2009s0275 newcastle level 1 sfra final 2€¦ · newcastle sfra level 1 final march 2010 rachael...

Newcastle SFRA

Level 1

Final March 2010

Rachael Ashworth Planning and Transportation Division Newcastle City Council Civic Centre Barras Bridge NEWCASTLE UPON TYNE NE99 2BN

2009s0275 Newcastle Level 1 SFRA Final 2.doc i

JBA Office JBA Consulting South Barn Broughton Hall Skipton, North Yorkshire BD23 3AE

JBA Project Manager Howard Keeble MPhil BEng BSc CEng CEnv CWEM CSci MICE MCIWEM MCMI

Revision History

Revision Ref / Date Issued Amendments Issued to

Final draft V1for checking Rachael Ashworth By email

Final Amended sites -following council review. CDA. SWMP. Updated plans to reflect sites

Rachael Ashworth By email / hardcopy

Final 1 Including response to EA review

Rachael Ashworth By email / hardcopy

Final 2 Appendix J Rachael Ashworth By email

Contract This report describes work commissioned by Newcastle City Council under ORDER VPTH 0618082 of 03/07/2009. Newcastle Council’s representative for the contract was Rachael Ashworth. Howard Keeble and Thomas Sherwood of JBA Consulting carried out the work.

Prepared by: Howard Keeble MPhil BEng BSc CEng CEnv CWEM MICE MCIWEM Principal Engineer Thomas Sherwood MphysGeog Analyst Reviewed by: David Stark BSc CEng MICE Principal Engineer Jonathan Cooper BEng MSc CEng MICE MCIWEM MIoD Divisional Manager Issued by Gary Deakin BSc CEng MICE Divisional Manager

Purpose This document has been prepared as a Strategic Flood Risk Assessment for Newcastle City Council. JBA Consulting accepts no responsibility or liability for any use that is made of this document other than by the Client for the purposes for which it was originally commissioned and prepared. JBA Consulting has no liability regarding the use of this report except to Newcastle City Council.

Copyright © Jeremy Benn Associates Limited 2010

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Executive Summary

Development & Flood Risk

Local Planning Authorities (LPAs) face a range of considerations when planning future development. These considerations are defined by Government Planning Policy Statements and in particular by Planning Policy Statement 25: Development and Flood Risk (PPS25). The aim of PPS25 is to avoid inappropriate development in flood risk areas.

The objectives of PPS25 are achieved using the sequential approach to land allocation. This means that in principle, further development should be avoided in flood risk areas before consideration is given to either the vulnerability of planned development, or possible measures designed to mitigate flood risk.

The sequential approach is governed by the Sequential and Exceptions Tests. Consideration of flood risk to people and development must be considered by the LPA at the earliest stage of the spatial planning process. These tests allow the decision-making process to be both transparent and effective in terms of managing flood risk and balancing the need for development.

High level policy and guidance documents such as Catchment Flood Management Plans (CFMPs), Shoreline Management Plans (SMPs) and Regional Flood Risk Assessments (RFRAs) provide a good introduction to flood risk. However, they do not provide the level of detail required for the LPA to make sufficiently informed spatial planning decisions. In order to carry out these tests an understanding of local flood risks is needed.

Strategic Flood Risk Assessments (SFRAs) provide this level of understanding. SFRAs provide the LPA with a central source of all relevant flood risk information as well as the evidence base to make tough planning decisions. The SFRA allows the LPA to prepare focused and local policies that are required to inform the Local Development Framework (LDF). The SFRA is, therefore, a key planning tool that enables the LPA to select and develop sustainable site allocations away from vulnerable flood risk areas.

A Level 1 SFRA provides the foundation of this evidence base. It relies on existing flood risk information and the Environment Agency’s (EA's) Flood Map is the main source of fluvial and tidal flood data. The Flood Zone Maps define the PPS25 Flood Zones and form the basis of the Sequential Test.

Consideration must also be given to flooding from all sources including surface water, sewers, groundwater and artificial sources. This information is obtained through consultation with those stakeholders having specific interest or knowledge of these flood risks within Newcastle. These include, for example, Northumbrian Water, the EA and Tyne and Wear Fire Service.

The PPS25 Flood Zone Map enables the LPA to carry out the first sweep of the Sequential Test. Additional Strategic Flood Risk Maps have been developed for this SFRA for use during the Sequential Testing process to identify further areas that are unsuitable for development.

Once the LPA has carried out the Sequential Test, the Council may seek to allocate more vulnerable development in areas at higher risk of flooding on the grounds of, for example, economic growth and regeneration. In these cases allocations must pass the Exception Test. However, the evidence provided in the Level 1 SFRA is not detailed enough to justify development through the Exception Test. In this instance a Level 2 SFRA will be required.

A Level 2 SFRA provides the LPA with a more detailed understanding of flood hazards. It includes assessment of flood depths, velocities and residual risks such as those associated with defence breach or overtopping scenarios. The information provides an LPA with a detailed understanding of flood risks within an area. However, a Level 2 SFRA does not provide the specific details required to pass the Exception Test. Instead it provides a clear understanding as to the appropriateness of a particular development and the likelihood of it remaining safe in the future.

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If the LPA has justified the development by passing parts A and B of the Exception Test, it must be supported by a site-specific Flood Risk Assessment (FRA) in order to pass part C.

Newcastle Level 1 SFRA

This Level 1 SFRA has been produced for Newcastle City Council in accordance with Planning Policy Statement 25 Development and Flood Risk (PPS25) and the associated Practice Guide.

Understanding the SFRA Process

The SFRA provides a comprehensive discussion of PPS25, and the Sequential and Exception Tests. It is a reference document that explains current flood risk management drivers including national, regional and local planning policies.

The SFRA provides a description of the mechanisms of flooding and the concept of flood risk for those with little knowledge of the issues and constraints. It should be read by:

� The general public or those new to flood risk; � Those wanting to understanding current flood risk management drivers; � Those wanting to understand the sequential approach to flood risk management;

and, � Development Control, Planners and Developers wanting to understand the wider

constraints of development in flood risk areas.

SFRA Technical Report

The SFRA provides the technical information and methods used in the assessment of flood risk in the Newcastle area. It includes assessment of six sources of flooding, comprising; fluvial, tidal, over land, sewers, groundwater and reservoirs.

There are many factors that influence flood risk. Information used and developed in the SFRA is presented as a suite of maps. The SFRA Maps, included as Appendix J, comprise:

� Set A: PPS25 Flood Zones � Set B: Flood Zone 3 Depths � Set C: Flood Hazards � Set D: Flood Risk Management Measures � Set E: Areas Naturally Vulnerable to Surface Water Flooding � Set F: Climate Change Sensitivity � Set G: Critical Drainage Areas

Section 7 provides the results of the first pass of the Sequential Test for Newcastle City Council’s Areas of Major Change, Employment Land Review Sites (ELR) and Strategic Housing Land Availability Assessment (SHLAA) sites. This Section in particular should be read by:

� Spatial Planners; � Development Control; � Planners; � Developers; � Emergency Planners; and � Key Stakeholders including the Environment Agency and Northumbrian Water.

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SFRA Guidance for Spatial & Development Management

Included as appendices to this SFRA is guidance for spatial planners, planners and developers. This section explains how to use the flood risk information provided in this SFRA. This section of the report also discusses further work that may be required, such as Level 2 SFRAs. This extra work will provide Newcastle City Council with a strategic and coherent framework for managing flood risk in the area. In addition consideration is also given to sustainable drainage systems and the identification of critical drainage areas requiring further investigation.

Contents

2009s0275 Newcastle Level 1 SFRA Final 2.doc

Executive Summary ........................................................................................................ ii�

1� Introduction ........................................................................................................ 1�

1.1� Background .......................................................................................................... 1�1.2� Scope & Objectives ............................................................................................. 1�1.3� Study Area ........................................................................................................... 2�

2� Understanding Flood Risk ................................................................................ 4�

2.1� Introduction .......................................................................................................... 4�2.2� Sources of Flooding ............................................................................................. 4�2.3� Flooding Likelihood & Consequence ................................................................... 6�

3� The Sequential Approach ................................................................................. 9�

3.1� Introduction .......................................................................................................... 9�3.2� The Sequential Test ............................................................................................. 9�3.3� Individual Planning Applications .......................................................................... 11�3.4� Flood Risk Vulnerability Classification ................................................................. 12�3.5� The Exception Test .............................................................................................. 14�3.6� How to assess a proposal is safe? ...................................................................... 15�3.7� Levels of Flood Risk Assessment ........................................................................ 16�3.8� Level 1 Strategic Flood Risk Assessment ........................................................... 16�

4� Data Sources ...................................................................................................... 18�

4.1� Flood Zone Map ................................................................................................... 18�4.2� Delineation of Low Risk Zone 1 ........................................................................... 18�4.3� Delineation of Medium Risk Zone 2 ..................................................................... 18�4.4� Delineation of High Risk Zone 3 .......................................................................... 18�4.5� Delineation of the Functional Floodplain ............................................................. 18�4.6� Flood Defences .................................................................................................... 19�4.7� Hydraulic Modelling Studies ................................................................................ 19�4.8� Historical Flooding ............................................................................................... 19�

5� Flood Risk in Newcastle.................................................................................... 20�

5.1� Introduction .......................................................................................................... 20�5.2� Tidal Flood Risk ................................................................................................... 20�5.3� River Tyne ........................................................................................................... 20�5.4� Flooding From Land ............................................................................................. 21�5.5� Screening For Critical Drainage Areas ................................................................ 21�5.6� Flooding From Sewers ......................................................................................... 21�5.7� Flooding from Groundwater ................................................................................. 22�5.8� Flooding from Reservoirs & other Artificial Sources ............................................ 22�5.9� Effects of Climate Change - Peak Tidal Levels ................................................... 22�5.10� Effects of Climate Change - Fluvial Flood Levels ................................................ 23�5.11� Functional Floodplain Predictions for Newcastle ................................................. 23�5.12� Geology & Soils ................................................................................................... 24�5.13� Flood Defences .................................................................................................... 24�5.14� Flood Warning Areas ........................................................................................... 25�

6� Strategic Flood Risk Mapping .......................................................................... 27�

6.1� Introduction .......................................................................................................... 27�6.2� Flood Zones Maps ............................................................................................... 27�6.3� Functional Floodplain ........................................................................................... 27�

Contents


6.4� Flood Zone 3 Depth & Hazard Maps ................................................................... 28�6.5� Flood Risk Management Measures Maps ........................................................... 28�6.6� Areas Vulnerable to Surface Water Flooding Map .............................................. 29�6.7� Climate Change Sensitivity Maps ........................................................................ 29�

7� Site-Specific Allocations ................................................................................... 30�

7.1� Summary of Information provided in the Sequential Test Spreadsheet .............. 30�7.2� Development Site Sequential Test ...................................................................... 30�7.3� Summary of sites at risk of Fluvial Flooding ........................................................ 31�7.4� Summary of sites at risk of Surface Water Flooding ........................................... 32�7.5� Review of Current Development Sites ................................................................. 32�7.6� Surface Water Management Plans ...................................................................... 33�7.7� Proposed Critical Drainage Areas ....................................................................... 34�7.8� Water Cycle Studies (WCS) ................................................................................ 35�7.9� Green Infrastructure Framework ......................................................................... 36�

Appendices...................................................................................................................... I�

A .� The Planning Framework .................................................................................. I�

B .� Flood Risk Zones ............................................................................................... XVI�

C .� Flood Risk Vulnerability Classification (Table D.2 PPS25 ............................. XIX�

D .� Guidance for Spatial Planners ......................................................................... XXI�

E .� Guidance for Developers .................................................................................. XXVIII�

F .� Guidance for Development Control ................................................................. XXXIII�

G .� Guidance for Emergency Planners .................................................................. XXXV�

H .� Flood Risk Management Measures .................................................................. XXXVIII�

I .� Consultation and Data Management ............................................................... XLII�

J .� Newcastle City Council - Sequential Test Spreadsheet ................................ XLVI�

K� Newcastle City Council - Data Register ........................................................... LII�

L� SFRA Maps ......................................................................................................... LIV�

M� Response to EA Level 1 review comments..................................................... LV�


List of Figures Figure 1 (Newcastle SFRA Study Area) ........................................................................ 3�

Figure 2 (Flooding From Other Sources) ..................................................................... 5�

Figure 3 (Source-Pathway-Receptor model) ................................................................ 6�

Figure 4 (Sequential Test Process) ............................................................................... 10�

Figure 5 (Where the Exceptions Test Applies) ............................................................ 14�

Figure 6 (Flood Warning Codes) ................................................................................... 26�

Figure 7 (Tyne CFMP Policy Units) ............................................................................... XIII�

Figure 8: Taking flood risk into account in LDDs ....................................................... XXIII�

Figure 9: Applying the Sequential Test and assessing the likelihood of passing the Exception Test .............................................................................. XXIV�

Figure 10: Likelihood of passing the Exceptions Test ............................................... XXV�

Figure 11: Planning for development ........................................................................... XXVI�

List of Tables Table 1 (Extreme tidal level estimates for North Shields2) ......................................... 20�

Table 2 (Effect of sea level rise on water levels in the Tyne Estuary) ....................... 23�

Table 3 (PPS25 Table B.2: Recommended national precautionary sensitivity ranges for peak rainfall intensity, peak river flows, offshore wind speeds and wave heights) ................................................................................ 23�

Table 4 (NFCDD Condition Ratings for Flood Defences) ........................................... 25�

Table 5 (Flood Hazard Rating) ....................................................................................... 28�

Table 6 (Summary of Development Sites at Risk of Fluvial and Tidal Flooding) ..... 31�

Table 7 (Summary of Development Sites at Risk of Surface Water Flooding) ......... 32�

Table 8: Screening for Critical Drainage Areas ........................................................... 35�

Table 9 (Lower Tyne CFMP Policy Unit Action Plan) .................................................. XIV�

Table 10: Development types and application of Sequential and Exception Tests.................................................................................................................... XXIX�

Table 11 (SFRA Review Triggers) ................................................................................. XLV�


Abbreviations ABD Areas Benefiting from Defences AEP Annual Exceedance Probability CFMP Catchment Flood Management Plans CLG Communities and Local Government COW Critical Ordinary Watercourse CS Core Strategy DPDs Development Plan Documents DCLG Department for Communities and Local Government EA Environment Agency EU European Union FAS Flood Alleviation Schemes FEH Flood Estimation Handbook FCERM Flood and Coastal Erosion Risk Management FRA Flood Risk Assessment FRM Flood Risk Management FRMP Flood Risk Management Plan GIS Geographic Information Systems IDB Internal Drainage Board IDD Internal Drainage District IFM Indicative Floodplain Map LDD Local Development Document LDF Local Development Framework LiDAR Light Detection and Ranging LPA Local Planning Authority NEA North East Assembly NFCDD National Fluvial and Coastal Defence Database NPD National Property Dataset NLRF Northumbria Local Resilience Forum NWL Northumbrian Water Ltd PPG Planning Policy Guidance PFRA Preliminary Flood Risk Assessment PPS Planning Policy Statement RBD River Basin District RBMP River Basin Management Plan RFRA Regional Flood Risk Assessment RPB Regional Planning Bodies RPG Regional Planning Guidance RSA Regional Sustainability Appraisal RSS Regional Spatial Strategy RVFD Receptors Vulnerable to Flooding Database SA Sustainability Appraisal SCI Statement of Community Involvement SEA Strategic Environmental Assessment SFR Significant Flood Risk SFRA Strategic Flood Risk Assessment SFVI Social Flood Vulnerability Index SHLAA Strategic Housing Land Availability Assessment SMP Shoreline Management Plans SoP Standard of Protection SPD Supplementary Planning Document SUDS Sustainable (Urban) Drainage Systems SWMP Surface Water Management Plan TWFRS Tyne and Wear Fire and Rescue Services UDP Unitary Development Plan WCS Water Cycle Study WFD Water Framework Directive

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1 Introduction

1.1 Background

JBA Consulting was commissioned in June 2009 by Newcastle City Council to undertake a review of the existing Tyne and Wear Strategic Flood Risk Assessment (SFRA) published in 2007. This report details a Level 1 SFRA for Newcastle City Council and has been prepared in accordance with current best practice, Planning Policy Statement 25 Development and Flood Risk (PPS25)1.

PPS25 reinforces the responsibility of LPAs to ensure that flood risk is managed effectively and sustainably as an integral part of the planning process, balancing socio-economic needs, the existing framework of landscape and infrastructure, and flood risk.

Key additional areas of work, building on the existing SFRA include:

� Taking account of advances in risk information from data collection and processing;

� Inclusion of climate change mapping; � Identification of functional floodplain; � Improved understanding of flooding from other sources; � Developing a greater focus on the application of the PPS25 Exception Test; and � Preparing a review of current sites identified for potential development.

