Flood Risk Technical Note 2021

Support

Representation ID: 29084

Received: 24/03/2021

Respondent: Environment Agency

We note there is currently no agreed SFRA Update and that the LPA is committed to producing this evidence, where data is lacking (e.g. models) the LPA will produce
information to a sufficient standard. We also note this uncertainty includes key considerations including but not limited to the removal of 3a(i) designations; agreeing
a 3b designation; and climate change that may/will affect some sites, this may affect allocation viability / requirement.

We note, in the Flood Risk Position Technical Note, the LPA is committed to amending the current Draft Plan/Allocations on the back of this the updated SFRA as needed, when available, and prior to the Reg 19 stage. The LPA makes a specific point in Appendix D that the EN7 Flood Risk Policy will be updated post the SFRA Update so as to use the best information to inform the policy, this may result in changes to the policy wording as a result. As a result it’s difficult to provide meaningful comments on the policy without the data required SFRA however, current comments on EN7 and SP9 Climate Change are within the policies supplement; these may/will change upon the review of the Updated SFRA (which is to follow).

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