Development within Functional Flood Plains
These notes aim to promote understanding of the issues relating to flood risk management, development and the Broads Authority’s position.
Introduction
The Government places an increasingly high emphasis on protecting property and individuals from flood risk. This is partly in response to recent flooding events and partly in response to climate change and the increasing risk of more frequent flood events. A further driver is the need to provide hundreds of thousands of new homes, particularly in the south-east where much development land is within the lower lying areas. The Government has determined that, rather than trying to protect these sites through traditional means such as flood defences, a more fundamental approach is required. It is seeking, therefore, not to allow new development in areas of high flood risk. As a general policy position this is a sensible approach and represents good forward planning.
Planning Policy Statement 25: Development and Flood Risk (PPS25)
The above approach is set out in Planning Policy Statement 25: Development and Flood Risk (PPS25). PPS25 is a Government document representing Government policy, published in December 2006 and later in a companion guide published in July 2008. For more information on Planning Policy Statements, visit the Communities and Local Government website at www.communities.gov.uk.
The implementation of PPS25 is overseen by the Environment Agency in their advice on, and response to, planning applications. All local planning authorities across the country, including the Broads Authority, are required to adhere to it. Therefore, although PPS25 is not a policy statement by the Broads Authority, we are required to abide by it.
PPS25 classifies development according to its vulnerability to flooding, ranging from ‘water compatible uses’ to ‘highly vulnerable uses’. It divides the country up into one of four flood risk zones (1, 2, 3a and 3b) ranging from low flood risk (Flood Risk Zone 1) to functional flood plain (Flood Risk Zone 3b). It then provides a matrix setting out what types of development are appropriate in each flood risk zone. The boundaries of the various flood risk zones have been published in the Broads Strategic Flood Risk Assessment (SFRA). The SFRA will be available via the Greater Norwich Development Partnership website and may also be viewed at the Authority’s offices.
Local policy on development and flood risk
In September 2008, the Authority published a Development and Flood Risk Supplementary Planning Document (SPD) as part of its Local Development Framework. The SPD provides guidance to developers and planning applicants on management of flood risk and the particular circumstances for allowing development in The Broads.
Broads planning policies favour development which contributes to the economic function of the area such as agriculture, tourism (including hotels and holiday accommodation) and the marine industry, or for environmental purposes. The policies are not looking for the provision of sites for new residential development. A proposal for permanent residential development on previously undeveloped land in Flood Risk Zone 3 is most unlikely to pass the Sequential Test. It is expected that, as most developed land in The Broads lies within Flood Risk Zone 3, an 'Exception Test' will need to be applied for most applications for new development which are compatible, in principle, with their location in The Broads. The SPD clarifies how the test will be interpreted locally.
In general, it is unlikely that development will be permitted on ‘green field’ sites in the flood plain. In Flood Risk Zone 3b, new water compatible development or a like-for-like replacement of an existing use may be appropriate. In Flood Risk Zone 3a, which includes previously developed land shown on the SFRA as being in functional flood plain, new development for water compatible uses or less vulnerable uses (as defined in PPS25) or a like-for-like replacement of an existing use may be permissable under certain circumstances.
Sustainable drainage systems (SUDS) are the best way of avoiding and managing surface water flooding if new development cannot be located away from the flood risk area. The SPD outlines how the Authority would expect to see sustainable drainage accommodated in a development.
Developers should assess carefully the full range of issues associated with flood risk when considering and formulating development proposals. They should take into consideration the effects of climate change over the lifetime of the proposed development. Pre-application discussion of these issues with officers of the Broads Authority and the Environment Agency is strongly encouraged. Developers must demonstrate that development both minimises flood risk and will still be of a scale and design appropriate to its Broads setting. There is a particular need for a good quality of design when dealing with waterside sites.
Further information
For more information on Broads planning policy, visit the Local Development Framework page, contact planning@broads-authority.gov.uk, or write to: Planning and Strategy Directorate, Broads Authority, Dragonfly House, 2 Gilders Way, Norwich NR3 1UB. Full information on flood risk may be found on the Environment Agency’s website at www.environment-agency.gov.uk or by writing to: Eastern Area Office, Environment Agency, Cobham Road, Ipswich, Suffolk IP3 9JE.