleythorpe 30 17 Keyingham 24 55 Kilham ~ 12 Leven 20 31 Market Weighton 4 28 Melbourne ~ 26 Melton ~ 44/52 Middleton on the Wolds ~ 22 Newport 5 43 North Cave 6 35/36 Pocklington 2 21 Pocklington Industrial Estate 2 21 Rawcliffe 10 49 Roos ~ 47 Skirlaugh ~ 38/39 Snaith 11 49 South Cave 6 44 Stamford Bridge 29 14 Wetwang ~ 10 Wilberfoss 28 14 Withernsea 25 56 For settlements/locations not listed in this table, refer to the Level 1 SFRA’s ‘Small Maps key’ and ‘Large Maps key’, available at: http://www.eastriding.gov.uk/corp-docs/forwardplanning/html/sfra.html
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Appendix 3
The Council’s Sustainability Appraisal Scoping Report (May 2010) objectives for the Allocations DPD are:
1. To improve levels of health and reduce health inequalities 2. To reduce social exclusion and improve equality of opportunity amongst social groups 3. To improve accessibility and public transport links to key services and employment areas 4. To improve housing affordability 5. To maintain overall levels of education and skills and retain local highly skilled labour 6. To improve air quality 7. To reduce the growth of road traffic 8. To encourage more efficient use of land 9. To improve the quality of local fresh water resources 10. To reduce levels of atmospheric GHG by reducing emissions and increasing extent of carbon sinks 11. To minimise the impacts of climate change by developing in a way that reduces risk from flooding and coastal erosion 12. To reduce carbon based energy use by increasing energy efficiency and production of renewable energy 13. To protect and enhance biodiversity and important wildlife habitats, and to conserve geology 14. To protect and enhance heritage assets and their settings 15. To protect and enhance the countryside and landscape quality 16. To minimise noise and light pollution 17. To maintain and strengthen the economy of East Riding 18. To increase diversity of employment 19. To support the renaissance of rural areas 20. To avoid sterilisation of mineral resources 21. To ensure adequate infrastructure provision for new development
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Appendix 4 - Spatial Planning and Development Control Recommendations (i) Level 1 SFRA Recommendations PPS25 Flood Zone
PPS25 TIDALLY DOMINATED FLOOD RISK (Flood Zone 3a) Requirement Areas in Close Proximity to Defences Areas Warned of a Defence Failure
Danger to All Danger to Most Danger to Some <6 hours 6-12 hours >12 hours
SPATIAL PLANNING RECOMMENDATIONS
Important Future development within areas at risk of tidal flooding can only be considered following application of the Sequential Test Considerations
Land use should be restricted to Water Compatible, Essential Infrastructure or Less Vulnerable development. More Vulnerable development may only be considered if Exception Test can be passed
New development should be sited away from existing flood defences except in exceptional circumstances, where a flood risk assessment shows how the building and its users will be made safe Land Use (refer (refer Appendix E). Table D2 of Refer to advice under 'Areas in PPS25) More vulnerable development ~ ~ Close Proximity to Defences' More vulnerable development should not be permitted in single More vulnerable development should not be permitted at storey buildings; habitable uses should not be permitted in single ground level should not be permitted at ground storey buildings level in multi-storey buildings
DEVELOPMENT CONTROL RECOMMENDATIONS Detailed Flood Risk Assessment Required (FRA) Floor Level To be agreed on a site by site basis
To ensure the safety of residents and employees during a flood, access and egress routes must be designed to Site Access & A safe refuge should be available on an upper floor, providing an immediate route of escape should a meet Environment Agency defined criteria, as set out in Appendix E. It is essential to ensure that the Egress breach failure occur nominated evacuation route does not divert evacuees onto a ‘dry island’ upon which essential supplies (i.e. food, shelter and medical treatment) will not be available for the duration of the flood event. Separate dwellings should not be permitted at basement level. All basements must have an access point that Basements are subject to rapid inundation without warning within this zone, and should not be Basements is above the 1 in 100 year fluvial, or 1 in 200 year tidal (whichever is greater) flood level, including climate permitted change
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PPS25 Flood Zone PPS25 FLUVIALLY DOMINATED FLOOD RISK Requirement Zone 2 Medium Probability Zone 1 Low Probability Zone 3b Functional Floodplain Zone 3a High Probability