1.2 Scope & Objectives

Flooding is a natural process that is not restricted by political demarcations or administrative boundaries. It is primarily influenced by natural elements such as rainfall, tides, geology, topography, rivers and streams and infrastructure such as flood defences, roads, buildings, and sewers.

As demonstrated by the summer 2007 floods experienced across England and more locally in September 2008, flooding can cause significant disruption to communities, substantial damage to property and possessions, and loss of life. For these reasons it is important to avoid, as a matter of principle, development in flood risk areas. Where this is not possible then the vulnerability of the proposed land use to flooding should be considered and measures taken to minimise flood risk to people, property and the environment. This is the basis of the risk-based sequential approach to managing flood risk.

Current Government policy requires LPAs to demonstrate that due regard has been given to the issue of flood risk as part of the planning process. It also requires that flood risk is managed in an effective and sustainable manner. Where new development is exceptionally necessary in flood risk areas, the policy aim is to make it safe without increasing flood risk elsewhere. Whenever possible, overall flood risks should actually be reduced.

An SFRA is a planning tool that enables the Council to select and develop sustainable site allocations away from vulnerable flood risk areas. The assessment focuses on the existing site allocations within the area but also sets out the procedure to be followed when assessing additional sites for development in the future.

It is recognised that considerable land use pressures for re-generation, inward investment and economic growth exist across the districts and this SFRA will inform and support the Regional Spatial Strategy (RSS). It will guide the Council in developing strategies, policies and decision-making in respect of their Local Development Frameworks (LDFs) and Local Development Documents (LDDs).

1 Communities and Local Government (2006) Planning Policy Statement 25: Development and Flood Risk


In addition to informing site allocations the SFRA forms the basis for decision-making on: non-allocated planning applications; strategic flood alleviation measures and other measures to reduce flood risk to existing development; planning requirements for new development; and emergency planning.

The key objectives of this SFRA are to:

� Investigate and identify the extent and severity of flood risk to an area both now and in the future;

� Contribute to the Council’s Strategic Environmental Assessment (SEA) and LDF; � Enable the Council to apply the Sequential Test and the Exception Test; � Provide strategic flood risk guidance and advice to planners and developers; � Help LPAs to identify specific locations where further, more detailed flood risk data

and assessment work is required. This includes Level 2 SFRAs and the scope for Surface Water Management Plans and Water Cycle Studies;

� Identify the level of detail required for site-specific FRAs; � Inform the emergency planning process; � Improve stakeholder working and the sharing of data, information and

understanding of flood risk; and � Be used as a reference document.

Since publication of the PPS25 Practice Guide in 2008 it is recognised that SFRAs are more than just a land use planning tool. SFRAs form a broader and inclusive mechanism for the assessment and delivery of integrated, strategic and local Flood Risk Management (FRM).

Since publication of the Pitt Review, it is apparent that SFRAs provide the central reference for data, information and consideration for all flood risk issues. This includes flooding from all sources at a local level. The SFRA provides the link between CFMPs, SMPs, RFRAs, SWMPs and the need for appropriate sustainable land uses over a number of planning cycles. SFRAs are proving to be pivotal documents in the introduction and promotion of a local authority’s role in flood management following publication of the Pitt Review.

SFRAs need to be fit for the future to help communities meet the considerable challenges of flood risk management and climate change.

1.3 Study Area

The study comprises the whole of the Newcastle City Council area. Newcastle is located in the north east of England and is one of five metropolitan districts that comprise the conurbation of Tyne and Wear.

Newcastle North includes the wards of Castle, Fawdon, Parklands and Woolsington. This area is at risk from fluvial flooding from the River Pont and Prestwick Carr Drains to the North, Hartley Burn to the East and the Ouseburn to the South.

Although the Flood Zones surrounding Prestwick Carr Drains are extensive, they only affect rural land west of Dinnington. Hartley Burn originates northwest of Brunswick Village producing wide Flood Zones along the drains surrounding Big Waters Nature Reserve, becoming narrower as Hartley Burn flows into North Tyneside.

The majority of flood risk to northern areas of Newcastle originates from the upstream reaches of the Ouseburn and two of its major tributaries: Gosforth Letch and Harley Burn. Over 90% of the catchment is upstream of Crag Hall gauging station. Flood Zones 2 and 3 are narrow but extensive along the Ouseburn.

Although the upper reaches of the Ouseburn flow through predominantly rural areas it does create a level of flood risk to the outskirts of Woolsington and Fencer Hill Park. The Ouseburn then enters the heavily developed areas of central Newcastle.


There is a raised defence on the left-hand bank of the Ouseburn upstream of Bridge Park providing a standard of protection for a 1% AEP event.

The tidally influenced River Tyne forms the southern boundary to Newcastle. The Newcastle SFRA Study Area is included as Figure 1 below.

Figure 1 (Newcastle SFRA Study Area)

© Crown Copyright 100019569 (2009)


2 Understanding Flood Risk

2.1 Introduction

Flooding is a natural process and can happen at any time in a wide variety of locations. It constitutes a temporary covering of land not normally covered by water and presents a risk when people, infrastructure and development and environmental assets are present in the area which floods. Assets at risk from flooding can include housing, transport and public service infrastructure, commercial and industrial enterprises, agricultural land and the environmental and cultural heritage.

Climate change predictions are that flood risk will increase due to more frequent severe storms bringing higher intensity rainfall and increasing run-off from land and buildings. This will cause rivers and streams to experience higher than normal flood flows and levels, and sewers and drains to surcharge more frequently than at present. The focus of activity in meeting these challenges in the future will be on flood risk management as opposed to simply providing flood defences. It is now widely recognised that whilst we cannot always prevent flooding we can manage the risks of it happening and reduce the consequences when flooding does happen.

As authorities the EA and LPA, should embrace effective flood risk management issues and actions. The focus should aim to reduce flood risks through a variety on measures including:

� Through the planning process ensuring that vulnerable land uses are located away from high flood risk areas;

� Providing flood warning and emergency planning in flood risk areas; � Raising awareness of flood risks amongst vulnerable communities; � Constructing and maintaining appropriately designed surface water sewers and

culverts; � Using temporary and demountable flood defences and various flood prevention

systems to buildings where appropriate; � Constructing new flood defences where they are sustainable, and improving and

maintaining those already existing; and � Constructing weirs, sluices and other flood flow control and management

structures. Pro-active land use planning has a key role to play in flood risk management as it is one of the few activities that can result in the avoidance of flood risk as opposed to other activities that can only hope to reduce it. Effective flood risk management through the planning system is achieved through a hierarchy where:

� Avoidance of inappropriate development in high risk zones takes priority; � Substitution of lower vulnerability uses when avoidance is not considered

possible; and � Mitigation if avoidance and substitution are not possible, then mitigation of risks

using a variety of techniques may be considered. � Flood risk assessment at all levels of planning and for all major developments is

critical to inform decision-making by planners and developers.

2.2 Sources of Flooding

Flooding can occur from many different sources and may be experienced in isolation or as a combined flooding event. Different types and forms of flooding present a range of different risks. The associated hazards of speed of inundation, depth and duration of flooding can vary greatly (See Figure 2).


With climate change, the frequency, pattern and severity of flooding are expected to change and become more damaging with time.

Figure 2 (Flooding From Other Sources)

Major causes of flooding are:

� Coastal flooding is caused by higher sea levels than normal causing tidal water to overflow onto the land;

� Inland flooding is caused by prolonged and/or intense rainfall resulting in excess water flowing overland, ponding in natural hollows and low-lying areas or behind obstructions;

� River flooding occurs when the capacity of a watercourse is exceeded or a channel is blocked and excess water spills out from the channel onto adjacent low lying areas or floodplain;

� Flooding from artificial drainage systems occurs when flow entering a system, such as an urban storm water drainage system, exceeds its discharge capacity, it becomes blocked or it cannot discharge due to a high water level in the receiving watercourse;

� Groundwater flooding occurs when the level of water stored in the ground rises as a result of prolonged rainfall to ground level;

� Estuarial flooding may occur due to a combination of tidal and fluvial flows, with tidal levels being dominant in most cases; and

� A less frequent form of flooding arises from the failure of infrastructure designed to store or carry water (for example, the breach of a dam, a leaking canal or a burst water main), or to protect an area against flooding (e.g. breach of a flood defence, failure of a flap valve or pumping station or blockage of a pipe or culvert). Because of the sudden onset, the impacts of this form of flooding can be severe.

Prior to the major flood events in summer 2007, non Main River flooding was based on anecdotal evidence or described with Critical Ordinary Watercourse (COW) investigations undertaken by the Environment Agency. Little data could be abstracted from the water companies on sensitive drainage catchments where runoff impacts of new development


could be significant on combined sewer systems. However, a significant proportion of recent flood insurance claims are due to flooding from non main river sources, so this issue is likely to increase with a more energised climate.

Historically the adopted approach in many SFRAs has been not to consider other sources of flooding as a spatial or strategic issue. Through good design and attenuation of drainage inputs to sensitive watercourses, mitigation was the accepted way forward.

Summer 2007 provided a stark reminder that the significance of capacity exceedance of artificial and natural drainage systems can be severe for many communities. Therefore, a clear example was provided that flooding from all sources should be included in SFRAs, and that new methods of rapid screening of these risks are required. Following the Pitt Review, the EA has prepared a national map showing areas vulnerable to surface water flooding. This was developed by JBA from research into the Making Space for Water programme.

Increases in flooding impacting on people and property, due to development can be caused:

� Upstream by restricting the capacity and conveyance function of the watercourse and floodplain system;

� Downstream by decreasing the volume available for flood storage on the floodplain, altering flow routes on the floodplain or by changes to the channel which can increase the flow discharged to downstream locations; and

� By increasing runoff from reduced permeability surfaces, such as roads, roofs and car parks.

2.3 Flooding Likelihood & Consequence

Flood risk is generally accepted to be a combination of the likelihood of flooding and the potential consequences arising. It is assessed using the source – pathway – receptor model as shown in Figure 3 below. This is a standard environmental risk model common to many hazards and should be starting point of any FRA. However, it should be remembered that flood risk can occur from many different sources and pathways and not simply those shown in the simple form below.

Figure 3 (Source-Pathway-Receptor model)

The principal sources of flooding are rainfall or higher than normal sea and river levels, the principal pathways are rivers, drains, sewers, overland flow and river and coastal


floodplains and their defence assets. The receptors may include people, their property and the environment. All three elements must be present for flood risk to arise. Mitigation measures have little or no effect on sources of flooding but they can block or impede pathways or remove receptors.

The planning process is primarily concerned with the location of receptors, taking appropriate account of potential sources and pathways that might put those receptors at risk.

It is important to define the components of flood risk in order to apply this guidance in a consistent manner.

2.3.1 Likelihood

Likelihood of flooding is normally expressed as a percentage probability based on the average frequency measured or extrapolated from records over a large number of years. A 1% probability indicates the flood level that is expected to be exceeded on average once in 100 years, i.e. it has a 1 in 100 chance of occurring in any one year.

Considered over the lifetime of development, such an apparently low frequency or rare flood has a significant probability of occurring.

2.3.2 Consequences

Consequences of flooding depend on the hazards caused by flooding (depth of water, speed of flow, rate of onset, duration, wave-action effects, water quality) and the vulnerability of receptors (type of development, nature, e.g. age and structure, of the population, presence and reliability of mitigation measures etc).

Flood risk is then normally expresses in terms of the following relationship:

� Flood risk = Probability of flooding x Consequences of flooding 2.3.3 Flooding Impacts on Property, People & the Environment

Flood impacts maybe direct or indirect, immediate or long-term and may affect households and communities, individuals as well as the environment, infrastructure and economy of an area.

2.3.4 Flooding Impacts on People

Flooding has a wide range of social impacts which may be difficult to delineate as they are interconnected, cumulative and often not quantifiable.

In small urban or steep upland catchments which have a very rapid response to rainfall, or with flooding due to infrastructure failure, flood waters can rise very quickly and put life at risk. Even shallow water flowing at 2m/s can knock children and many adults off their feet and vehicles can be moved by water of 300mm depth. The risks rise if the flood water is carrying debris.

The impact on people as a result of the stress and trauma of being flooded, or even of being under the threat of flooding, can be immense. This also extends to whole communities. Long term impacts can arise due to chronic illnesses and stress. Flood water contaminated by sewage or other pollutants (e.g. chemicals stored in garages or commercial properties) is particularly likely to cause such illnesses, either directly as a result of contact with the polluted flood water or indirectly as a result of sediments left behind.

The degree to which populations are at risk from flooding is, therefore, not solely dependent upon proximity to the source of the threat or the physical nature of the flooding. Social factors also play a significant role in determining risk. Although people may experience the same flood, in the same area, at the same time, their levels of suffering are likely to differ greatly as a result of basic social differences. These differences will affect vulnerability in a variety of ways including an individual's or community’s response to risk communication (flood warning) and physical and psychological recovery in the aftermath of a flood. How individuals and communities experience the impact will also vary


depending on their awareness of the risk of flooding, preparedness for the flood event and the existence or lack of coping strategies.

2.3.5 Flooding Impacts on Property

Flooding can cause severe property damage. Flood water is likely to damage internal finishes, contents, electrical and other services and possibly cause structural damage. The physical effects can have significant long-term impacts, with reoccupation sometimes not being possible for over a year. The costs of flooding are increasing, partly due to increasing amounts of electrical and other sophisticated equipment within developments.

The damage flooding can cause to businesses and infrastructure, such as transport or utilities like electricity and water supply, can have significant detrimental impacts on local and regional economies. The long-term closure of businesses, for example, can lead to job losses and other economic impacts.

Placing new development or regenerating in flood risk areas has its additional short and long-term costs. The need to build resistant and resilient properties could significantly increase overall costs of development, whilst ongoing maintenance and insurance increase future expenditure.

2.3.6 Flooding Impacts on the Environment

Environmental impacts can be significant and include soil erosion, bank erosion, landslips and damage to vegetation as well as the impacts on water quality, habitats and flora and fauna caused by bacteria and other pollutants carried by floodwater.

Flooding can have a beneficial role in natural habitats. Many wetland habitats are dependent on annual flooding for their sustainability and can contribute to the storing of flood waters to reduce flood risk elsewhere. It is important to recognise the value of maintenance or restoration of natural riparian zones such as grasslands which protect the soils from erosion and ‘natural’ meadows which can tolerate flood inundation. The use of Green Infrastructure throughout the river corridor can also play a vital role in enhancing the river environment as well as safeguarding land from future development, protecting people and buildings from flooding and reducing flood risk downstream.

A natural floodplain can help accommodate climate change and improve the quality of rivers and associated wetlands to help achieve ‘good ecological status’ by 2015 under the Water Framework Directive (WFD). Meeting WFD objectives involves not only ecosystems, water quality, drought and flood impact considerations but also the physical characteristics and morphology of the river channel, floodplain and associated structures.


3 The Sequential Approach

3.1 Introduction

The SFRA is a planning tool that is used to inform the spatial planning and development management process. It helps to ensure new development is appropriate and that developments are sustainable. Due to the need for growth, regeneration and inward investment, suitable development land has to be identified and its land use changed where necessary, in order to meet this demand.

This is achieved using a hierarchical approach to risk management as stated within PPS25 by the sequential approach to land allocation, by first avoiding development in flood risk areas wherever possible. Where this is not possible then the vulnerability of the proposed land use to flooding should be considered and substitution of lower vulnerable developments in high flood risk areas must be carried out. Finally mitigation measures taken to minimise flood risk to people, property and the environment should be considered. Spatial planning is the greatest contribution to the long-term reduction in flood risk and is the focus of the risk-based sequential approach.

The sequential approach is governed by two tests, the Sequential and Exceptions Test. Consideration of flood risk to people and development must be considered by the LPA at the earliest stage of spatial planning decisions and these tests allows transparent application of the process.

3.2 The Sequential Test

PPS25 provides the basis for the Sequential Approach and the associated Practice Guide explains how to implement PPS25. It recommends that LPAs use a risk-based approach to development planning and specifies the need for undertaking RFRAs and SFRAs. The SFRA provides a framework to undertake both the Sequential and Exception Tests as part of the sequential approach.

The Flood Zone Map provides the foundation of the Sequential Test, according to PPS25,

“The overall aim of decision makers should be to steer new development to Flood Zone 1. Where there are no reasonably available sites in Flood Zone 1, decision makers identifying broad locations for development and infrastructure, allocating land in spatial plans or determining applications for development at any particular location should take into account the flood risk vulnerability of land uses and consider reasonably available sites in Flood Zone 2, applying the Exception Test if required. Only where there are no reasonably available sites in Flood Zone 1 or 2 should decision makers consider the suitability of suites in Flood Zone 3, talking into account the flood risk vulnerability of land uses and applying the Exception Test if required.”

