Object

Representation ID: 29253

Received: 24/03/2021

Respondent: Environment Agency

A local planning authority should demonstrate through evidence that it has considered a range of options in the site allocation process, using the Strategic Flood Risk Assessment to apply the Sequential Test and the Exception Test where necessary. This can be undertaken directly or, ideally, as part of the sustainability appraisal. Where other sustainability criteria outweigh flood risk issues, the decision making process should be transparent with reasoned justifications for any decision to allocate land in areas at high flood risk in the sustainability appraisal report. The Sequential Test can also be demonstrated in a free-standing document, or as part of strategic housing land or employment land availability assessments.

We would strongly encourage you to produce a free-standing sequential test document so it is clear how requirements of Planning Practice Guidance and the NPPF had been fulfilled. This would enable ease of reference throughout each stage of the Local Plan development and importantly at examination. We are happy to work with you on is.

Please note within the PPG that a document is provided that explains the application of the Sequential Test for Local Plan preparation. Please review this and consider it as a basis for a sequential test document. Please see further guidance here:
https://www.gov.uk/guidance/flood-risk-and-coastal-change