2036 Site Allocations Flood Risk Sequential Test
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South East Lincolnshire Local Plan 2011 – 2036 Site Allocations Flood Risk Sequential Test (February 2017) 1.0 Introduction 1.1 This document provides the sequential test for proposed allocations identified in the pre-submission draft South East Lincolnshire Local Plan (SELLP). The approach taken considers all the potential sites considered in the consultations undertaken in the: • Preferred Options consultation (January/ February 2016); and • Further Preferred Sites consultation (July/ August 2016). • Sites considered to be developable which have not been selected as allocations1. 1.2 The report initially provides an overview of the flood risk issues for the SELLP area, alongside a summary of both national and local policy requirements in relation to flood risk. Following this, the document describes the methodology applied to undertake the Sequential Test for the housing sites identified in the SELLP to establish whether it would be possible for development to be directed to locations with a lower risk of flooding and, where relevant, also identifies when the Exception Test will need to be applied to proposed allocations. The tables included in Appendix 1 provide commentary on each settlement and divides the sites considered into those proposed to be allocated in the pre-submission SELLP; and those, which are considered developable, but are not proposed for allocation. 2.0 Overview and Policy Context National Policy 2.1 The National Planning Policy Framework (NPPF) sets out the Government’s planning policy for England including the consideration of flood risk. The NPPF states in paragraph 99 that, ‘Local Plans should take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape’. 2.2 Paragraph 100 of the NPPF elaborates upon the requirements in relation to flood risk and specifically states that ‘...inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere’. 1 This includes sites submitted for consideration in the SHLAA and any additional sites submitted as a result of the various rounds of consultation on the emerging local plan. 1 2.3 The NPPF therefore advocates the use of a sequential, risk-based approach to allocating sites for development in order to, where possible, avoid flood risk to people and property and manage any residual risk. It is advised that this should be achieved by: • applying the Sequential Test; • if necessary, applying the Exception Test; • safeguarding land from development that is required for current and future flood management; • using opportunities offered by new development to reduce the causes and impacts of flooding; and • where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to facilitate the relocation of development, including housing, to more sustainable locations. Sequential Test 2.4 The Sequential Test is, in effect, a sieving process designed to ensure that development is steered away from areas at high risk of flooding, where possible. If flood risk avoidance was the sole consideration in the selection of development sites, this would mean that when a local planning authority is allocating sites for development in their local plan all sites that are in Flood Zone 1 would be allocated before those in Flood Zone 2, and sites in Flood Zone 2 before those Flood Zone 3 until sufficient land is found. Other sources of flood risk also need to be considered, for example a site in Flood Zone 1 may still be at risk of surface water flooding. Moreover, the information contained in the SFRA documents for South East Lincolnshire provides additional detail on flood hazard and flood depth which has been incorporated into the analysis of the sequential test in this report. 2.5 The test takes a hierarchical approach to flood risk management of avoidance wherever possible. Paragraph 101 of the NPPF states that: ‘The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic Flood Risk Assessment will provide the basis for applying this test. A sequential approach should be used in areas known to be at risk from any form of flooding’. 2.6 Additional guidance is available in the Planning Practice Guidance (PPG) to explain the application of the Sequential Test. In accordance with this guidance, the Level 1 and Level 2 SFRAs for the Local Plan area will be used 2 as the basis for undertaking a Sequential Test for the proposed allocations in terms of flood risk. 2.7 If, following the application of the Sequential Test, it is not possible, consistent with wider sustainability objective, for the development to be located in zones with a lower probability of flooding; the Exception Test can be applied if appropriate. The accompanying SA to the pre-submission SELLP considers a range of sustainability objectives including flood risk. Exception Test 2.8 Having completed the Sequential Test, the Exception Test aims to provide a method of managing flood risk whilst still allowing necessary development to occur in the interests of sustainable development. 2.9 Paragraph 102 of the NPPF allows the application of the Exception Test by a local planning authority where following application of the Sequential Test it is not possible, consistent with wider sustainability objectives, for the development to be located in zones with a lower risk of flooding. The Exception Test therefore provides a method of managing flood risk while still allowing for development to occur. 2.10 There are two elements to the Exception Test as set out below. Both elements need to be passed: • 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; and • A site-specific FRA must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible will reduce flood risk overall. 2.11 Site-specific FRAs have not been completed for each of the proposed allocations and these are usually undertaken at the planning application stage. Consequently, at this stage it is only possible to determine whether the proposed allocations identified by the pre-submission SELLP would need to be subject to the Exception Test. The sustainability appraisal of the proposed allocations and “reasonable alternatives” sites has informed the consideration of sites with respect to flood risk and wider sustainability matters, fulfilling the first element noted above in paragraph 2.10. 3 Flood Risk Vulnerability Classification 2.12 The Planning Practice Guidance sets out flood risk vulnerability classification for various land uses as per Table 1 below. The classification acknowledges that not all land uses have the same vulnerability to flooding. Some land uses, such as residential development, are more vulnerable to the potential loss of life and damage to personal property and possessions than retail or office developments for example. 2.13 By way of example, Table 1 below shows that within Flood Zone 1 all land uses are acceptable as flood risk is not considered to be significant constraint to development. However, a site-specific Flood Risk Assessment (FRA) will be required on sites that are greater than one hectare in size and this assessment will need to consider other potential sources of flood risk, such as ground and surface water flooding. In Flood Zone 3a, potentially suitable land uses are water compatible (e.g. minerals development) and less vulnerable uses (e.g. employment uses). More vulnerable uses (e.g. residential) and essential infrastructure uses (e.g. transport infrastructure) should only be permitted in this zone if the Exception Test is passed. Highly vulnerable development (e.g. caravans) should not be permitted in this zone. Flood Risk Essential Water Highly More Less Vulnerability Infrastructure Compatible Vulnerable Vulnerable Vulnerable and Flood Zone e.g. Transport e.g. open e.g. Police e.g. e.g. offices, Compatibility and Utility space, Stations, Hospitals, industry and Infrastructure docks, mobile residential storage or marinas and homes and institutions distribution wharves emergency and dispersal buildings points used for dwelling houses Flood Risk Zone 1 Yes Yes Yes Yes Yes - low probability Flood Risk Exception Zone 2 Yes Yes Test Yes Yes - medium Required probability Flood Risk Exception Exception Test Zone 3a – high Yes No Test Yes Required probability Required Flood Risk Zone 3b – the Exception Test Yes No No No Functional Required Flood Plain Table 1: Flood Risk Vulnerability Classification (Planning Practice Guidance March 2014) 4 Local Policy 2.14 The Environment Agency's Flood Map shows that almost the whole of the Borough of Boston and a large part of the South Holland District are subject to flooding. Approx 85% of Boston lies within areas that could flood (84% in Flood Zone 3 'high probability', 1% in Flood Zone 2 ' medium probability') resulting in 26,503 residential and 1,212 commercial properties being at risk. Approximately 74% of South Holland lies within areas that could flood (68% in Flood Zone 3, 6% in Flood Zone 2) resulting in 29,922 residential and 1,296 commercial properties being at risk. 2.15 The approach to flood risk in the pre-submission SELLP is a key aspect of the strategy given the significant issues faced by potential flooding incidents in the area. The Lincolnshire Coastal Study Group was formed in 2008 to progress a coastal strategy covering the districts of Boston, East Lindsey and South Holland.