The LPA will be required to prioritise the allocation of land for development in ascending order from Flood Zone 1 to 3, including the subdivisions of Flood Zone 3, if necessary. The EA has statutory responsibility and must be consulted on all development applications allocated within medium and high risk zones, including those in areas with critical drainage problems and for any development on land exceeding 1 hectare inside Flood Zone 1. In these circumstances, the EA will require the LPA to demonstrate that there are no reasonable alternatives, in lower flood risk categories, available for development.

One of the limitations to the Sequential Test is that it is solely based on Flood Zones and according to PPS25, those developments proposed in any of the three Flood Zones must take account the likelihood of flooding from other sources and the same principles of the Sequential Approach must be applied. However, this is difficult as information on the probability of other forms of flooding is not always available. This can make the Sequential Approach difficult to carry out.

It is recommended in this SFRA that a Sequential Testing process is applied. If carried out appropriately at a spatial planning level it will ensure a cost-effective use of time and


resources by the LPA and the EA. This will be achieved by avoiding inappropriate development in flood risk areas and minimising the number of development proposals needing to be subjected to the Exception Test. The Sequential Test Process is included as Figure 4 below.

Figure 4 (Sequential Test Process)

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Decision makers, such as spatial planners and development control, should use the Flood Zone Map produced in the SFRA as a first sweep of the Sequential Test as required in PPS25. This will allow inappropriate sites to be identified and removed. This should be carried out a number of times to identify and remove inappropriate development.

To help aid the Sequential Test a suite of Strategic Flood Risk Maps have been produced for this SFRA. These provide a greater resolution and understanding of flood risk. These maps should be used as further sweep of the Sequential Test by considering flood risk from all sources, and if required, its mitigation through each tier. The Sequential Testing process comprises seven key stages with each designed to remove the development allocations at an early stage where the scale of risk is considered unsustainable or unsafe.

Figure 4 identifies how to avoid inappropriate development in flood risk areas by using the Sequential Testing process and as a result, the hierarchical approach to risk management.

It is also a recommendation of this SFRA that the Sequential Testing process is carried out at a local or community level especially when it comes to identifying and substituting more vulnerable development in land outside of flood risk areas. By doing this the aim of the Sequential Test can still be achieved as well as the LPA meeting their own housing development targets within town centres of specific areas that have been identified for regeneration.

Further information on the EA's requirements for Sequential Testing can be found at http://www.environment-agency.gov.uk/research/planning/93498.aspx

3.3 Individual Planning Applications

The Sequential Testing process has focused on those development allocations which have been identified by the LPA in their LDDs. However there will be circumstances where the Sequential Test will have to be applied to individual planning applications. In every case it must be seen as best practice to search for alternative sites appropriate for the type and function of development in lower flood risk areas before considering the vulnerability of proposed development and applying the Exception Test. There are two types of development in which the Sequential Test must be applied. These include:

� Windfall sites � Sites within existing redevelopment or regeneration areas (this is an important

distinction (refer to the Practice Guide section 4.35 for further details). Where sites have not been sequentially tested by the LPA, the Sequential Test will need to be applied at the individual site level i.e. the developer will need to provide evidence to the LPA that there are no other reasonable available sites appropriate for the type of development considered where the development could be located and the LPA will carry out the Sequential Test. No applicant is to Sequentially Test windfall sites. According to PPS25, as part of this evidence the planning application must include:

� Flood risk to the site, using data provided within this SFRA; � Availability of ‘reasonably available’ sites in the relevant area within a lower flood

risk that could be used for the development - this SFRA and already sequentially tested sites should provide this evidence;

� The vulnerability classification of the development; � Assessment as to the likelihood that the Exceptions Test will need to be applied;

and � That the development will be safe and residual flood risks can be overcome to the

satisfaction of the Environment Agency and other stakeholders. On completion of this SFRA, the LPA should develop policies in their LDDs on how windfall sites should be treated in terms of flood risk. Sequentially tested sites should help the LPA identify where windfall development would be appropriate. This may remove the need for individually sequentially testing windfall sites within these locations. Where this has not been carried out, other sites allocated as suitable for housing should be considered as part of the development proposals.


All development on previously developed land still requires the application of the Sequential Test. Where redevelopment is ongoing, as part of an existing regeneration strategy in Flood Zones 2 or 3, it has to be accepted that the redevelopment cannot always be relocated and it will very likely pass parts a) and b) of the Exception Test. In this case flood risk must be considered at the earliest stage of the regeneration strategy which should create opportunities to reduce flood risk to the community. This may still mean locating more vulnerable development in lower flood risk areas or removing some redevelopments in order to increase flood storage or flow routes as these approaches may benefit the wider regeneration strategy.

According to PPS25 it will be difficult to consider alternative sites for some redevelopments, including:

� Redevelopment of an existing single property; and � Changes of property use.

Whilst the site will not be subjected to the Sequential Test, the planning application must state why. However the site will still need to pass the Exceptions Test and the sequential approach to site layout should also be considered. PPS25 states that,

“Changes of use should not be subjected to the Sequential and Exceptions Tests.”

However the site will still need to meet the requirements of a site-specific FRA as the vulnerability of the site may change and as such it must meet the objectives of PPS25 in keeping the development safe.

3.4 Flood Risk Vulnerability Classification

Flood risk vulnerability classifications are provided in Table D.2 of PPS25 and Appendix C of this report. These provide recognition that not all land uses have the same vulnerability to flooding. Some land uses such as residential developments are more vulnerable to the potential loss of life and damage to personal property and possessions than say shops and offices. Five flood risk vulnerability classifications are contained in PPS25 and these are:

� Essential infrastructure � Highly vulnerable � More vulnerable � Less vulnerable � Water compatible development.

3.4.1 Flood Zone 1 – Low Probability

From a flood risk perspective all land uses are acceptable within Flood Zone 1. Flood risk is not considered to be a significant constraint to development and all land uses listed below are appropriate in this zone.

� Essential infrastructure � Highly vulnerable � More vulnerable � Less vulnerable � Water compatible development.

A Screening Study, as per PPS25 Practice Guide, will be required for development in this zone. This will determine whether further assessment of flood risk is required. This will take account of historical flood records of localised flooding, site specific considerations and the surface water proposals for the development, including mitigation.

However, due to their potential impact on the local flood risk, a full FRA will be required for all developments greater than 1ha in size. This will include further consideration of surface water drainage and onsite mitigation measures that may be required, particularly where the capacity of the surface water sewer or receiving watercourse is limited. This


assessment will be undertaken by the developer of the site and should be appropriate to the scale, nature and location of the development. The Council’s Drainage Engineers and the EA will be able to advise potential developers as to their specific requirements on a site by site basis.

3.4.2 Flood Zone 2 – Medium Probability

Subject to the application of the Sequential Flood Risk Test, PPS25 specifies suitable types of development in Flood Zone 2 as:

� Essential infrastructure � More vulnerable � Less vulnerable � Water compatible development.

Highly vulnerable uses should only be permitted in this zone if the Exception Test is passed. The SFRA is unable to assess whether the site will pass parts a. and b. of the Exception Test. However, the Council must be able to demonstrate the need for development through the spatial planning process.

An FRA will be required for all development in this zone. The FRA will need to assess the current level of flood risk as well as the level of flood risk following development. Development plans for the site will need to demonstrate that flood risk can be effectively and safely managed without increasing flood risk elsewhere.

Proposals will also need to demonstrate that access and egress to the development can be maintained during an extreme flood event and that development is set at an appropriate level. A further level of analysis may be required where development is planned behind or adjacent to existing defences in order to test the sustainability and robustness of the mitigation measures. In keeping with Flood Zone 1 other flood risk constraints, such as incidents of localised flooding and other site-specific considerations will need to be addressed. Again, detailed FRAs will be undertaken by the developer of the site and the EA will be able to advise potential developers as to their specific requirements on a site by site basis. The FRA will need to address part c. of the Exceptions Test and should only be commenced when the planning justification is clearly established.

3.4.3 Flood Zone 3 – High Probability

A Sequential Flood Risk Test is used to prioritise sites in order of vulnerability to flood risk and their acceptability for development. Developers should primarily focus on lower Flood Zones in preference to Flood Zone 3. Any proposals for development within Flood Zone 3 will require developers to undertake a detailed FRA. It should be noted that constraints to development are likely to be significant and developers should seek advice from the Council and the EA as to the specific requirements for assessment.

Flood Zone 3 is subdivided into Zones 3a and 3b. Flood Zone 3b is the portion of floodplain that provides natural and/or managed attenuation. It can be all or part of the flow area and owing to the frequency of inundation, Zone 3b areas are considered to be Functional Floodplain. Urban areas are generally considered to be Zone 3a, so for the purpose of this SFRA, Brownfield sites will be assumed Zone 3a.

Zone 3a is potentially suitable for water-compatible and less vulnerable land uses. The more vulnerable and essential infrastructure uses should only be permitted in this zone if the Exception Test is passed. Highly vulnerable development should not be permitted in this zone.

In Zone 3b, only essential infrastructure (subject to Exception Testing) and water-compatible uses may be permitted.

Where sites are partially located within Flood Zone 3b, it is recommended that Council should avoid development by specifying water-compatible uses or public open space for these areas.


Land use vulnerability classifications and flood zones are carried forward into Table D.3 for application of the Exception Test.

3.5 The Exception Test

Where new development is exceptionally necessary within areas at risk of flooding, Government policy aims to make it safe without increasing flood risk elsewhere and where possible reducing overall flood risk. This is in accordance with paragraph 19 of PPS25, which states:

“The Exception Test is only appropriate for use when there are large areas in Flood Zones 2 and 3, where the Sequential Test alone cannot deliver acceptable sites, but where some continuing development is necessary for wider sustainable development reasons, taking into account the need to avoid social or economical blight and the need for essential civil infrastructure to remain operational during floods…”

PPS25 explains where and for what type of development the Exception Test needs to be applied. In some situations, for certain types of development, it is not appropriate to use the Exception Test to justify development. For example, highly vulnerable development cannot be justified within the high risk zone through the use of the Exception Test.

Figure 5 shows flood risk vulnerability and flood zone compatibility, indicating situations where it is necessary and appropriate to apply the Exception Test, the Exception Test must not be used to bypass the Sequential Test.

Figure 5 (Where the Exceptions Test Applies)

Category Zone EI HV MV LV WC 1 2 3a 3b

EI = Essential Infrastructure, HV = Highly Vulnerable, MV – More Vulnerable, LV – Less Vulnerable, WC = Water Compatible

Denotes that development would be permitted. An FRA would be

required in Zones 2 & 3 and may be required in Zone 1 sites Denoted where Exception Test is required

Denotes that development should not be permitted in this zone


There are three stringent conditions, all of which must be fulfilled before the Exception Test can be passed. These conditions (see paragraph D9 of PPS25) are as follows:

� It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a SFRA where one has been prepared. If the LDD has reached the ‘submission’ stage (see Figure 4.1 of PPS12: Local Development Frameworks) the benefits of the development should contribute to the Core Strategy’s Sustainability Appraisal (SA);

� The development must be on developable previously-developed land or, if it is not on previously-developed land, that there are no reasonable alternative sites on developable previously-developed land; and

� A site-specific FRA must demonstrate that the development will be safe, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall.

The Level 1 SFRA provides sufficient information to complete the Sequential Test in terms of flood risk. However, it can only provide information on where it will be necessary to complete the Exception Test and areas where part C of the Exception Test is most likely to be met. It will not provide sufficient information to complete the Exception Test. To pass part C more detailed assessment of risk will still be required. Only on completion of the Sequential Test should the Exception Test be used to justify allocations or developments in high risk areas.

Whilst the SFRA has been undertaken in conjunction with the EA, it is likely they will object to some of the more vulnerable sites, and may maintain objections to these on site specific flood risk grounds unless sufficient information can be provided to show the risks can be safely mitigated in the design.

This is a matter of detail that cannot be addressed in a Level 1 SFRA, however, elements that will need to be considered in the delivery of the Exception Test include:

� Will the development be safe? Can all the risks be designed out and can the residual risks to people and property be managed by an emergency plan or by limiting the type of land use?

� Will the site be deliverable? This involves a review of economic and design aspects, together with an understanding of how complicated the assessment will need to be and how “exceptional” the development would need to be.

� How well does the development fit with the current mix of land uses and future provision of flood management measures? Can development within the policy area reduce flood risk to other areas; will it require further more expensive provision of flood defence infrastructure?

3.6 How to assess a proposal is safe?

PPS25 requires that where development is permitted in flood risk areas that it is safe, for the lifetime of development, taking into account climate change.

The most effective way of making development safe is firstly by avoiding development in flood risk areas. However, if development has first gone through the Sequential Test sieving process and passed Part a) of the Exceptions Test, then the development must be viewed as an essential part of that community's redevelopment or regeneration strategy and therefore relocation would be difficult. It is the aim of a site-specific Flood Risk Assessment (FRA) to assess whether the development can be designed to be sustainable and safe.

According to PPS25, “When considering safety, specific local circumstance need to be taken into account, including:

� The characteristics of a possible flood event, e.g. the type and source of flooding and frequency, depth, velocity and speed of onset;


� The safety of people connected with the development. This should cover both the safety of people within the building if it floods and also the safety of people in adjacent areas. This includes the ability to safely access and exit the building and the ability of the emergency services to evacuate or rescue people;

� The structural safety of the building; and � The impact of a flood event on the service provided by the development, e.g.

water, electricity and fuel supplies. “

3.7 Levels of Flood Risk Assessment

Within the hierarchy of regional, strategic and site-specific FRA, a tiered approach ensures that the level of information is appropriate to the scale and nature of the flood-risk issues and the location and type of development proposed, avoiding expensive flood modelling and development of mitigation measures where it is not necessary. As stated in PPS25 the three principal levels of assessment comprise:

� Regional Flood Risk Appraisal (RFRA) – a broad overview of flood risk issues across a region to influence spatial allocations for growth in housing and employment as well as to identify where flood risk management measures may be required at a regional level to support the proposed growth;

� Strategic Flood Risk Assessment (SFRA) – an assessment of all types of flood risk informing land use planning decisions. This will enable the LPA to apply the Sequential Test in PPS25 and allocate appropriate sites for development, whilst identifying opportunities for reducing flood risk; and

� Site-specific Flood Risk Assessment (FRA) – site or project specific flood risk assessment to consider all types of flood risk associated with the site and propose appropriate site management and mitigation measures to reduce flood risk to and from the site to an acceptable level.

In a plan-led system, implementation of the sequential risk-based approach requires that forward planning policy decisions in RSSs and LDF/LDDs are guided by information on flood risk to ensure that allocating inappropriate development does not unnecessarily raise expectations of landowners and developers. This should be achieved through the use of RFRAs and SFRAs, which are generally broad-brush assessments of the risk of flooding, to guide strategic planning decisions. They involve the collection and collation of data on flooding and flood risk management from all available sources to provide information to the necessary level of detail to allow decision makers to:

� Prepare appropriate policies for flood risk management within RSSs and LDFs; � Produce a strategic understanding of the scale, extent and nature of the flood risk

at a community level and how that would alter with any proposed development; � Apply a risk-based, sequential approach, providing risk data to inform the

Exception Test and to confirm the compatibility between the flood risk vulnerability of the proposed allocation and the Flood Zone;

� Inform the strategic environmental assessment of RSSs and LDFs; � Translate national guidance into locally specific guidance, including the

identification of areas of floodplain that should be safeguarded for flood management purposes;

� Identify the level of detail required for site-specific FRA in particular locations; and � Determine the acceptability of flood risk in relation to emergency planning

capability and how the existing and proposed community would respond to a flood event.

3.8 Level 1 Strategic Flood Risk Assessment

A Level 1 SFRA should be sufficiently detailed to allow the application of the Sequential Test and to identify whether the Exception Test is likely to be necessary. Existing data


should be used to make an assessment of flood risk from all sources now and in the future.


4 Data Sources

4.1 Flood Zone Map

The EA Flood Zone Maps indicate areas of land that are susceptible to either fluvial or tidal flooding. These maps have been prepared in a consistent manner across the country. They show the likely extent of flooding for both the 1% (0.5% if tidal) and 0.1% annual exceedance probability (AEP) flood events.

The Flood Zone Maps were prepared using methodology based on the national digital terrain model (NextMap), calculated river flows (using Flood Estimation Handbook techniques (FEH)) and two-dimensional flood routing. The extent of flooding has been further adjusted to take historical flooding events and more detailed flood mapping studies into account. In the Newcastle area the majority of fluvial and tidal Flood Zones have been updated to include the results of detailed flood mapping studies.

The Flood Zone Maps offer a precautionary approach to defining the extent of flooding. This is because they do not take the flood-limiting effects of defences into account, as these structures may fail or be overtopped. The extent of flooding shown on the Flood Zone Maps tends, therefore, to represent a worst-case scenario for each design event.

