Comment

Representation ID: 4744

Received: 21/12/2022

Respondent: Environment Agency

We welcome the addition of a Level 2 SFRA. The Level 2 SFRA shows that the critical 1 in 100 year plus climate change flood extent encroaches (albeit largely into public open space) on sites 119a, 284, 139, Land North of Penkridge, SA1 and SA4. The SFRA confirms that for the majority of these sites the encroachment is only minor.

All these sites will therefore require a site specific FRA which shows development laid out as to avoid the floodplain and finished floor levels 600mm above the 1 in 100 plus climate change flood level. This should be detailed within the allocation requirements. In addition, the quantum of development should be reviewed to ensure that it can fit onto the area outside the 1 in 100 plus climate change flood event, with particular note of 119a which shows about a third of the site affected by flooding.

Although referenced within the Sustainability Appraisal it is unclear where the evidence sits to clearly demonstrate how the proposed site allocations have had the Sequential Test applied as is required by Paragraphs 161 and 162 of the NPPF. We recommend however given the proximity of the fluvial floodplain, residual risk should be mitigated for by it being required that finished floor levels are set at or in excess of 600mm above the 1in 100 year plus climate change for that specific location.
• Site Ref 617
• Site Ref 646a.
• Site Ref 646b