SPATIAL PLANNING RECOMMENDATIONS It should be recognised that property situated within this zone will be subject to frequent flooding, on average, no It is important to recognise that sites less than once in every 20 years. There are clear within Zone 1 may be susceptible to sustainability implications to be considered in this regard, Future development within Zone 3a High Probability can Future development within Zone 2 Medium Important flooding from other sources. and it is highly questionable whether insurance against only be considered following application of the Sequential Probability can only be considered following Considerations Development may contribute to an flooding related damages will be available in the longer term. Test application of the Sequential Test increase in flood risk elsewhere if not Future development within Zone 3b Functional Floodplain carefully mitigated can only be considered following application of the Sequential Test. Land use should be restricted to Water Land use should be restricted to Water Compatible, Land Use (refer Compatible, Less Vulnerable, Essential Land use should be restricted to Water Compatible Essential Infrastructure or Less Vulnerable development. Table D2 of Infrastructure or More Vulnerable development. No restrictions development or Essential Infrastructure. More Vulnerable development may only be considered if PPS25) Highly Vulnerable development may only be Exception Test can be passed considered if Exception Test can be passed DEVELOPMENT CONTROL RECOMMENDATIONS Required for all sites greater than 1ha Detailed Flood in area, and/or situated within the Risk Assessment Required Required Required Groundwater Emergence Zone, (FRA) and/or a Surface Water Hazard Zone. Finished floor levels to be set at 600mm above average site Finished floor levels to be set at 300mm above level or adjacent road frontage level, whichever is higher average site level or adjacent road frontage level, No minimum level stipulated by Floor Level To be agreed on a site by site basis plus an additional 300mm flood proofing. (Road frontage whichever is higher. (Road frontage level defined as PPS25 level defined as the average between the gutter and the the average between the gutter and the crown of crown of the road.) the road). To ensure the safety of residents and employees during a flood, access and egress routes must be designed to Site Access & meet Environment Agency defined criteria, as set out in Appendix A. It is essential to ensure that the nominated No minimum level stipulated by N/A Egress evacuation route does not divert evacuees onto a ‘dry island’ upon which essential supplies (i.e. food, shelter and PPS25 medical treatment) will not be available for the duration of the flood event. Separate dwellings should not be permitted at basement level. All basements must have an access point that is above Basements N/A No restrictions No restrictions the 1 in 100 year fluvial, or 1 in 200 year tidal (whichever is greater) flood level, including climate change
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ADDITIONAL DEVELOPMENT CONTROL RECOMMENDATIONS FOR ALL FLOOD ZONES Implement SuDS on all sites unless it can be demonstrated that they are not practicable or that they will present an unacceptable pollution risk to controlled waters. Development on greenfield sites will be expected to restrict runoff to the greenfield runoff rate. Developments on brownfield sites will be expected to reduce existing runoff rates by a minimum of 30% in order to tackle the predicted impacts of Site Runoff climate change. Any SuDS design must take due account of groundwater and geological conditions (refer Section 6.6.3). It should be ensured that all developments adequately mitigate for the additional volume of surface water generated, not just the rate at which it runs off, to ensure that existing receiving waters are not over burdened. A minimum 8m buffer zone should be provided to ‘top of bank’ within sites immediately adjoining a river corridor. This relates to both open waterways and culverted waterway corridors. Reference should be Buffer Zone made to the Environment Agency's "Living on the Edge" guide (www.environment-agency.gov.uk) that discusses any development situated in, over, under or adjacent to rivers and/or streams. This requirement may be negotiated with the EA in heavily constrained locations. Ensure that the proposed development does not result in an increase in maximum flood levels within adjoining properties. This may be achieved by ensuring (for example) that the existing building footprint is not increased, that overland flow routes are not truncated by buildings and/or infrastructure, or hydraulically linked compensatory flood storage is provided within the site (or upstream). Other As an integral part of the government’s “Making Space for Water” agenda, the Environment Agency is actively seeking the renaturalisation of culverted watercourses as part of any future development. Realistic opportunities to reinstate the natural open waterway within existing culverted reaches of the river(s) should be promoted