It should also be noted that the Flood Zone Maps do not include consideration of climate change or other sources of flooding, such as ground water and surface water.

4.2 Delineation of Low Risk Zone 1

PPS25 divides the country into Flood Zones 1, 2 and 3. These Flood Zones correspond to areas of low flood risk, medium flood risk and high flood risk respectively.

PPS25 considers areas within Flood Zone 1 to be at low risk to flooding. The annual probability of flooding within this area is less than 0.1%. This zone can easily be identified on the Flood Zone Maps as areas of land located outside either Flood Zone 2 or 3. In general, Flood Zone 1 is considered suitable for all development.

4.3 Delineation of Medium Risk Zone 2

Areas within Flood Zone 2 are considered to be at medium risk of flooding. The annual probability of fluvial flooding within this area is between 0.1% and 1% (0.5% and 0.1% if within tidally influenced areas of flooding). In general, Flood Zone 2 is considered suitable for most development except highly vulnerable land uses, such as police, fire and ambulance stations, where Exception Testing is required.

4.4 Delineation of High Risk Zone 3

PPS25 considers areas within Flood Zone 3 to be at high risk of flooding. Flood Zone 3 is divided into sub-zones 3a and 3b. Both sub-zones are areas at high risk of flooding with area 3b defining the functional floodplain. In general, development within lower flood risk zones should be considered before development in Flood Zone 3.

� Flood Zone 3a is defined as land susceptible to flooding during the 1% annual probability of flooding (or 0.5% if tidal).

� Flood Zone 3b is the functional floodplain and is defined as land where water has to flow or be stored in times of flood.

4.5 Delineation of the Functional Floodplain

PPS25 considers areas of functional floodplain to comprise land within Flood Zone 3 where water has to flow or be stored in times of flooding. The 5% annual probability flood event is used as the baseline for defining functional floodplain. However, a higher


probability can be used where appropriate, depending on catchment characteristics, available modelling and with agreement between the LPA and the EA.

SFRAs can also be used to identify areas where it may be appropriate to extend the 5% flood outline to include areas within Flood Zones 2 and 3 in order to restore or enhance the flood water storage potential of functional floodplain areas. The ability to safeguard large areas of land against future development, in both urban and rural areas, means that existing open spaces may be safeguarded for flood storage. This approach could potentially reduce downstream flood risks and contributes to the policy aims, identified in table D.1 of PPS25, which include:

� “Reduc(ing) the overall level of flood risk in the area through the layout and form of the development and the appropriate application of sustainable drainage systems, and;

� Creat(ing) space for flooding to occur by restoring functional floodplain and flood flow pathways and by identifying, allocating and safeguarding open space for flood storage.”

In order to achieve this, the SFRA needs to be integrated with CFMPs and other catchment-scale strategies that aim to protect floodplain and avoid inappropriate development in high risk areas.

4.6 Flood Defences

Defended areas are those areas that are protected to some degree against flooding by the presence of formalised flood defences. However, land behind these defences is still considered to be at risk of flooding and is shown as such on the Flood Zone Maps. The EA’s National Flooding and Coastal Defence Database (NFCDD) provides information on existing defences in Newcastle, in terms of their structure and condition rating.

Areas Benefiting from Defences (ABDs) have also been provided. ABDs are those areas which benefit from formal flood defences in the event of flooding. The EA have confirmed that there are no ABDs in the Newcastle area.

4.7 Hydraulic Modelling Studies

The majority of rivers throughout the Newcastle area have been assessed using detailed hydraulic models. These comprise:

1. River Tyne & Derwent FRM Study (2005)

2. River Tyne Estuary Model (2007)

3. The Ouseburn Flood Study (2002) and model update (2006) comprising:

Crag Hall Dene, Forest Hall Letch, Golf Club Tributary, Gosforth Letch, Harey Dene, Killingworth Letch Kingston Park Tributary, Longbenton Tributary, Town Moor Drain, West Moor Tributary and Whorlton Hall Branch

4. Seaton Burn S105 Phase 1 Study (2001)

4.8 Historical Flooding

Historical flooding data was provided by key stakeholders during the SFRA consultation process. The general location of historical flooding events, from all sources of flooding, was provided by the EA, Newcastle City Council and Tyne and Wear Fire and Rescue Service (TWFRS). Information on the status of surface water drainage system was provided by Northumbrian Water.

There is little evidence of flooding on smaller watercourses within Newcastle and the majority of historical events tend to be associated with surface water flooding.

Dredging of the River Tyne upstream of the Newcastle bridges was discontinued in the late 1960s, and it is understood that natural siltation is occurring, albeit slowly.


5 Flood Risk in Newcastle

5.1 Introduction

This section of the SFRA focuses on assessing the implications of flood risks to the Newcastle City Council area. All sources of flood risk are considered including the long term impacts of climate change. The River Tyne and the Ouseburn, including its tributaries, are the principal watercourses in Newcastle.

Water levels along the River Tyne are primarily dependent on tide levels and the tidal cycle. The River Tyne is tidally influenced throughout the Newcastle area. It is considered unlikely that any land use changes along the River Tyne could have a significant impact on tidal flood levels.

Areas of land along the Ouseburn and its tributaries have been known to flood or, in accordance with the Flood Zone Maps, are at significant risk of flooding. Land use changes within these areas may alter conveyance and storage characteristics. This may potentially increase localised flood risk and demonstrates the need for the Council and the EA to work together on development and flood risk management issues.

As well as carefully planning and controlling development, Newcastle City Council needs to implement a robust approach to surface water management that controls surface water runoff from new and existing development. In addition, consistent regional development policies to manage runoff and development throughout the Tyne and Wear area in general, are required.

5.2 Tidal Flood Risk

For Newcastle, the risk of tidal flooding is caused by high tides or storm surges in the North Sea, generating extreme water levels within the estuary. Estuarine flooding can be complex and difficult to predict as flood levels are also influenced by the volume of water flowing down the river at any time during the tidal cycle.

Extreme tidal levels, included as Table , were calculated in the Rivers Tyne and Derwent FRM study in 2005 for the years 1990 and 2004.

Table 1 (Extreme tidal level estimates for North Shields2)

Return Period / Tidal Level 1 10 25 50 100 200 250 500 1000

Level (1990) m AOD 3.20 3.53 3.68 3.77 3.92 3.98 4.06 4.13 4.23

Level (2004) m AOD 3.23 3.56 3.71 3.80 3.94 4.01 4.09 4.16 4.27

5.3 River Tyne

Apart from a few locations, water levels are contained within the river channel throughout the Newcastle area. The River Tyne is, therefore, capable of containing water levels associated with the 0.1% design event. Where flooding does occur the Council will need to review any development proposals identified within these locations.

Fluvial flooding is caused by high flows in rivers or streams exceeding the capacity of the river channel and spilling onto the floodplain. The main source of flooding to residential development is associated with the Ouseburn system.


5.4 Flooding From Land

Flooding in urban areas can occur from a variety of sources. The Floods and Water Management Bill (2010) defines local flood risk, for which local authorities will have a leadership role, as the risk of flooding from ordinary watercourses, surface water and ground water.

Flooding of land from surface water runoff is usually caused by intense, short duration, rainfall events. Surface water follows topography, creating flow paths along roads, through areas of development and rural landscape. Surface water flow paths often coincide with fluvial floodplains in low-lying areas.

Flooding in urban areas can also be attributed, in part, to sewer systems. Sewers are generally designed to a 1 in 30 year design standard and flooding from sewers will occur during higher magnitude events or when sewers become blocked or fail.

The summer flooding of 2007 highlighted the widespread damage and disruption that can be caused by surface water flooding. Both Making Space for Water (2005) and Future Water (2008) recognise the importance of integrated urban drainage. The Foresight Report (2004) estimated that 80,000 properties are at very high risk from surface water flooding (1 in 10 chance of occurring in any one year).

The EA has recently produced a national Surface Water Flood Map, which identifies areas vulnerable to surface water flooding during an extreme rainfall event. This Map is separated into areas at less, intermediate or high risk of surface water flooding. Surface water mapping is based on topography and includes allowances for sewer capacity.

SFRAs provide the opportunity for the Council to assess, at a strategic level, the risk associated with multiple sources of flooding. This information can be used as the focus for more detailed assessment as well as the identification of Critical Drainage Areas (CDAs).

CDAs are those areas that have significant risks of surface water flooding. Recommendations can then be made for the future provision of Surface Water Management Plans (SWMPs) in high risk locations, or areas where significant development is planned.

5.5 Screening For Critical Drainage Areas

Screening for CDAs within the Newcastle area was undertaken using data from the following sources:

� Newcastle City Council and TWFRS incident records; � Recommendations from Newcastle City Council’s Drainage Engineers, and; � The National Surface Water and EA Flood Zone Maps.

The Surface Water Flooding Map indicates properties at risk within areas of surface water flooding. The maps also indicate areas of historical flooding. Critical Drainage Areas are discussed further in Section 7.

5.6 Flooding From Sewers

Northumbrian Water are required to maintain a register of flooding incidents from the public sewer network. This database identifies properties where flooding has occurred on a frequency of 1 in 5 years and 1 in 10 years, known as DG5 and DG10 registers.

Northumbrian Water has proposed in their report, ‘What Customers can Expect in 2005-102’, to either remove or provide mitigation measures that reduce the risk of flooding for all properties on the DG5 register by the end of 2009/10. Northumbrian Water has

2 Northumbrian Water (2005) What Customers can expect in 2005-10


approximately 1.2 million properties on the register and is aiming to have no more than 76 properties remaining by the end of 2009/10.

Whilst this data can give an idea of those areas with limited drainage capacities, it should be acknowledged that it is a register of properties that have flooded due to the hydraulic inadequacies of the sewer systems. Its usefulness in terms of predicting future flooding is, therefore, limited.

Northumbrian Water drainage areas have been provided for North Tyneside and indicate the risk rating of each area as Red, Amber and Green. The risk rating of each drainage area has been calculated by Northumbrian Water using DG5 records. The original DG5 data, used to quantify and locate the instances of flooding, have not been provided for this Level 1 SFRA.

The mapping may be used to identify those general areas more susceptible to sewer flooding. Whilst this does not necessarily mean that there are drainage problems within the area it should be used as a starting point for further consultation with Northumbrian water, Newcastle City Council and the EA.

New large scale development will need to connect to the current drainage network, which could already have capacity issues. Adding further pressure on the system could place that new development site at risk of flooding and exacerbate the issue to the surround community.

5.7 Flooding from Groundwater

Groundwater flooding is caused by water emerging from the ground at either point or diffuse locations. The occurrence of groundwater flooding is usually localised and because of the slow rate at which water levels rises, does not generally pose a significant risk to life.

Groundwater flooding can persist over a number of weeks and poses a significant, if localised, issue that has attracted an increasing amount of public concern in recent years. In most cases groundwater flooding cannot be easily managed or lasting solutions engineered.

5.8 Flooding from Reservoirs & other Artificial Sources

Whilst the probability of dam or embankment failure is small, the consequences of such an event occurring may be significant particularly if located in an urban setting. The EA is currently producing simplified inundation maps for all reservoirs under the Reservoirs Act as required by Recommendation 57 of the Pitt Review.

According to the EA’s Register of Reservoirs, there are no large raised reservoirs located within Newcastle City Council’s boundaries or surrounding council areas.

5.9 Effects of Climate Change - Peak Tidal Levels

Peak tidal levels for a range of return periods have been taken from the 2005 River Tyne model. A summary of these results is included as Table 2.

Table B.1 of PPS25 gives recommended allowances for net sea level rise to 2115. The 2005 levels were extrapolated using the Defra guidance provided in PPS25 to 2009, 2050 and 2100.


Table 2 (Effect of sea level rise on water levels in the Tyne Estuary)

Return Period Tidal Levels (m AOD)

2005 2009 2050 2100

1 in 10 years 3.56 3.57 3.79 4.37

1 in 25 years 3.71 3.72 3.94 4.52

1 in 50 years 3.80 3.81 4.03 4.61

1 in 100 years 3.94 3.95 4.17 4.75

1 in 200 years 4.01 4.02 4.24 4.82

1 in 1000 years 4.27 4.28 4.50 5.08

Note: 2005 levels were obtained from Tyne & Derwent HEC-RAS model (2005). Climate change levels calculated using values from Table B.1 of PPS25 as a basic assessment of the potential effect of climate change.

UKCIP02 scenarios also suggest that winters will become wetter over the whole of England by as much as 20% by 2050. A shift in seasonal rainfall patterns is also expected, with summer and autumn months becoming drier than at present. The amount of snowfall is expected to decrease significantly throughout the UK, however, average rainfall intensities are expected to increase.

Rainfall intensity and the increase in the number of days when it is raining could have significant implications for surface water flooding and should be considered when assessing the requirements for drainage systems associated with new developments. A summary of the recommended national precautionary allowances for peak rainfall and river flows, in accordance with Table B.2 of PPS25, is included as Table 3.

Table 3 (PPS25 Table B.2: Recommended national precautionary sensitivity ranges for peak

rainfall intensity, peak river flows, offshore wind speeds and wave heights)

Parameter 1990 to 2025

2025 to 2055

2055 to 2085

2085 to 2115

Peak rainfall intensity +5% +10% +20% +30%

Peak river flow +10% +20%

Offshore wind speed +5% +10%

Extreme wave height +5% +10%

5.10 Effects of Climate Change - Fluvial Flood Levels

It is estimated that peak flow rates for fluvial flood events are likely to increase by 20% over the next 50 to 100 years and the increased volume of flood water will result in higher flood levels.

5.11 Functional Floodplain Predictions for Newcastle

Outlines for the functional floodplain (Zone 3b) have been derived from available modelling data for Newcastle. For the Ouseburn and its tributaries the outlines are based on the Ouseburn Flood Study model results (JBA 2006). This study included assessment of a range of flood scenarios ranging from the 2 year to 1000 year flood events and the 1% outline generated during this study is the current EA Flood Zone 3b for this SFRA has incorporated the 4% modelled outline as a representation of the Flood Zone 3b areas for the Ouseburn system.


Climate change impacts for the River Tyne have been assessed using model results for the 5% (20 year) design scenario. Only a few highly localised areas along the river bank are classified as functional floodplain.

Comparison of Flood Zones 2 and 3 for the River Tyne through Newcastle indicates that there is little variation between the extents of flooding. Bank levels are, in general, high enough to contain flood water from the River Tyne during the 0.1% event, far in excess of the functional floodplain scenario.

The extent of Flood Zones 2, 3a and 3b are included as Drawing 2009s0275-D01 (PPS25 Flood Zone Map Overview Map).

5.12 Geology & Soils

The underlying geology and soils data for Newcastle was reviewed using strategic scale (1:250,000) mapping. The soils map for the area is available from the National Soil Research Institute: http://www.landis.org.uk/soilscapes/

According to the soils map the Newcastle area is, in general, underlain by slowly permeable clay soils which tend to impede natural drainage. During periods of heavy rainfall the subsoil tends to become waterlogged.

The quality and, hence, suitability of this information is not considered appropriate for use at site-specific levels and can only be used to provide an early indication of the low potential for infiltration drainage.

Geology and soils should be investigated at a site level during development of a drainage strategy for development. The application of SUDs should be explored at the earliest stage of all developments.

5.13 Flood Defences

Defended areas are protected to some degree against flooding by the presence of formalised flood defences. However, land behind these defences is still considered to be at risk of flooding and is shown as such on the Flood Zone Maps. The EAs National Flooding and Coastal Defence Database (NFCDD) provides information on existing defences in Newcastle, in terms of their structure and condition rating.

The location of flood defences in the Newcastle area, including their standard of protection, is shown on Drawing 2009s0275-D011 (Flood Risk Management Measures Map).

Information on Areas Benefiting from Defences (ABDs) has also been provided. ABDs are those areas which benefit from formal flood defences in the event of flooding. The EA have confirmed that there are no ABDs in the Newcastle area.

In general, flood defences along the River Tyne are in good or fair condition with a life expectancy of 100 years or more. When assessing or allocating new development, the condition of existing flood defences is an important consideration for the Council. PPS25 considers that defended areas are still at risk of flooding. Therefore, sites located within a defended area need to be assessed along with the suitability, condition and extent of any defences present.

The condition of existing defences is provided, by the EA, in the form of a condition rating from 1 to 5. The condition rating reflects the observed structural integrity of a defence. It is determined on the basis of visual inspections that focus on obvious signs of structural defect such as slippage, cracking and poor maintenance. A summary of the NFCDD condition rating allocations is shown in Table 4.


Table 4 (NFCDD Condition Ratings for Flood Defences)

Condition Rating Condition Condition Description

1 Very Good Fully serviceable.

2 Good Minor defects.

3 Fair Some cause for concern. Requires careful monitoring.

4 Poor Structurally unsound now or in the future.

5 Very Poor Completely failed and derelict.

The condition of existing flood defences, and their continued maintenance and enhancement in the future, are issues that need to be considered as part of the risk-based sequential approach. This process will enable informed decisions to be made as to whether proposed land allocations are both appropriate and sustainable within defended areas.

