Sequential and Exception Tests for Housing Site Options Review 2020 Contents Introduction ........................................................................................................................... 1 Housing Requirement ........................................................................................................... 3 Sites...................................................................................................................................... 5 Methodology ......................................................................................................................... 6 Results .................................................................................................................................11 Conclusions .........................................................................................................................26 1 Introduction A sequential and exceptions test paper was prepared in 2018 to inform the selection of sites for inclusion in the emerging Castle Point Local Plan. Since that time, there have been some modest changes to the housing supply situation, and this paper therefore reviews the sequential and exceptions test and ensures that the site selection process remains in line with national policy regarding development and flood risk. National Policy Context The National Planning Policy Framework (NPPF) requires local planning authorities to take account of the risk of flooding when preparing their local plans. The NPPF sets out a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property, and to manage any residual risk. It is expected that the impacts of climate change are taken into account when considering flood risk, as properties built now are expected to last at least 100 years. In order to direct development, where possible, away from areas at highest risk of flooding, the NPPF requires local planning authorities to carry out a ‘sequential test’ when preparing their local plans. National planning guidance contains information on the application of the sequential test including information on the different ‘flood risk zones’ and the types of development normally appropriate in each having regard to the vulnerability of future users. The NPPF recognises that following the application of the sequential test, it is not always possible, consistent with wider objectives, for certain development proposals/requirements to be located in lower ‘flood risk zones’. It therefore also sets out a test that needs to be passed if certain types of development are to be exceptionally allocated in a local plan, or otherwise permitted. This is known as the Exception Test and comprises two elements: • It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk; • A site specific Flood Risk Assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. National planning guidance details when it is required when applying the Exception Test. Local Policy Context The Thames Estuary 2100 Plan sets out specific policies in relation to the management of flood risk in and around the Thames Estuary. Whilst applying the general policy of directing development away from areas at higher risk of flooding, it recognises that there are some areas around the Thames Estuary that are already substantially developed, and may require additional development to occur in the future in order to support the creation of sustainable communities. Where substantial communities do exist, the Thames Estuary 2100 Plan sets out a policy of maintaining and enhancing the existing defences in order to respond to the 1 implications of climate change. This policy applies on Canvey Island. It does not however apply to the undeveloped area south of Hadleigh. Evidence Base The NPPF expects local authorities to prepare Strategic Flood Risk Assessments in areas where there is likely to be a risk of flooding. Due to Castle Point’s coastal location, it is appropriate for a Strategic Flood Risk Assessment to form part of the New Local Plan’s proportionate evidence base. The South Essex Strategic Flood Risk Assessment Level 1 (SFRA) was prepared in 2018 and assessed tidal, surface, rivers, groundwater, sewers and other sources. The study found that tidal and fluvial flooding poses the most significant risk to Castle Point, in particular Canvey Island and Hadleigh Marshes. The topography and location of watercourses on Canvey Island means that the whole island is at risk from tidal and fluvial flooding. Although much of the island is protected by the presence of defences, the island is still at residual risk of flooding if the defences were to fail or to be overtopped. This risk is increased as a consequence of climate change and predictions around sea level rise. On the mainland area of the Borough, the Prittle Brook and Benfleet Hall Sewer pose the most significant fluvial risk with the southern part of South Benfleet and Hadleigh located within Flood Zone 2 and 3 as well as a small area along the course of the Prittle Brook. High Ground and embankments protect the area from flooding however the area is still at residual risk. A series of high level site specific assessments were undertaken as part of the draft SFRA Level 2 2018 to assist in the consideration of site options. 2 Housing Requirement Based on the standard methodology of calculating housing need set out in the NPPF, there is a need for 5,295 new homes in Castle Point between 2018-2033. This equates to 353 homes per year. At April 2020, 271 homes net had been delivered leaving an outstanding requirement for 5,024 homes. The NPPF requires a 5-year land supply of deliverable housing sites to be identified. Due to poor delivery in the past this should include a 20% buffer brought forward from later in the plan period. The deficit arising between 2018 and 2020 also needs to be addressed. This means it is necessary to identify deliverable sites that can deliver 2,553 homes within the five year period from 2020 to 2025. To ensure that 353 homes are delivered per annum for the period 2018-2033, developable sites need to be identified with a capacity to provide a further 2,471 homes after 5 years. At April 2020, there were extant consents in place for 712 homes (net). These will contribute towards future housing supply, but do not form part of this assessment, as any requirement to undertake the Sequential and Exception Tests has already been addressed through the development management process. This includes allocations HO27, HO28, HO29 and HO30 in the Local Plan November 2019. It is anticipated that these consents will be delivered within the five-year period from 2020 to 2025, reducing the requirement to find for that period from 2,553 to 1,841. To identify additional housing supply, it is necessary to turn to the Strategic Housing Land Availability Assessment SHLAA (2018) which identified 212 development sites that are suitable, available and achievable for the delivery of housing. Due to the passage of time some of these sites now benefit from planning consent. At April 2020, there were 14 sites identified through the SHLAA 2018 which do not benefit from full planning consent and are included on the brownfield register. These sites have capacity for 184 homes. The majority of these are for sites located in flood risk zone 1. There are however four sites located on Canvey Island. Two of these sites benefit from outline planning consent and have consequently been tested against the sequential and exception tests. However, there are two, with a capacity of 25 homes which still require planning consent. There is therefore capacity from the brownfield land register of 159 homes in flood risk zone 1. The remaining capacity from the Brownfield Land Register (25 homes) will be tested through this paper. At April 2020, there were 102 sites identified through the SHLAA 2018 that are located within the urban areas and are policy compliant. These sites have the capacity for 275 homes. 139 of these homes can be secured on sites in flood risk zone 1. However, there 136 homes which are on otherwise policy compliant sites within the existing urban area of Canvey Island. This capacity on Canvey Island will be tested through this paper. Overall, there is identified capacity for 1,010 homes (712 extant consents; 159 brownfield land register; 139 policy compliant) to be secured on identified sites within Castle Point 3 outside flood risk zones 2 or 3 outside of any allocations in the Local Plan. This leaves a requirement for a supply of a further 4,014 homes to be identified. This paper will test the potential for sites in Castle Point to meet the sequential and exception test to fulfil this requirement. This will include testing of potential brownfield capacity and existing urban sites, as well as potential strategic allocations. There are clear constraints on Castle Point that affect the ability to achieve such high levels of growth. However, both the Government and neighbouring authorities will expect Castle Point to go as far as is reasonably possible to achieve housing growth. Table 1: Housing Requirement Calculation based on Objectively Assessed Housing Need of 342 homes per annum Required Identified1 Outstanding Delivery Requirement 2018 – 2033 5,295 1,281 4,014 4 Sites