Local Plan 2036: Issues and Options Stage

Comment ID 14590529//20
Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Potential new policy areas Q48. Do you have any views on our intended approach to flood risk? View all on this section
Respondent Persimmon Homes Severn Valley View all by this respondent
Response Date 10 Dec 2018
Comment

We think it is important to introduce policy guidance for flood risk in a wider sustainability context. It is clear however that any balancing of benefits against risk will have to be undertaken on a case by case basis but we consider that would be better informed by policy guidance which sets out what needs to be considered through a criteria base policy to inform the balances that need to be assessed in any Flood Risk Assessment accompanying a planning application.

Having said that, proposals will need to be assessed against other requirements, notably the exception and sequential tests, and the importance of demonstrating the development will be safe from flooding throughout its life without increasing flood risk elsewhere. The NPPF and NPPG set out criteria for when the sequential and exception tests need to be applied, so these do not need to be repeated in any Local Plan policy.  However there are other considerations that should be covered.

Firstly the policy should support the Spatial Strategy of the Local Plan. Secondly, the policy will need to be evidenced by a plan wide strategic Flood Risk Assessment.  Therefore it would be appropriate for the policy to say the sequential test is considered to be passed for proposals located within settlement boundaries and for Local Plan allocations which have been assessed in the SFRA and would be in accordance with the strategy.  We note that the Issues and Options document suggest this should be limited to the towns.  However since the policy is only intended to apply within settlements there is no reason why it should not be extended to the service villages, which are by definition sustainable locations for new development.

 

Where there are sites which are not covered in the context of the SFRA and will need to consider the sequential test, any policy should provide guidance on areas of search for reasonably available alternative sites at lower flood risk and provide guidance on the definition of reasonable alternative sites.

 

Summary
We think it is important to introduce policy guidance for flood risk in a wider sustainability context. It is clear however that any balancing of benefits against risk will have to be undertaken on a case by case basis but we consider that would be better informed by policy guidance which sets out what needs to be considered through a criteria base policy to inform the balances that need to be assessed in any Flood Risk Assessment accompanying a planning application.
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