Detailed FRAs will need to be prepared to confirm the flood-limiting effect of any available defences. They will be of particular importance where defences are considered to be informal or where defences comprise a wide variation in condition grades.

5.14 Flood Warning Areas

The EA has the lead role in providing flood warning services in England. The aim of the flood warning service is to reduce risk to life, distress to people and damage to property as a result of flooding. This is achieved by providing accurate and timely flood warnings to residents and businesses in river and coastal areas.

People at risk of flooding require appropriate flood warnings in order to take action. In the EA’s corporate plan “Creating a Better Place3” they have highlighted three key targets. These are:

� To have 80% of properties at risk in the floodplain receiving an appropriate flood warning service;

� 75% of people, living in flood risk areas, should take appropriate action by 2011, and;

� To have major incident plans in place for high flood risk areas. Currently the EA operates a Flood Warning Service in specific locations known as Flood Warning Areas. Within these areas, flood warning codes indicate the flood status within an area and are described in Figure 6 as follows:

3 Environment Agency (2006) Creating a Better Place: Corporate Strategy 2006-2011


Figure 6 (Flood Warning Codes)

Flood Watch

flooding of low-lying land and roads is expected

Flood Warning

flooding of homes and businesses is expected

Severe Flood Warning

severe flooding is expected

All Clear

all clear or receding floodwaters

There are 8 Flood Warning Areas covering Newcastle and the location of these areas is shown on Drawing 2009s0275-D011 (Flood Risk Management Measures Map). These Flood Warning Areas are:

� 121FWFNS105 - River Pont at Ponteland � 121FWFNW326 - Ouse Burn at Woolsington and Brunton Park � 121FWFNW327 - Ouse Burn at Whitebridge Park � 121FWFNW328 - Ouse Burn at South Gosforth � 121FWFNW329 - Ouse Burn at Upper Brunton Park and South Gosforth � 121FWTNST50 - Tyne Estuary � 121FWTNWT49 - Tyne Estuary Riverside � 121FWTNWT56 - Ouse Burn at Byker


6 Strategic Flood Risk Mapping

6.1 Introduction

The SFRA maps allow Sequential Testing and prioritisation of sites to be undertaken. This means that through careful planning, inappropriate development may be avoided in higher flood risk areas. Where development is acceptable the SFRA maps can be used to ensure that development located in flood risk areas is of an appropriate flood risk vulnerability categorisation.

The SFRA maps allow broad assessment and better understanding of significant flood risk issues. As a Level 1 SFRA, it is inappropriate to look at flood risk in detail for each allocation. This level of investigation is assessed during preparation of a Level 2 SFRA and subsequent site-specific FRAs.

The SFRA maps enable the Council to make informed spatial planning decisions so that allocations, put forward in the LDD, can comply with the requirements of the Sequential and Exception Tests.

The SFRA maps provide a complementary suite of information that enhances the information provided by the EA’s Flood Zone Maps. Individual maps should not be considered in isolation and flood risk to a site needs to be determined by comparison and cross reference, to all the SFRA maps.

However, it should be noted that the EA’s Flood Zone Maps are periodically updated and the extent of flooding depicted in these maps takes precedence over the extent of flooding indicated on any other SFRA map. Information provided in the SFRA maps needs to be interpreted consistently for all allocated and windfall sites.

The maps included in this SFRA are included as Appendix J and summarised below:

� Set A: PPS25 Flood Zones � Set B: Flood Zone 3 Depths � Set C: Flood Hazards � Set D: Flood Risk Management Measures � Set E: Areas Naturally Vulnerable to Surface Water Flooding � Set F: Climate Change Sensitivity � Set G: Critical Drainage Areas (see section 7.6 for further details)

6.2 Flood Zones Maps

The Flood Zones have been reproduced on a set of eight maps and included as Drawings 2009s0275-D001 to 008. These maps are based on information provided in the Environment Agency Flood Map (Version 3.14), and show main rivers, ordinary watercourses, Flood Zones 2, 3a and 3b (functional floodplain), Newcastle SHLAA sites, ELR sites, LDF Areas of Major Change and historical flooding records.

In accordance with the requirements of PPS25 these key maps should be used by planners and developers to sequentially test sites.

6.3 Functional Floodplain

The functional floodplain (Flood Zone 3b) has been defined using modelled (4% AEP) outlines where available. The extent of the functional floodplain is included on the Flood Zone Maps. Modelled outlines were then edited to include areas of land that provide a flood conveyance or storage function, such as wetlands. Any areas of developed Brownfield land are not considered as functional floodplain unless specifically designed to mitigate flood risk.


6.4 Flood Zone 3 Depth & Hazard Maps

A depth map for the 1% AEP event has been included for the Ouseburn and its tributaries as Drawing 2009s0275-D009 (Flood Zone 3 Depth Map). The depth grid used to generate this map was obtained from the EA North East Broad Scale modelling work for CFMPs (JBA 2008).

This depth map has been generated using the same process as that used to prepare the EA’s Flood Zone Maps. However, the depth maps include consideration of updated hydrology and are based on the latest topographical data. The approach also allows internal flooding to buildings to provide a more realistic approximation of flood depths.

Although the extent of flooding cannot be directly compared to the EA’s Flood Zone 3 outline, it is intended that the depth map is used to provide an early indication of the likely depths of flooding during a 1% AEP event. The depth of flooding is likely to influence the selection and acceptability of sites for development, with sites at greater depths of flooding being considered less appropriate for future development. The depth map will help both master planning and sequential layout of development proposals.

A hazard map, also based on EA data, has been prepared to show potential hazards based on the EA flood hazard formula proposed in Phase 2 of the Risks to People Project. The hazard map is included as Drawing 2009s0275-D010 (Hazard Map).

The hazard posed by flooding is determined by the relationship between the depth and velocity of the flood water. The hazard grid has been categorised and presented in accordance with Table 5 below.

Information for this mapping is based on the NE CFMP velocity and hazards data. Velocity is not specifically modelled but allowance is included within the calculation for hazard ratings.

Table 5 (Flood Hazard Rating)

Flood Hazard Rating Hazard to People

0 No Hazard

0 to 0.75 Very Low Hazard

0.75 to 1.25 Dangerous for some

1.25 to 2.0 Dangerous for most

Over 2.0 Dangerous for all

These maps provide an additional level of detail to the Flood Zone Maps and give an indication as to whether a development site is likely to remain safe during flooding.

6.5 Flood Risk Management Measures Maps

A depth map for the 1% event has been included as Drawing 2009s0275-D011 (Flood Zone 3 Depth Map). This map also shows the current flood risk management measures for the Newcastle area. These comprise:

� The location of EA river flood defences; � The location of coastal defences; and, � The coverage of EA Flood Warning Areas.

There is a need to assess the residual risks that remain despite the presence of these flood avoidance and mitigation measures. Residual risks in the Newcastle area are


associated with scenarios that have a low probability of occurring, such as higher magnitude flood events, defence failure and storm surges that overtop coastal defences.

It is envisaged that this map will enable an initial consideration of likely residual risks to be taken into account when planning for development. For example, it may be assumed that these defences are designed for the 1%AEP event, and the 1% outline gives a rudimentary indication of the defended areas which might flood if the defences fail. However, the understanding of residual risks will need to be developed further during the Level 2 SFRA or detailed FRA stages.

6.6 Areas Vulnerable to Surface Water Flooding Map

Areas vulnerable to surface water flooding are included as Drawing 2009s0275-D013. This map indicates the extents and depths of surface water flooding. It is based on a 0.5% AEP rainfall event and includes allowance for the capacity of the sewer system.

Areas vulnerable to surface water flooding have been categorised as follows:

More Vulnerable

Vulnerable

Less Vulnerable

It is intended that this map is used to identify areas susceptible to localised flash flooding. Flooding in these locations is not dependent on fluvial or tidal flooding events, so often occurs outside of Flood Zone 3. Surface water flooding is often due to high intensity rainfall that exceeds the capacity of the sewer systems. These maps may also be used to identify significant flow routes where topography may channel surface water flooding towards areas of critical infrastructure or development.

6.7 Climate Change Sensitivity Maps

The climate change sensitivity maps, included as Drawings 2009s0275-D020 (Climate Change Sensitivity Map) show the predicted depth and extent of flooding from rivers for an undefended floodplain during a 1% design event with a 20% increase in flood flows (to represent climate change). The increased extent of flooding due to climate change is shown where detailed hydraulic models are available. For watercourses that have not been modelled then the presumption is to take the extent of flooding, as represented by Flood Zone 2, as a representation of climate change in the future.

A 2D TUFLOW model of the River Tyne Estuary was produced for the NE RFRA to investigate the impact of climate change on tidal flood extents and depths. The results have been included to show the impact of increased tidal levels along the River Tyne.

PPS25 requires consideration of climate change to be undertaken as part of a site-specific FRA. It is intended that these maps provide an early indication of climate change impacts on potential development sites. In addition these maps may also be used for emergency planning and evacuation.


7 Site-Specific Allocations

7.1 Summary of Information provided in the Sequential Test Spreadsheet

The EA must be consulted on all development applications in areas with critical drainage issues and for any development on land exceeding 1 hectare. At LLD level it is for the Council's Sustainability Appraisal, using the information within the SFRA, to conclude the Sequential Test. This process is not just about finding lower risk sites and has to be balanced against other planning criteria. Where appropriate, the Exceptions test should be applied.

The Council is required to prioritise the allocation of land for development in ascending order from Flood Zone 1 to 3. The Sequential Test should be used to identify, remove, or adjust those sites at greatest risk within the Sustainability Appraisal.

Having assessed the sites for development, the EA will require that the Council demonstrates that there are no reasonable alternative sites available for development in lower flood risk categories.

The vulnerability of the remaining sites at risk should be considered further to ensure that lower risk development types are substituted in place of more vulnerable development. Sequential planning of the site layout should occur before any mitigation measures are considered.

7.2 Development Site Sequential Test

Although the Sequential Test Spreadsheet (Appendix I) summarises the pertinent flood risk information on a site by site basis, a further summary of the results is provided as Tables 6 and 7 below. These Tables quantify the overall number and location of developments within each Flood Zone or area susceptible to surface water flooding.

Development sites identified by Newcastle City Council comprise:

� Strategic Housing Land Availability Assessment sites (SHLAA); � Employment Land Review Sites (ELR); and, � Areas of Major Change.


7.3 Summary of sites at risk of Fluvial Flooding

In accordance with Table 6 and Appendix I:

� Approximately 17.8ha of land identified for development is located within high risk Flood Zones 3a and 3b.

� Approximately 42.2ha of the total site area is at risk of flooding during the 0.1% event (Flood Zone 2+3a+3b)

� 8 sites have some element of land located within the functional floodplain. These risk areas should be considered as part of the Sequential Testing process. Further information, including ongoing assessments and studies, about individual sites is given in Appendix J. No development, other than water compatible, will be allowed within Flood Zone 3b areas.

It should be possible to avoid development in Flood Zone 3 without losing significant developable area and affected yield numbers. These areas should be left as green/public open space.

Table 6 (Summary of Development Sites at Risk of Fluvial and Tidal Flooding)

Council sites

Total Number of sites

Total Area (ha)

Flood Zone 2 Flood Zone 3a Flood Zone 3b

Area affected (ha)

% of total site area

Area affected (ha)


Area affected (ha)


SHLAA 2 2.3 0 0 0 0 0 0

ELR 6 58.4 2 3.4 0.5 0.8 8.3 14.3

Combined SHLAA and ELR sites

14 63.2 2.4 3.7 0 0 0.2 0.3

Areas of major change

4 1631.7 20 1.2 4.8 0.3 4 0.2

Total 26 1755.6 24.4 8.3 5.3 1.2 12.5 14.8

On review of the information provided in the Tyne and Wear SFRAs, the EA recommended that the following text be included for development sites identified as being at risk to fluvial flooding:

� “The EA consent any works within 5 metres of a main river. It is likely that we will object in principle to any development within this area. As such, we consider that this should be highlighted as a major constraint to be noted in individual site assessments.

� Compensation storage is a requirement for any development within fluvial flood risk areas. We consider that this should be noted as a constraint within the individual site assessments as this requirement may have implication for the yields achievable for individual sites given the associated land take this may require.

It should be noted, however, that the issue of compensation is something for the SFRA to address and reinforce. During the Council's Exception Testing process it should be noted whether compensation is required and potentially achievable. This affects a site's viability for development and is considered a hidden policy test.


7.4 Summary of sites at risk of Surface Water Flooding

The number of sites at potential risk from surface water flooding significantly exceeds those at risk from either fluvial or tidal flooding. 22 sites of the 26 identified sites have some susceptibility to surface water flooding.

A total of 8 sites have a high susceptibility of surface water flooding and 16 are at intermediate vulnerability. These risk areas should be considered as part of the Sequential Testing process.

If these sites are allocated for development then an FRA will need to consider surface water mitigation techniques. This may include the use of SUDs, or lowering the density of development by including areas of open space within the development planning. A sequential approach to site layout will also be required. Development within areas of high vulnerability should be avoided.

Table 7 (Summary of Development Sites at Risk of Surface Water Flooding)

Council sites

Total Number of sites

Total Area (ha)

Low Vulnerability Intermediate Vulnerability

High Vulnerability

Area affected (ha)

Number of sites affected

Area affected (ha)


Area affected (ha)


SHLAA 2 2.3 0.1 0 0 0 0 0

ELR 6 58.4 6.1 2 5.1 2 3.1 2

Combined SHLAA and ELR

14 63.2 16.7 2 11.1 2 1.0 1

Areas of Major Change

4 1631.7 211.7 4 149.5 4 47.7 4

Total 26 1755.6 234.6 8 165.7 8 51.8 7

7.5 Review of Current Development Sites

A review of Sequentially Tested sites demonstrates that a majority of proposed locations are outside of Flood Zones 3a and 3b. The criteria set out below is only for screening of a large number of sites, to primarily identify which sites should be Exception Tested. These percentage areas provide a pragmatic approach to screening and not an alternative to Sequential Testing.

It is recommended that areas of development planned within Flood Zones 2, 3a or 3b are avoided if:

� the percentage cover is greater than 20% in Flood Zone 3a; � development is within Flood Zone 3b; and, � and 40% of the developable area is located in Flood Zone 2.

This assessment should be undertaken in the Sustainability Appraisal, with specific sites being considered in greater detail during the level 2 SFRA Only if this is not achievable should Exception Testing be considered.

Those sites still allocated for development in flood risk areas must be accompanied by a site-specific FRA with the planning application.


Newcastle City Council will only be able to assess the likelihood of sites passing the Exception Test at this stage. If it is unlikely that the site will pass parts B or C, using the information supplied in this SFRA, or there is no planning justification to pass part A, then the council should look to avoid development in preference to developing inappropriate sites which may require large and expensive mitigation measures.

7.6 Surface Water Management Plans

The Pitt Review, PPS25, the Making Space for Water Integrated Urban Drainage pilots and the Flood and Water Management Bill recognise the need for clearer roles and responsibilities for addressing each sources of flood risk. The current legislative framework tends to result in a fragmented and piecemeal approach to managing urban flood risk.

A local leadership role for flood risk issues has emerged whereby local authorities will need to have in place a strategy to manage these risks. Preparation of a Surface Water Management Plan (SWMP) is an integral part of this process.

Surface water flooding is a major source of flood risk and as demonstrated by recent floods, can result in serious and wide scale flooding. These impacts can typically be mitigated by using best practice techniques for surface water management, implemented at planning stage, for controlling surface water flooding. This may, for example, require the use of Sustainable Urban Drainage Systems (SUDS) on a site by site basis.

However, in some circumstances site constraints dictate that a catchment-wide, holistic approach to surface water management is required. This can be achieved through strategic urban catchment planning including consideration of the design, construction, maintenance and improvement of sewers and watercourses.

Local Authorities need to take a lead role. Close liaison between Water Companies and the Environment Agency is essential to ensure a consistent and co-ordinated approach to surface water management. This may best be achieved by preparing an appropriate SWMP.

SWMPs are developed in partnership between the Local Authority, Water Company and the Environment Agency. They provide an opportunity to:

� Develop a framework for joint working and data sharing. This is a fundamental aspect of flood risk management under the Flood and Water Management Bill);

� Collate a central geographic database of drainage assets and flood risk issues; � Assess the likelihood of surface water flooding through various modelling

techniques; � Assess the risk of surface water flooding to people, properties and the

environment; � Communicate risks to local communities; � Assess the costs and benefits of various flood risk reduction measures; � Provide a drainage strategy for areas of significant development if appropriate;

and � Provide a framework for implementation and monitoring of the surface water

strategy for a given area. The Defra SWMP guidance is based on the Integrated Urban Drainage pilot studies undertaken as part of Making Space for Water. It is currently being tested as part of the six national pilot studies. The government outlined its future intentions towards the development of SWMPs in the Government Response to the Pitt Review into the 2007 floods. £5M has been set aside for the development of a further 50 SWMPs for high priority locations.

