Core Strategy - Consultation Draft

Comment ID 1020673/CSCD/39
Document Section Core Strategy - Consultation Draft Chapter 3: Spatial Policies Delivering Strong and Inclusive Communities CS14: Distribution of New Housing CS14: Distribution of New Housing [View all comments on this section]
Respondent Environment Agency [View all comments by this respondent]
Response Date 24 Feb 2010
Policy CS14 discusses the role of service villages in delivering housing and the small scale infill housing and conversions. Some of these villages lie within flood risk areas and due to their rural nature are likely to fall within functional floodplain areas.

We would strongly recommend that NSC influence the infill development of the service villages by applying their SFRA Level 1 and 2 to ensure sound decisions are made in the Core Strategy.

In these areas it will be necessary to apply the Sequential Test to all infill sites. Conversions which can be classed as change of use applications are not subject to the Sequential Test and therefore conversions proposed in Flood Zones will not have to show that they can avoid flood risk. For housing development, this can set a dangerous precedent where existing buildings are converted to residential use which provides little scope for improving the building to protect against flood risk. This can also lead to barn conversions and ground floor accommodation which puts the end user at a higher vulnerability in a flood event.

PPS25 Practice Guide Paragraph 4.4.2 gives further advice on this scenario; "LPA's when formulating Local Development Documents (LDD) should bear in mind that change in use may involve an increase in flood risk if the vulnerability classification of the development is changed, as reflected in table D.2 of PPS25. For example, a change of use from industrial use to residential use will increase the vulnerability classification from less vulnerable to more vulnerable. The LPA should consider when formulating LDD policy, what changes of use will be acceptable taking into account the findings of the SFRA." As it is likely that the rural areas will be classed as functional floodplain we would recommend that development is avoided in the flood risk areas. We would encourage NSC to formulate a policy controlling the types of development.