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(ii) Goole - Level 2 SFRA Recommendations
PPS25 Flood Zone
TIDALLY DOMINATED FLOOD RISK (Flood Zone 3a) PPS25 Requirement Flood Zone 2 (See EA Flood Zone 1 (See EA Areas in Close Proximity to Defences Flood Map) Flood Map) Remaining Flood Zone Rapid 3a (See EA Flood Map) Inundation Danger to All Danger to Most Danger to Some Caution Zone
SPATIAL PLANNING RECOMMENDATIONS
It is important to recognise that sites within Zone 1 Future development within may be susceptible to Zone 2 Medium Probability flooding from other Important Future development within areas at risk of tidal flooding can only be considered following application of the Sequential Test can only be considered sources. Development Considerations following application of the may contribute to an Sequential Test increase in flood risk elsewhere if not carefully mitigated No development - reserved for Land use should be restricted to Water Compatible, Essential Infrastructure or Less Vulnerable development. More Vulnerable open space / development may only be considered if Exception Test can be passed Land use should be landscaping restricted to Water Development will only be More vulnerable Compatible, Less Vulnerable, Essential Land Use (refer permitted in this zone in development should not Infrastructure or More Table D2 of exceptional be permitted in single More vulnerable No restrictions Vulnerable development. PPS25) circumstances storey buildings; development should not be ~ ~ Highly Vulnerable habitable uses should permitted in single storey development may only be Habitable development not be permitted at buildings considered if Exception should not be permitted ground level in multi- Test can be passed at ground level storey buildings
41 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
DEVELOPMENT CONTROL RECOMMENDATIONS
Required for all sites Detailed Flood greater than 1ha in area, Risk and/or situated within the N/a Required Assessment Groundwater Emergence (FRA) Zone, and/or a Surface Water Hazard Zone.
Finished floor levels to be set at 300mm above average site level or adjacent road frontage To be agreed on a site by site basis and to be informed by the combined flood depth defence breach hazard map No minimum level Floor Level N/a level, whichever is higher. stipulated by PPS25 (Road frontage level defined as the average between the gutter and the crown of the road).
To ensure the safety of residents and employees during a flood, access and egress routes must be designed to meet Environment Agency defined criteria, Site Access & A safe refuge should be available on an upper floor, providing an immediate as set out in Appendix E. It is essential to ensure that the nominated No minimum level N/a Egress route of escape should a breach failure occur evacuation route does not divert evacuees onto a ‘dry island’ upon which stipulated by PPS25 essential supplies (i.e. food, shelter and medical treatment) will not be available for the duration of the flood event.
Separate dwellings should not be permitted at basement level. All basements must have an Basements are subject to rapid inundation without warning within this zone, Basements N/a access point that is above the 1 in 100 year No restrictions No restrictions and should not be permitted fluvial, or 1 in 200 year tidal (whichever is greater) flood level, including climate change
Implement SuDS on all sites unless it can be demonstrated that they are not practicable or that they will present an unacceptable pollution risk to controlled waters. Development on greenfield sites will be expected to restrict runoff to the greenfield runoff rate. Developments on brownfield sites will be expected to reduce existing runoff rates by a minimum of 30% in Site Runoff N/a order to tackle the predicted impacts of climate change. Any SuDS design must take due account of groundwater and geological conditions (refer Section 6.6.3). It should be ensured that all developments adequately mitigate for the additional volume of surface water generated, not just the rate at which it runs off, to ensure that existing receiving waters are not over burdened.
A minimum 8m buffer zone from the bank top of a main river or landward toe of a flood defence should be provided within sites immediately adjoining a river corridor. This relates to both Buffer Zone N/a open waterways and culverted waterway corridors. Reference should be made to the Environment Agency's "Living on the Edge" guide (www.environment-agency.gov.uk) that discusses any development situated in, over, under or adjacent to rivers and/or streams. This requirement may be negotiated with the EA in heavily constrained locations.