SFRAs provide the opportunity for local authorities to assess, at a strategic level, the risk from multiple sources of flooding, which can then be used to inform more detailed assessments where appropriate by both themselves and other operating authorities. This


includes identification of Critical Drainage Areas (CDAs). Recommendations can then be made for the future provision of SWMPs in high risk locations or areas of significant development for which an integrated drainage solution is possible.

7.7 Proposed Critical Drainage Areas

Correlation between incidents of historical flooding, and properties at risk from large areas of surface water flooding, provide a good indication as to the location of vulnerable areas to surface water flooding. These are known as Critical Flood Areas (CFAs). CFAs may help to identify Critical Drainage Areas (CDAs). CDAs tend to be defined by areas of low lying ground where the capacity of the sewer system is likely to be exceeded.

Proposed CDAs, have been identified in the Newcastle City Council area by combining the drainage areas (provided by Northumbrian Water) and their contributing natural catchments with the surface water inundation and historical flood mapping. The natural catchment areas were identified from the FEH CD-ROM. The sewer network may have significant impact on the location of surface water and sewer flooding for more relatively frequent events. It may also influence the distribution of flood water throughout urban catchments by passing excess flows from the sewer networks into watercourses through combined sewer overflows.

For the purpose of this Level 1 SFRA Critical Drainage Areas have been identified as the most obvious locations where flooding has either been predicted to occur or has actually occurred in the past. It is not intended that the identified areas represent all Critical Drainage Areas in Newcastle as more detailed and focussed information is required from stakeholders before detailed assessment can occur. The identified Critical Drainage Areas are included as an initial indication only and should not be used as the basis for further assessment or study without further review and consideration.

Definition of Critical Drainage Areas is dependent on available information that has been provided as part of the study. In this instance Critical Drainage Areas are based on the following information:

� National Flood Zone Maps – indicating significant areas of flooding in urban areas; � Pluvial (rainfall) maps; � Natural catchment areas (as defined by the Flood Estimation Handbook software); � Historical flooding records (both recorded and anecdotal); � Red, Amber, Green drainage asset areas (as provided by Northumbrian Water) � Local authority incident records; and, � Northumbrian Water drainage areas and DG5 register.

The information on the performance of drainage systems is highly limited at this stage. The information released by Northumbrian Water provides a superficial appreciation of drainage related flooding issues at this stage. Further assessment is required as part of the Level 2 SFRA and subsequent Surface Water Management Plan.

Future Water (Defra 2008) sets out the role that SFRAs have in identifying CDAs for which more detailed Surface Water Management Strategies can be developed. The recent Defra Surface Water Management Plan Guidance (2009) supports the use of SFRAs in providing the evidence base for where SWMPs are required.

The CDAs identified in this SFRA should, therefore, be taken as an initial starting point in the identification of areas for which a SWMP would be beneficial. Where sewer systems are interconnected across the boundaries of natural catchments, the additional catchments of the sewers should be taken into account when finalising SWMP boundaries in areas where there is a high risk of sewer flooding, known historic flooding incidents or the sewer network is at capacity. The catchments of sewers often encompass more than one local authority.


CDAs proposed for the Newcastle area are shown in Table 8. The Level 2 SFRA will confirm the CDAs once the refined surface water mapping and analysis has been completed.

Table 8: Screening for Critical Drainage Areas

Proposed CDA - topography, rainfall and historical flooding

Reason

Ouseburn (including Woolsington, Gosforth & Jesmond.)

These areas have been selected based on the significant areas of surface water flooding, historical flooding events and DG5 data. Catchment boundaries have been defined based on the Flood Estimation Handbook topographic catchment boundaries. Development within these areas has the potential to significantly impact on flood risk elsewhere

Walbottle

Blakelaw

Heaton

Townmoor

Proposed CDA - Based on areas of major change Reason

Newburn, Lemington, Stella Council defined areas of major change. These comprise areas where significant levels of development could impact on flood risk elsewhere

Walker Riverside

City and Ouseburn

Benwell, Scotswood

It is recommended that more detailed surface water modelling is undertaken for the entire borough as part of the Level 2 SFRA. This should allow the surface water mapping to be refined so that it picks up flow paths along roads and around buildings. The risk to properties can then be assessed with more confidence to provide recommendations for SWMPs.

Until a SWMP has been completed, all developments identified at risk from surface water flooding should adhere to the guidance in PPS25 and the recommendations outlined in this SFRA. Integrated drainage solutions should be prepared for larger sites or areas. Where major flow paths have been identified these should be considered in the master planning of the site and the sequential placement of development. Where suitable, SUDS techniques should be identified within the development at the earliest possible stage.

7.8 Water Cycle Studies (WCS)

Water Cycle Studies (WCS) aim to assess the available capacity in terms of water supply and waste water infrastructure to an area. The WCS is aimed at those regions where growth is expected and the main aim of the WCS is to ensure that new development can be supplied with the required water services.

To ensure that growth can be supplied with sufficient water and wastewater treatment facilities, without detriment to the natural water cycle, the water infrastructure needs to be considered at an early stage in the planning process. A WCS will provide Newcastle Council with the necessary planning tool for this purpose and the planning base to support their LDF.

A SWMP and a WCS should be undertaken at the same time. Whilst the SWMP will address surface water management; water supply and sewage treatment should be considered by the WCS.


7.9 Green Infrastructure Framework

Green Infrastructure is a planned and managed network of natural spaces that connects urban with rural areas. It comprises:

� Areas of open space such as parks, woodlands, nature reserves and lakes; � Areas of land linking open spaces such as river corridors, canals, pathways and

cycle routes; and � The network of private gardens, tree lined streets and grass verges.

The identification and planning of Green Infrastructure is an essential aspect of sustainable growth. It is central to planning appropriate flood risk management measures and mitigating the impacts of climate change in the future. Green spaces can be used to control and attenuate storm water and reduce the risk of damage to property and infrastructure, particularly in vulnerable urban regeneration areas.

In addition Green Infrastructure can also improve accessibility to waterways, support regeneration and improve opportunities for leisure, economic development and biodiversity.

The evidence base provided in this SFRA should be used to enhance the council’s Green Infrastructure policy. Safeguarding land to convey flood water and provide flood water storage can help protect current and future areas of development.

Areas of land identified within the urban environment or upstream of areas vulnerable to surface water flooding should be incorporated into council’s Green Infrastructure strategy.

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Appendices

A . The Planning Framework

A.1 Introduction

The purpose of this section of the report is to outline the requirements of those documents that were taken into account during preparation of this SFRA.

The land use planning process is driven by a whole host of policy guidance at national, regional and local levels. Whilst the majority of these policies are not aimed at mitigating flood risk, there are key links at strategic and operational levels between land use and spatial planning, and Flood Risk Management (FRM) planning. These should be considered as part of a planned and integrated approach to delivering sustainable development.

The sustainability appraisal will help draw together these links and balance the application of wider social, economic and environmental planning policy and guidance.

Assessment of flood risk is required at all levels of the planning process and for all major developments in flood risk areas. These assessments play an increasingly important role in the effective delivery of key planning objectives.

A.2 Flood Risk Management Drivers

The principal FRM policy drivers are brought together in the Government’s recently released Flood and Water Management Bill. This Bill is an important part of the Government’s response to Sir Michael Pitt’s Report on the summer 2007 floods. It also gives effect to a number of commitments in the Government’s “Future Water” strategy document.

In addition, the Bill provides a response to a range of challenges including: climate change; increased population; increased water demand; and more water quality problems. It also tasks the Environment Agency with a strategic role over flood risk in England and Wales and gives local authorities in England a clear leadership role in local flood risk management. An improved integrated and risk-based approach is proposed to future management of flood risks. This requires other considerations such as sustainability, biodiversity and the whole water cycle to be taken into account by LPAs and other stakeholders.

The establishment of a core strategy, incorporating all current policy drivers, is the fundamental shift in emphasis away from building defences to prevent flooding to managing flood risk by using a suite of land use and flood risk management measures.

All operating authorities are required to invest in the provision of sustainable flood risk management and this includes LPAs adopting a hierarchy of flood risk management that is focused on assessing, avoiding, substituting, controlling and mitigating flood risk through the land use planning system. LPAs should have regard to flooding from all sources. Government does, however, recognise that in some circumstances appropriate mitigation measures may still involve the construction or maintenance of defences to protect increasingly vulnerable communities.

Current policy-related documents provide LPAs with valuable knowledge on the strategic direction of flood risk management and assist LPAs with strategic land use planning for regeneration, inward investment and growth.

Key documents currently influencing FRM policy are:

� EU Floods Directive – (2007)

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� Floods and Water Management Bill – Defra (2010) � Future Water (2008) � Improving Surface Water Drainage – Defra (2008) � Making Space for Water – Defra (2005) � Planning Policy 25: Development & Flood Risk - (2006) � Planning Policy 25: Development & Flood Risk Practice Guide - (2008) � Learning Lessons from the 2007 Floods – Sir Michael Pitt (2008) � Catchment Flood Management Plans � Shoreline Management Plans

A.3 EU Floods Directive

The EU Floods Directive aims to reduce and manage the risk floods posed to human health, the environment, cultural heritage and economic activity. Member States have two years in which to transpose its provisions into domestic legislation and the first requirements of the Directive begin at the end of 2011. By this date, an evidence base for flood risk should be developed to map the risk and then produce plans to manage it.

Preliminary Flood Risk Assessments (PFRAs) for all sources of flooding need to be prepared showing the impact of historic flooding and the potential impact of a repeat event. Following this, areas of potentially Significant Flood Risk (SFR) need to be defined. In addition, by the end of 2013, flood hazard and flood risk maps for the SFR areas are required and be coordinated with, and possibly integrated into, the reviews of River Basin Districts under the Water Framework Directive. Finally, by the end of 2015, Flood Risk Management Plans must be established to aim to reduce the potential adverse consequences of flooding and reduce the likelihood of flooding occurring.

The Government propose to use existing flood risk planning outputs of RFRAs and SFRAs to deliver the requirements of PFRAs. It is also proposed that local authorities extend their Level 2 SFRAs to look at the impact of flooding on the environment and cultural heritage when determining SFR areas. In addition, it is proposed that Surface Water Management Plans (SWMPs) will form Flood Risk Management Plans under the Directive and will also be a tool for use more generally in local flood risk management. This integrated approach will underpin the planning system and guide the location of future development that avoids and minimises flood risk whilst also meeting the requirements of the Floods Directive. Local authorities, through their land use planning activities, have a key role to play.

A.4 Floods & Water Management Bill

The Floods and Water Management Bill proposes new unifying legislation covering all forms of flooding and shifting the emphasis from building defences to managing risk. It aims to:

� Reduce the likelihood and impacts of flooding; � Improve the ability to manage the risk of flooding, by clarifying responsibilities; � Reduce pollution and improve water quality; � Give water companies better powers to conserve water during drought; � Reduce bureaucracy on water and sewerage companies; and � Improve the overall efficiency of the industry.

A number of proposals in the Bill have particular implications for local authorities, land use planning and related flood risk. These include:

� The Environment Agency will be given a strategic overview role covering all forms of flooding and will coordinate maps and plans in relation to the sea, main rivers

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and reservoirs; it will also be given the same powers as councils to carry out coastal erosion works and may be a statutory consultee in respect of future coastal erosion planning applications;

� Local authorities will have an enhanced leadership role in local flood risk management which includes ensuring that flood risk from all sources, including surface run-off, groundwater and ordinary watercourses, is identified and taken into account in the spatial planning process and managed as part of locally agreed work programmes;

� Local authorities will develop a suite of measures for managing local flood risk, for example, surface water mapping, appropriate development planning and collating information on flood risk and drainage assets;

� County and unitary authorities will be responsible for local Flood Risk Assessment and ensuring the production of SFRAs and SWMPs;

� SFRAs will provide the evidence to allow LPAs to factor flood risk into their LDFs, Development Planning Documents (DPDs) and individual planning proposals, and help to determine where SWMPs are needed;

� Level 2 SFRAs in areas of significant risk would directly inform EU Floods Directive flood risk maps and also inform the production of local Flood Risk Management Plans (FRMPs), such as SWMPs;

� SWMPs will have a stronger role in coordinating development and investment planning;

� County and unitary authorities will lead new local partnerships and have responsibility for adopting and maintaining sustainable drainage systems (SUDS) in new development, where they affect more than one property;

� The automatic right to connect surface water drains and sewers to the public sewerage system will be ended and developers will be required to put SUDS in place in new developments wherever practicable;

� Surface water connection to public sewers will be conditional on meeting new national standards on SUDS and drainage. The approval of a SUDS approving body will be needed, and a certificate issued before development can begin;

� Increased emphasis is needed on enabling flood water to safely flow overland with green infrastructure and safe flow routes being identified as part of flood risk assessments;

� County or unitary authorities, the Environment Agency and IDBs will have powers to formally designate natural and man made features (similar in principle to the Listed Buildings classification), which help to manage flood or coastal risk; they will give formal consent before anyone can change or remove the feature and use enforcement powers where needed; and

� All relevant authorities will have a duty to cooperate and share information. The content and implications of the Bill provide considerable opportunities for improved and integrated land use planning and flood risk management by local authorities and other key partners. The integration and synergy of strategies and plans at national, regional and local scales is increasingly important to protect vulnerable communities and deliver sustainable re-generation and growth.

A.5 Improving Surface Water Drainage

The Improving Surface Water Drainage consultation document was produced in support of the Government’s water strategy and in line with Sir Michael Pitt’s initial conclusions. Many of the proposals identified have been carried forward into the new Flood and Water Management Bill. The consultation considers policy measures to improve the way surface water runoff is managed. In particular, it proposes:

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� Issuing SWMPs as a tool to improve coordination between stakeholders involved in drainage and local management of flood risk;

� Increasing uptake of SUDS by clarifying responsibilities for adoption and management; and

� Reviewing the ability for premises to connect surface water drainage automatically into the public sewer system.

Current roles and responsibilities were considered along with various options for improving the current surface water drainage situation. In particular it is recognised that SFRAs and SWMPs already form part of the PPS25 planning framework and there is an aim to enhance their role and make stronger links between surface water drainage and strategic planning.

A.6 Making Space for Water Strategy

The Making Space for Water Strategy confirms the Government’s strategic direction for Flood and Coastal Erosion Risk Management (FCERM). Over the 20 year lifetime of the new strategy, Government will implement a more holistic approach to managing flood and coastal erosion risks in England. The approach will involve taking account of all sources of flooding, embedding flood and coastal risk management across a range of Government policies, and reflecting other relevant Government policies in the policies and operations of operating authorities for flood and coastal erosion risk management.

The 2004 consultation document Making Space for Water sets out the following vision:

“…we want to make space for water so that we can manage the adverse human and economic consequences of flooding and coastal erosion while achieving environmental and social benefits in line with wider government objectives.”

In other words, the aim of the strategy is to balance sustainability and flood risk with the social and economic benefits which accrue from growth and development. This balanced approach, integrating sustainable development with responsible risk management, has underpinned this SFRA.

Section 7 of the consultation document deals with measures aimed at reducing flood risk through land use planning. This emphasises the Government’s commitment to ensuring that the planning system reduces flood risk wherever possible. However, it is acknowledged that 10% of England is already within mapped areas of flood risk and that contained within these areas are some of the Brownfield sites which other areas of Government policy has identified as a priority for future housing provision. It is an assertion of the report that over the past five years, 11% of new houses were built in flood risk areas. Three sets of measures have been identified which may be undertaken to manage flood risk when development is located in higher risk areas. These are:

� Protection measures to provide, at minimum, the standards of protection specified in PPS25;

� The provision of features such as sacrificial areas and compartmentalisation to reduce the consequences of a flood event (such as functional floodplain); and

� To use of construction techniques that increase the flood resistance and resilience of buildings.

Key outcomes highlighted in the document are that RSSs and LDFs should take full account of flood risk and incorporate the sequential approach in PPS25. Moreover, integration with other planning systems is encouraged, in particular Catchment Flood Management Plans. Use of European Union (EU) funding, such as INTERREG IIIB is recommended where applicable, to enable Local Authorities to undertake trans-national projects aimed at advancing knowledge and good practice in flood risk management.

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A.7 Making Space for Water: Programme of Work

The Making Space for Water: Programme of Work was developed following consultation and takes account of relevant recommendations that emerged from the Pitt Review into the 2007 floods that affected many parts of England.

