Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Health and Wellbeing, Air Quality and Climate Change Flood Risk and Sustainable Drainage Policy 18 - Health and Wellbeing, Air Quality, Climate Change and Flooding [View all comments on this section]
Comment ID DLPP997
Respondent Jon Kirby ID-2728 [View all comments by this respondent]
Response Date 26 Sep 2018
Current Status Accepted

Policy 18 states "residential development must avoid, and non-residential development should avoid, areas

at risk of flooding and no development should take place in Flood Zones 2 and 3 without agreement from

the Environment Agency."

11.2 This is supported by policies set out in the NPPF. Paragraph 157 states:

"All plans should apply a sequential, risk-based approach to the location of development – taking into

account the current and future impacts of climate change – so as to avoid, where possible, flood risk to

people and property."

11.3 Paragraph 158 goes onto state that "development should not be allocated or permitted if there are

reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding."

11.4 If it is not possible for development to be located in zones with a lower risk of flooding, the exception testmay have to be applied. This should be informed by a strategic or site-specific flood risk assessment. For the exception test to be passed, it should be demonstrated that:

he development would provide wider sustainability benefits to the community that outweigh the flood

risk; and The development will be safe for its lifetime taking into account the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall.11.5 Both elements of the exception test should be satisfied for development to be allocated or permitted

(Paragraph 161).

11.6 The following sites outlined in Table 7 put forward in the Draft Local Plan are located partially in Flood Zones 2

or 3.

Table 7: Sites in Flood Zones 2 and 3 put forward for allocation

Site Ref. and Address

Site Area (ha)

No. of dwellings

Site Constraints

MX25/MX26 Land south

and east of Four Elms

Road, Edenbridge

27.2 ha


Partially located

in Flood Zone 2.

MX10 Land at

Breezehurst Farm,

Crouch House Road,


18.00 ha


Partially located

in Flood Zone


SKE express concerns regarding the lack of evidence to demonstrate that the sequential and exception tests have been progressed to support the allocation of these sites. Additionally, SDC have not provided an explanation as to how the wider sustainability benefits of the site outweighs the flood risk. Unless the Council provide this justification, there is a risk that new Local Plan will be found unsound, as it will be in conflict with national planning policy.

Recommendations to ensure soundness

The Council should identify sites in low risk flood areas first. Sites in moderate or high risk flood areas should only be allocated once all alterative options have been assessed and their allocation is

accompanied by the appropriate supporting evidence. This will demonstrate that a sequential, riskbased approach to the location of development has been undertaken, in line with national planning policy. This will help ensure that the plan is found sound.

The sites identified in Table 7 should be omitted from the Local Plan. The land at London Road/School Lane is not located in either Flood Zone 2 or 3, and so should be allocated for the delivery of up to 189 dwellings.