Ensure that the proposed development does not result in an increase in maximum flood levels within adjoining properties. This may be achieved by ensuring (for example) that the Other N/a existing building footprint is not increased, that overland flow routes are not truncated by buildings and/or infrastructure, or hydraulically linked compensatory flood storage is provided within the site (or upstream)
42 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
Appendix 5 – Useful documents
Design and Construction of Buildings in a Flood Zone
Improving the flood performance of new buildings: flood resilient construction. [Communities and Local Government] http://www.communities.gov.uk/publications/planningandbuilding/improvingflood
Improving the flood resistance of your home - advice sheets [CIRIA] http://www.ciria.org.uk/flooding/advice_sheets.html
Preparing for a Flood Practical advice on what to do to protect you and your property [Environment Agency] http://publications.environment-EA.gov.uk/pdf/FLHO1007BNET-e-e.pdf
During a Flood Practical advice on what to do to stay safe in a flood [Environment Agency] http://publications.environment-EA.gov.uk/pdf/FLHO1007BNEV-e-e.pdf
After a Flood Practical advice on recovering from a flood [Environment Agency] http://publications.environment-EA.gov.uk/pdf/FLHO1007BNER-e-e.pdf
Flood Protection Association (Promote the interests of manufacturers and installers of flood protection equipment and requirements) http://www.floodprotectionassoc.co.uk/
Flood Evacuation Plans
Get ready for the unexpected [East Riding of Yorkshire Council] http://www.eastriding.gov.uk/hyperlinks/PDF/GetReadyfortheUnexpectedbooklet2010.pdf
Preparing for a Flood [Environment Agency] http://www.environment-agency.gov.uk/homeandleisure/floods/31640.aspx
Make an Emergency Flood Plan [Environment Agency] http://www.environment-agency.gov.uk/homeandleisure/floods/38329.aspx
Temporary Flood Protection Equipment http://www.environment-agency.gov.uk/homeandleisure/floods/31644.aspx
How to Prepare a Flood Plan [Environment Agency] http://www.environment-agency.gov.uk/business/topics/flooding/32362.aspx
Your Risk of Flooding [Environment Agency] http://www.environment-agency.gov.uk/business/topics/flooding/32366.aspx
Preparing a Flood [Environment Agency] http://www.environment-agency.gov.uk/business/topics/flooding/32364.aspx
43 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
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44 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
Appendix 6 – Useful Contacts
East Riding of Yorkshire Council County Hall Beverley HU17 9BA
Development Management (planning applications) Switchboard: 01482 391666 Email: [email protected]
Land drainage Tel: 01482 395656 Email: [email protected]
Emergency Planning Tel: 01482 393095 Email: [email protected]
Forward Planning (planning policy / local plans) Tel: 01482 391748 Email: [email protected]
Environment Agency
Yorkshire and Humber Office Phoenix House Global Avenue Millshaw Beeston Ring Road Leeds LS11 8PG
Tel: 08708 506506 Email General: [email protected] Email External Relations: [email protected] Email Planning Liaison: [email protected] Floodline: 0845 9881188
Internal Drainage Boards
Isle of Axholme IDB Contact: Mr Colin Hinchcliffe Tel: 01507 328095 Email: [email protected] Website: http://www.ioaidb.co.uk/
Lower Aire and Don Consotia of Drainage Boards Cowick IDB Dempster IDB Goole and Airmyn IDB Rawcliffe IDB Snaith IDB
45 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
Contact: Mr Graham Bate Tel:01430 441765 Email: [email protected] Website: http://www.loweraire-idbs.org.uk/
Lower Ouse IDB Contact: Mr Edward Allen Tel: 01430 430237 Email: [email protected] Website: http://www.loidb.co.uk/
Market Weighton IDB Contact: Mr Peter Clark Tel: 01759 302115 Email: [email protected] Website: http://www.marketweighton-idb.org/
Shire Group of IDBs Black Drain IDB Goole Fields IDB Knottingley to Gowdall IDB Reedness and Swinefleet IDB Selby Area IDB Went IDB
Contact: Mr Ian Benn Tel: 01302 329887 Email: [email protected] Website: http://www.shiregroup-idbs.gov.uk/
South Holderness IDBs Keyingham Level IDB Ottringham IDB Preston IDB Skeffling IDB Winestead Level IDB
Contact: Mr Ralph Ward Tel: 01964 630531 Email: [email protected]
Thorntree IDB (near Goole) Contact: Mr Michael Townend Tel: 01405 762557 Email: [email protected]
York Consortium of Drainage Boards Beverley and North Holderness IDB Ouse and Derwent IDB Preston IDB Wilberfoss and Thornton Level IDB
Contact: Mr Bill Symons
46 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
Tel: 01904 720785 Email: [email protected] Website: http://www.yorkconsort.gov.uk/
Yorkshire Water Developer Services PO Box 52 Bradford BD3 7AY
Tel: 08451 208482 Email via website: http://www.yorkshirewater.com/extra-services/developer-services.aspx
47 East Riding of Yorkshire Council Flood Risk Note for the Planning Application Process
East Riding of Yorkshire Council County Hall Beverley East Riding of Yorkshire HU17 9BA
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