One of Defra’s early outputs from the Making Space for Water Programme was the publication, of PPS25 in December 2006. This work, together with the Practice Guide forms the Government's required approach to managing and reducing flood risk through the land use planning system.

Studies into Developing a Broader Portfolio of Options to Deliver Flooding and Coastal Solutions has been carried out as part of this programme and is useful to local authorities and other operating authorities, in their strategic planning of flood risk management. Outputs from this work are available from Defra.

Quarterly update reports are released providing details of progress made and key achievements. These reports can be accessed via the Making Space for Water website at http://www.defra.gov.uk/environ/fcd/policy/strategy.htm

A.8 The Pitt Review

The Pitt Review has been carried out following the severe floods of summer 2007 and is a key document for local authorities in their consideration of flood risk management. Sir Michael Pitt was asked by Ministers to conduct an independent review of events and report on the lessons that should be learned. In December 2007 an Interim Report was published by the Review team. The Review collected evidence by visiting affected areas and examining over 600 written statements submitted by victims of the floods. The report presents a schedule of interim conclusions, many of which relate to local authorities. These interim conclusions shaped the national approach to flood management and can be accessed via the Defra website.

Pitt’s final report was released in June 2008 and contains detailed findings, conclusions and 92 recommendations for action, covering all aspects of strategic and local flood risk management. These interim conclusions are intended to shape the national approach to flood management and can be accessed via the Defra website. Some of the recommendations which are relevant to this SFRA include:

� Recommendation 11: Building Regulations should be revised to ensure that all new or refurbished development in high flood risk areas is flood resistant or resilient.

� Recommendation 14: Local Authorities should lead on the management of local flood risk, with support of the relevant organisations.

� Recommendation 17: All relevant organisations should have a duty to share information and cooperate with local authorities and the Environment Agency to facilitate the management of flood risk.

� Recommendation 18: Local Surface Water Management Plans, as set out under PPS25 and coordinated by local authorities, should provide the basis for managing all local flood risk.

� Recommendation 52: In the short term, the Government and infrastructure operators should work together to build a level of resilience in critical infrastructure assets that ensures continuity during worst case flood events.

� Recommendation 57: The Government should provide Local Resilience Forums with the inundation maps for both large and small reservoirs to enable them to assess risks and plan for contingency, warning and evacuation.

Pitt’s findings, conclusions and recommendations for action are challenging but will be extremely important in guiding local authorities and other operating authorities in their

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consideration of future flood risk management activities, including land use planning. They have also been a key driver in shaping the content of the Flood and Water Management Bill.

A.9 National Planning Policy

This SFRA has been prepared in a period during which planning authorities have been implementing the provisions of the Planning and Compulsory Purchase Act 2004 and accompanying planning guidance, including PPS1 Delivering Sustainable Development and PPS12 Local Development Frameworks. This affected all tiers of the planning system and has necessitated major changes at both the regional and local level which will impact on the way in which planned development is approached in the regional strategy and delivered locally.

A.10 PPS25 Development and Flood Risk

In December 2006 the Government published PPS25: Development and Flood Risk.

The aim of PPS25 is to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding and to direct development away from areas at highest risk. The key planning objectives are that “Regional Planning Bodies (RPBs) and Local Planning Authorities (LPAs) should prepare and implement planning strategies that help to deliver sustainable development by:

� Identifying land at risk and the degree of risk of flooding from river, sea and other sources in their areas;

� Preparing Regional or Strategic Flood Risk Assessments (RFRAs / SFRAs) as appropriate, as a freestanding assessment that contributes to the Sustainability Appraisal of their plans;

� Framing policies for the location of development which avoid flood risk to people and property where possible, and manage any residual risk, taking account of the impacts of climate change;

� Only permitting development in areas of flood risk when there are no suitable alternative sites in areas of lower flood risk and the benefits of the development outweigh the risks from flooding;

� Safeguarding land from development that is required for current and future flood management e.g. conveyance and storage of flood water, and flood defences;

� Reducing flood risk to and from new development through location, layout and design, incorporating sustainable drainage systems (SUDS);

� Using opportunities offered by new development to reduce the cause and impacts of flooding e.g. surface water management plans; making the most of the benefits of green infrastructure for flood storage, conveyance and SUDS; re-creating functional floodplain; and setting back defences;

� Working effectively with the Environment Agency, other operating authorities and other stakeholders to ensure that best use is made of their expertise and information so that plans are effective and decisions on planning applications can be delivered expeditiously; and

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� Ensuring spatial planning supports flood risk management policies and plans, River Basin Management Plans and emergency planning.”

In addition to setting out the roles and responsibilities for LPAs and RPBs, PPS25 identifies that landowners also have a primary responsibility for safeguarding their land and other property against natural hazards such as flooding. Those promoting sites for development are also responsible for:

� Demonstrating that is consistent with PPS25 and Local Development Documents (LDDs);

� Providing a Flood Risk Assessment (FRA) demonstrating whether the proposed development: is likely to be affected by current or future flooding; satisfies the LPA that the development is safe; and identifies management and mitigation measures.

PPS25 also introduces an amendment to Article 10 of The Town and Country Planning (General Development Order) 1995 which makes the Environment Agency a Statutory Consultee on all applications for development in flood risk areas, and those within 20m of a Main River.

The Direction also introduces the requirement for LPAs to notify the Secretary of State where they are minded to approve a planning application contrary to a sustained objection by the Environment Agency.

The introduction of PPS25 enables local authorities to make a direction under Article 4 of the Town and County Planning (General Permitted Development) Order 1995. This will enable Local Authorities to remove permitted development rights where those rights threaten to have a direct, significant and adverse effect on a flood risk area, or its flood defences and their access, or the permeability and management of surface water, or flood risk to occupants.

A.11 PPS25 Development and Flood Risk Practice Guide

The Practice Guide to PPS25 was published by the Department for Communities and Local Government (DCLG) in June 2008. It provides advice on the practical implementation of PPS25 policy and reflects extensive discussion with local authorities, the Environment Agency and other key stakeholders and practitioners. The guide provides further guidance on the preparation of SFRAs and FRAs, the Sequential and Exception Test, and outlines potential mitigation measures e.g. SUDS and risk management techniques.

Local Authority planners and developers are advised to refer to and use PPS25 and the Practice Guide in conjunction with the further advice contained within this report.

A.12 Other Planning Policy Statements

PPS1 Delivering Sustainable Development published in February 2005 sets out the overarching planning policies for the delivery of sustainable development across the planning system and sets the tone for other planning policy statements. PPS1 states that development plan policies should take account of flooding, including flood risk. It proposes that new development in areas at risk from flooding should be avoided. Planning authorities are also advised to ensure that developments are “sustainable, durable and adaptable” including taking into account natural hazards such as flooding.

PPS1 also places an emphasis on ‘spatial planning’ in contrast to the more rigid ‘land use planning’ approach which it supersedes. Planning authorities will still produce site-specific allocations and a proposals map as LDDs, but their Core Strategy will be more strategic and visionary in content and will take into account the desirability of achieving integrated and mixed use development and will consider a broader range of community needs than in the past. With regard to flood risk, it will be important for the Core Strategies and

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accompanying Supplementary Planning Documents to recognise the contribution that non-structural measures can make to flood management.

Planning Policy Statement: Planning and Climate Change, a supplement to PPS1, published in December 2007, sets out how the Government expects the planning system to address climate change. It explains that there is a compelling scientific consensus that human activity is changing the world’s climate. The evidence that climate change is happening, and that man-made emissions are its main cause, is strong. The Intergovernmental Panel on Climate Change highlights that we are already experiencing the effects of climate change and if these changes deepen and intensify, as they are predicted to do without the right responses locally and globally, we will see even more extreme impacts.

One of the predicted impacts of climate change is more intense periods of rainfall and consequent flooding. The PPS1 supplement requires Regional Spatial Strategies and Local Development Frameworks to shape sustainable communities that are resilient to such effects. A key objective of the planning system is to secure new development that minimise vulnerability and provide resilience to climate change in ways that are consistent with social cohesion and inclusion. Accordingly new development should be planned to minimise future vulnerability in a changing climate. The SFRA incorporating Sequential and Exception Test information is essential in meeting the objectives of the PPS1 supplement Planning and Climate Change.

Whilst not directly relevant to the development of an SFRA, it is important to recognise that implementation of the PPS takes place within the context of other planning policy guidance and statements, some of which also require sequential testing of site allocations and development proposals. PPS3 (Housing), emerging PPS4 (Planning for Sustainable Economic Development) and PPS6 (Planning for Town Centres) are intrinsic within the planning process and, therefore, an understanding of the constraints faced as a result of this additional policy guidance is required.

A.13 Regional Spatial Strategy

The Regional Planning Guidance for the North East (RPG1) was published in November 2002. In September 2004, following the implementation of the Planning and Compulsory Purchase Act 2004, the Regional Planning Guidance was converted to the Regional Spatial Strategy (RSS) in line with Governmental reforms. The converted RSS was prepared as a draft revision called VIEW: Shaping the North East, which was issued for consultation in December 2004 and published in August 2006.

After two consultation periods the North East RSS was updated and published in July 2008. It now outlines the current adopted planning strategy for the period to 2021.

The published RSS, when compared to the previous, demonstrates an increased emphasis and heightened awareness of flood risk. Under the emerging RSS Policy 35, ‘Flood Risk’ is more extensive than ENV4. It states that:

“Strategies, plans and programmes should adopt a strategic, integrated, sustainable and pro-active approach to catchment management to reduce flood risk within the Region, managing the risk from:

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� Tidal effects around estuaries and along the coast including the implications of the latest Government predictions for sea level rise;

� Fluvial flooding along river corridors and other significant watercourses resulting from catchments within and beyond the Region and other sources of flooding; and

� Flooding resulting from surface water runoff and capacity constraints in surface water drainage systems.

In developing Local Development Frameworks and considering planning proposals, a sequential risk-based approach to development and flooding should be adopted as set out in PPS25. This approach must be informed by Strategic Flood Risk Assessments prepared by planning authorities in liaison with the Environment Agency to inform the application of the Sequential Test and, if necessary, the Exception Test, in development allocations in their LDDs and consideration of planning proposals.”4

A.14 Northumbria River Basin Management Plan

In accordance with the Water Framework Directive (WFD), implemented in December 2000, a River Basin Management Plan (RBMP) must be produced for each of the 11 River Basin Districts by 2009. The Environment Agency state that:

“RBMPs will have a number of functions, but are primarily intended:

� To establish a strategic plan for the long term management of the River Basin District.

� To set out objectives for waterbodies and in broad terms what measures are planned to meet these objectives

� Act as the main reporting mechanism to the European Commission” The Northumbria River Basin District is one of only two that cross the England-Scotland border. The Environment Agency recognise that cross-board RBDs can,

“Raise issues for the relationship between those responsible for the delivery of the WFD's objectives, the devolved governments, local authorities and government agencies.”5

The North East RSS observes that,

“To ensure the planning system can positively facilitate the delivery of the Directive’s objectives and the River Basin Management Plan can take account of local priorities, frequent dialogue between the Environment Agency and local planning authorities at all stages in the planning cycle is essential.”6

A.15 North East Regional Flood Risk Appraisal

JBA Consulting was commissioned by the North East Assembly (NEA) in conjunction with One Northeast to undertake a scoping study for the RFRA. The scoping study examines the Strategic Flood Risk Assessments undertaken across the North East region, and considers how these could form the basis for a more

4 Communities and Local Governments (2008) The North East England Plan Regional Spatial Strategy to 2021. 5 The Environment Agency (2005) Briefing Note: Cross-border River Basin Districts and the Water Framework Directive www.environment-agency.gov.uk/commondata/acrobat/bn_cb_2005_1184314.pdf 6 Communities and Local Governments (2008) The North East England Plan Regional Spatial Strategy to 2021.

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strategic flood risk appraisal. By using the sub-areas defined in the RSS, the study provides a more holistic view of flood risk and, therefore, planning implications at a sub-area level.

The appraisal is displayed through maps which have been structured:

� Regionally through economic indicators; � At City regions via a range of flood risk indicators presented at Growth Point

Level; and � At Growth Areas using a broad range of combined flood risk indicators.

The scoping report and associated maps can be found on the Association of North East Councils website.

The primary objective of a Regional Flood Risk Appraisal (RFRA) is to provide an appraisal of strategically significant flood risk issues in a region in order to guide strategic planning decisions.

The RFRA assists decisions on key land use factors such as need for employment, inward investment, re-generation, provision of housing and open/green space, major road and other infrastructure provision to deliver sustainable growth whilst taking full account of flood risks, now and in the future. The appraisal also drives and informs policy development and preparation of the Regional Spatial Strategy (RSS) for the strategic management of flood risk and, in turn, assists local authority planners in their consideration and implementation of land use policies in Local Development Frameworks (LDFs) and Local Development Documents (LDDs). In addition, it provides important strategic flood risk input to the Regional Sustainability Appraisal (RSA) and the Strategic Environmental Assessment (SEA).

The outputs of the RFRA help to identify where there may be a need for further flood risk assessment work to be undertaken, particularly in respect of Strategic Flood Risk Assessments (SFRAs) and where strategically significant developments are proposed in areas currently at risk of flooding. Even where SFRAs already exist, the RFRA helps to place specific local authority flood risks into a regional context, showing the variation of risk and the interdependency between neighbouring authorities and river sub-catchments. Flooding does not respect local authority administrative boundaries and the RFRA provides a mechanism to help local authorities work better together, and with key stakeholders, to consider, communicate and share common or similar flood risk management policy objectives, opportunities and constraints.

A.16 Climate Change Action Plan for the North East

The North East England Climate Change Adaptation Study was published in 2002 based on the UKCIP 2002 scenarios. This was followed by the North East Climate Change Adaption Study in 2008.

The Climate Change Action Plan for North East England identifies what is needed to be done to tackle climate change in North East England. It shows how all sectors have the opportunity to actively engage with this work, take direct action and influence how the plan is developed.

Climate change action plans already exist or are being developed at a sub-regional and local level. The action plan for North East England provides a regional framework that coordinates and facilitates action at a regional level, incorporating

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both adaptation and mitigation measures, ensuring that a regional evidence base is developed to inform those local action plans.

Climate change impacts continue to provide an increasing challenge to sustainable flood risk management for government and operating authorities. The severe flooding experienced across the country in recent years and in particular during the summer 2007 were, in the words of Sir Michael Pitt, “a wake up call”.

Flood risk related climate change issues are extremely important to the future management of flood risk in the UK and beyond. These issues need to be taken seriously and mitigation and adaptation measures planned and adopted by Regional and Local Authorities.

Principal adverse flood risk effects of climate change threatening people and property include:

� More frequent and intense rainfall events causing flash flooding to low-lying areas; � More and faster surface water runoff and overland flows causing sewers, drains,

rivers and streams to overflow; � Increased sea level rise, storminess and frequency of storm surges threatening

low-lying coastal communities; and � Rising groundwater levels causing increased spring-source activity and higher

spring flows increasing the risk of flooding. If not addressed, these effects are likely to have a significant impact on many communities and in particular new developments in areas at high risk of flooding. Recent climate change trends are contained within a UK Climate Impacts Programme document: The Climate of the United Kingdom and Recent Trends published in December 2007 and is available on their website. The next UKCIP09 report is planned for launch in late 2009.

In recognition of the Government's increasing concerns about the effects of climate change on flood risk management, Defra produced a “Supplementary Note to Operating Authorities – Climate Change Impacts” in October 2006 in which they updated the climate change policy for flood and coastal management. This document is available on the Defra website. In conjunction with Defra, DCLG then provided the recommended climate change contingency allowances for sea level rise and precautionary sensitivity ranges for peak rainfall intensities and peak river flows etc. in Annex B of PPS25. These figures should be used in all aspects of flood risk management including the consideration of new developments and changes of land use in flood risk areas.

A.17 Local Planning Policy

Following the introduction of the Planning and Compulsory Purchase Act 2004, the way in which development plans are prepared is changing. With the aim of speeding-up and simplifying plan preparation and improving community involvement, development plans in their current form are to be abolished and replaced with a new development plan system, the Local Development Framework (LDF).

A.18 Newcastle Unitary Development Plan

The Newcastle upon Tyne Unitary Development Plan was adopted in January 1998 and is the current local plan for the city. Under the Planning and Compulsory Order Act 2004 a selected number of UDP policies have been saved until such time as they are superseded in LDF Development Plan Documents. In relation to flood risk UDP policy POL14 has been saved:

POL 14: Development which would be at direct risk from flooding or likely to increase the risk of flooding elsewhere will not be allowed.

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The supporting text confirms that ‘areas at highest risk from flooding in the City are limited and confined largely to the upper reaches of the Ouseburn. The City Council, in consultation with the Environment Agency, wishes to ensure that new development will not increase the risk of flooding which could endanger life or damage property. Development anywhere in the catchment may increase surface water run off, adding to the flood risk downstream, and, may increase the risk of pollution and damage to river habitats’.

A.19 The Emerging Local Development Framework

Newcastle City Council is currently working together with Gateshead Borough Council to prepare a joint Core Strategy, which will form a key document in both authorities Local Development Framework.

The UDP is currently in the process of being replaced by the Local Development Framework (LDF). The LDF will take the form of a portfolio of plans and documents made up of several Local Development Documents (LDDs). Some of them will have statutory status (Development Plan Documents) and others will be adopted as local guidance documents. LDDs can either deal with different issues or different geographical areas, but when taken together they will set out the Council’s policies for how it will assess development proposals and direct future growth.

The LDF includes a Statement of Community Involvement (SCI) that describes how the local planning authority intends to carry out its public consultation arrangements. The SCI and all other DPDs will be submitted to the Secretary of State. They will be subject to an independent examination that is led by a planning inspector.

The full Newcastle Local Development Framework is currently being prepared and will eventually comprise the following documents. Some documents have already been adopted whilst others are still in the early stages of preparation.

1. Walker Riverside Area Action Plan (adopted April 2007) 2. Benwell Scotswood Area Action Plan (deemed sound by an independent

Inspector in July 2009, awaiting formal adoption by the Council)

A.20 Environment Agency Policy

Tyne Catchment Flood Management Plan

The Tyne CFMP was published in 2008 is a high level policy document covering the whole of the River Tyne catchment. The CFMP is investigating what factors influence flood risk at the catchment scale and will assess the impacts that climate change, land use change and urbanisation may have on flood risk over the next 50 to 100 years.

The CFMP has established a policy framework for flood risk management across the catchment through which future flood defence management strategies and programmes will be formulated. Recognition of these strategic plans is very important to local authority planners when planning for the future and considering long term land use options for regeneration, inward investment and growth.

The CFMPs help to prioritise activities, focus

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resources where there is greatest need, and determine what flood risk management responses need to be considered further (and which responses will not be effective). The responses to flood risk will be broader than those traditionally used for flood defence to reflect the full range of management options available. CFMPs support an integrated approach to spatial planning and river basin management, in line with the Water Framework Directive and the EU Directive on the assessment and management of flood risk; they cover all geographical areas in England and Wales and are crucial in the planning of sustainable flood risk management.

The Tyne CFMP has been split into seven policy units as outlined in

Figure 7.

Figure 7 (Tyne CFMP Policy Units7)

Rivers in Newcastle fall under the Policy Unit ‘The Lower Tyne’, for which the policy is to “Take further action to sustain flood risk at the current level in future.” This means that flooding of residential, commercial and community buildings and infrastructure does not increase, and flood depth and velocity stay the same even if flows increase under climate change. It has to be noted that this policy does not fully address the tidal flood risk in the Main River Tyne channel. The management of the tidal flood risk areas will be outlined further within the shoreline management plan for the area.

There are several flood risk management policy messages relevant to the Newcastle SFRA to emerge from the CFMP (summarised in Table 9).

7 Environment Agency (2008) Draft Tyne CFMP Main Stage Summary Report June 2008

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Whilst the actions outlined below are for the whole Lower Tyne Policy Unit there are a number of Generic Actions which are centred on the Local Authority under the Local Area Agreement NI189.

Table 9 (Lower Tyne CFMP Policy Unit Action Plan8)

Action Lead Organisation

Timescale

Produce and implement a System Asset Management Plan (SAMP) for the policy unit to determine the most sustainable approach to sustaining the currently level of flood risk throughout the policy unit.

Environment Agency

1-6 years

Undertake detailed studies to identify the true level of flood risk in the policy unit where this is not known, and implement recommendations.

Environment Agency

1-6 years

Work in partnership to develop a FRM Strategy for the Lower Tyne. This strategy should take into account all sources of flooding as well as the implications of climate change to develop the most sustainable long term approach to managing flood risk within the Lower Tyne.

Environment Agency

1-6 years

Work in partnership to develop an assessment into the risk of flooding from surface water through undertaking a Surface Water Management Plan (SWMP) for the policy unit. Where locations of surface water flood risk are identified, ensure that cross-boundary issues are taken into account and fed into the management of surrounding policy units.

Local Authorities (Newcastle City Council)

1-6 years

Determine in greater detail the risk of flooding to educational facilities and the consequences of loss of the site during flooding. Where practically possible ensure that the site remains operational during flood events. Following the identification of flood risk to these facilities, ensure evacuation plans and alternative accommodation is identified.

Local Authorities (Newcastle City Council)

1-20 years

Determine in greater detail the risk of flooding to health facilities and the consequences of loss of the site during flooding. Where practically possible ensure that the site remains operational during flood events.

Health Authority 1-20 years

Determine in greater detail the risk of flooding to gas and electricity installations and the consequences of loss of the site during flooding. Where practically possible ensure that the site remains operational during flood events.

Northern Electric Distribution Ltd/ National Grid

1-20 years

Investigate securing Local levy funding to reduce localised flood risk.

Environment Agency

1-20 years

In accommodating future development in Newcastle, there is a range of planning policies to consider and balance on a national, regional and local level. Future development needs have been broadly specified in regional plans and are being refined on a local level in the emerging LDF.

8 Environment Agency (2008)Tyne Catchment Flood Management Plan

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PPS25 and its Practice Guide provides the overarching national guidance with respect to development and flood risk, emphasising the need to effectively manage flood risk within the planning system, rather than relying on reactive solutions to flooding. This includes a responsibility for LPAs to reduce flood risk to people and property as a result of new development. It also identifies the preparation of SFRAs as a key process in the understanding and management of flood risk for planning purposes.

It is widely recognised that flood risk is one of a whole raft of policy constraints placed upon the local planning system. Development must facilitate the socio-economic needs of a community, and spatially must sit within an existing framework of landscape and infrastructure. For this reason, a balance must be sought between development need and the risk it may pose upon existing and future dwellers of the area as a result of flooding.

The aim of this SFRA is to provide a better understanding of flood risk in Newcastle that can feed into the emerging LDF and enable informed and balanced planning decisions to be made.

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B . Flood Risk Zones Information taken from Table D1 of PPS25

Zone 1: Low Probability

Definition This zone comprises land assessed as having a less than 1 in 1000 annual probability of river and sea flooding in any year (<0.1%). Appropriate uses All uses of land are appropriate in this zone. FRA requirements For development proposals on sites comprising one hectare or above the vulnerability to flooding from other sources as well as from river and sea flooding, and the potential to increase flood risk elsewhere through the addition of hard surfaces and the effect of the new development on surface water run-off, should be incorporated in an FRA [Flood Risk Assessment]. This need only be brief unless the factors above or other local considerations require particular attention. See Annex E (of PPS25) for minimum requirements. Policy aims In this zone, developers and local authorities should seek opportunities to reduce the overall level of flood risk in the area and beyond through the layout and form of the development, and the appropriate application of sustainable drainage techniques.

Zone 2: Medium Probability

Definition This zone comprises land assessed as having between a 1 in 100 and 1 in 1000 annual probability of river flooding (1% – 0.1%) and between a 1 in 200 and 1 in 1000 annual probability of sea flooding (0.5% – 0.1%) in any year. Appropriate uses The water-compatible, less vulnerable and more vulnerable uses of land and essential infrastructure listed in The Flood Risk Vulnerability Classification, are appropriate in this zone. Subject to the Sequential Test being applied, the highly vulnerable uses in Table D.2 (of PPS25) are only appropriate in this zone if the Exception Test is passed. FRA requirements All development proposals in this zone should be accompanied by a FRA. See Annex E (of PPS25) for minimum requirements. Policy Aims In this zone, developers and local authorities should seek opportunities to reduce the overall level of flood risk in the area through the layout and form of the development, and the appropriate application of sustainable drainage techniques.

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Zone 3a: High Probability

Definition This zone comprises land assessed as having a 1 in 100 or greater annual probability of river flooding (>1%) and a 1 in 200 or greater annual probability of flooding from the sea (>0.5%) in any year. Appropriate uses The water-compatible and less vulnerable uses of land listed in Table D.2 (of PPS25) are appropriate in this zone. The highly vulnerable uses listed in Table D.2 (of PPS25) should not be permitted in this zone. The more vulnerable and essential infrastructure listed in the Table D.2 (of PPS25) should only be permitted in this zone if the Exception Test is passed. Essential infrastructure permitted in this zone should be designed and constructed to remain operational and safe for users in times of flood. FRA requirements All development proposals in this zone should be accompanied by a FRA, see Annex E (of PPS25) for minimum requirements. Policy Aims In this zone, developers and local authorities should seek opportunities to: • reduce the overall level of flood risk in the area through the layout and form of the

development and the appropriate application of sustainable drainage techniques; • relocate existing development to land in zones with a lower probability of flooding and • Create space for flooding to occur by restoring functional floodplain and flood flow pathways

and by identifying, allocating and safeguarding open space for flood storage.

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Zone 3b: Functional Floodplain

Definition This zone comprises land where water has to flow or be stored in times of flood. SFRAs should identify this Flood Zone (land which would flood with an annual probability of 1 in 25 (5%) or greater in any year or is designed to flood in an extreme (0.1%) flood, or at another probability to be agreed between the LPA and the Environment Agency, including water conveyance routes). Appropriate uses Only the water-compatible uses and the essential infrastructure listed in Table D.2 (of PPS25 and Table A-2 of this report) that has to be there should be permitted in this zone. It should be designed and constructed to • remain operational and safe for users in times of flood; • result in no net loss of floodplain storage; • not impede water flows; and • not increase flood risk elsewhere. Essential infrastructure in this zone should pass the Exception Test. FRA requirements All development proposals in this zone should be accompanied by a FRA. See Annex E (of PPS25) for minimum requirements. Policy aims In this zone, developers and local authorities should seek opportunities to: • reduce the overall level of flood risk in the area through the layout and form of the

development and the appropriate application of sustainable drainage techniques; and • relocate existing development to land with a lower probability of flooding.

Note 1: These Flood Zones refer to the probability of river and sea flooding ignoring the presence of defences.

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C . Flood Risk Vulnerability Classification (Table D.2 PPS25

Essential Infrastructure

• Essential transport infrastructure (including mass evacuation routes) which has to cross the area at risk and strategic utility infrastructure, including electricity generating power stations and grid and primary substations.

Highly Vulnerable

• Police stations, Ambulance stations and Fire stations and Command Centres and telecommunications installations required to be operational during flooding.

• Emergency dispersal points. • Basement dwellings. • Caravans, mobile homes and park homes intended for

permanent residential use. • Installations requiring hazardous substances consent (1)

More Vulnerable

• Hospitals. • Residential institutions such as residential care homes, children’s

homes, social services homes, prisons and hostels. • Buildings used for: dwelling houses; student halls of residence;

drinking establishments; nightclubs; and hotels. • Non–residential uses for health services, nurseries and

educational establishments. • Landfill and sites used for waste management facilities for

hazardous waste. (2) • Sites used for holiday or short-let caravans and camping, subject

to a specific warning and evacuation plan

Less Vulnerable

• Buildings used for: shops; financial, professional and other services; restaurants and cafes; hot food takeaways; offices; general industry; storage and distribution; non–residential institutions not included in ‘more vulnerable’; and assembly and leisure.

• Land and buildings used for agriculture and forestry. • Waste treatment (except landfill and hazardous waste facilities). • Minerals working and processing (except for sand and gravel

working). • Water treatment plants. • Sewage treatment plants (if adequate pollution control measures

are in place).

Water-compatible Development

• Flood control infrastructure. • Water transmission infrastructure and pumping stations. • Sewage transmission infrastructure and pumping stations. • Sand and gravel workings. • Docks, marinas and wharves. • Navigation facilities. • MOD defence installations. • Ship building, repairing and dismantling, dockside fish

processing and refrigeration and compatible activities requiring a waterside location.

• Water-based recreation (excluding sleeping accommodation). • Lifeguard and coastguard stations. • Amenity open space, nature conservation and biodiversity,

outdoor sports and recreation and essential facilities such as changing rooms.

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• Essential ancillary sleeping or residential accommodation for staff required by uses in this category, subject to a specific warning and evacuation plan.

Note 1: This classification is based on advice from the Environment Agency on the flood risks to people and the need of some uses to keep functioning during flooding. Note 2: Buildings that combine a mixture of uses should be placed into the higher of the relevant classes of flood risk sensitivity. Developments that allow uses to be distributed over the site may fall within several classes of flood sensitivity. (1)DETR Circular 04/00 – para. 18: Planning controls for hazardous substances. (2)See Planning for Sustainable Waste Management: Companion Guide to Planning Policy Statement 10 for definition.

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D . Guidance for Spatial Planners

D.1 Introduction

The purpose of this section of the report is to provide guidance to Spatial Planners on dealing with allocations using the SFRA.

Throughout the risk-based sequential testing process, opportunities to minimise flood risk at each stage of the planning process need to be considered. The principal aim of these actions is to ensure that risks to people and property are effectively managed. The hierarchy of management decisions and actions comprise:

� Avoidance, by locating new development outside areas at risk of flooding; � Substitution, by changing from more vulnerable to less vulnerable land uses; and,

1 Apply the Sequential Test to proposed development sites by:

• Using the Sequential Test Spreadsheet; and,

• Using the SFRA Maps (the FZ & Surface Water Maps in particular).

2 Remove those sites where flood risk is too great by:

• Identifying those sites where more than 20% of the land is located within FZ3 and (or) more than 40% is located within FZ2;

• Identifying those sites where flood depths are greater than 1m or hazards have been categorised as being higher than “dangerous to most”; and,

• Identifying those sites where there is no planning justification for regeneration or development in flood risk areas.

3 Identify suitable sites for substitution by:

• Identifying those sites with high percentages of land within FZ1 and FZ2, in which higher vulnerability development could be located.

4 Identify the likelihood of sites passing the Exception Test by:

� Using vulnerability classifications in Appendix C of this report and Table D.2 of PPS25; and,

• Using the SFRA Maps, particularly the fluvial depths and hazards maps, to take account of residual risk.

5 Produce evidence that both tests have been applied by:

• Recording the outcome and decisions made in a separate document including the details of the SFRA evidence base used to reach the decision.

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� Control & Mitigation of residual risks, by implementing suitable flood risk management measures.

The SFRA provides information on flood risk allowing the LPA to:

� Produce appropriate policies for development control and site allocation; � Produce appropriate flood risk indicators that inform the Sustainability Appraisal; � Undertake the Sequential Test and (with sufficient and suitable information)

Exceptions Testing; and, � Allocate appropriate land use for development.

It is recommended that a supporting document is prepared, by the LPA, recording decisions made for each proposed development site. This should include all evidence considered in making a decision and this record will form the evidence base that demonstrates that both the Sequential and Exception Test have been applied.

In granting planning permission it will be the requirement of Development Control officers to confirm that all parts of the Exception Test have been addressed. During the initial spatial planning stage, only the likelihood of passing the Exception Test can be assessed. To pass the Exceptions Test a site-specific FRA will be required to identify constraints and demonstrate that safe development is achievable.

D.2 Undertaking the Sequential Test and assessing the likelihood of passing the Exception Test

There are a number of steps that Spatial Planners may follow when Sequentially Testing sites and assessing the likelihood that a site will pass the Exception Test. These are:

� The LPA is required to prioritise the allocation of land for development in ascending order from FZ 1 to FZ 3 (including subdivisions of FZ 3);

� The general approach to be followed when assessing sites is included as Figure 8. This, combined with the information provided in the Sequential Test spreadsheet, should be used to identify those sites to be avoided where risk is considered too great;

� Identify those sites where substitution is possible due to high percentage of land within lower flood risk areas;

� Using Figure 9, identify those sites that may pass the Exception Test. Remove those sites where: - There is little or no planning justification to pass Part A of the Test; - Where sites are located on Greenfield land; - Where development will require drastic and complicated mitigation measures to make the site safe.

� Produce a supporting document recording all decisions made during the decision-making process. Each proposed development site should be referenced and the decisions made to avoid, substitute, or allocate the site and the evidence and/or reasoning used to make the decision should be recorded.

� Those sites which have been allocated must be identified in the relevant LDD accompanied by appropriate FRM policies which the LPA must then use when considering planning applications. These should include the need for an appropriate site-specific FRA.

2009s0275 Newcastle Level 1 SFRA Final 2.doc XXIII

Figure 8: Taking flood risk into account in LDDs

Undertake a Level 1 SFRA

Use the SFRA to inform the scope of the Sustainability Appraisal of

the LDD

Use the SFRA to identify where development can be located in areas with a low probability of

flooding Consult on the scope of the

Sustainability Appraisal

• Assess alternative development options using Sustainability Appraisal; considering flood risk and other planning objectives.

• Can sustainable development be achieved through new development located entirely within areas with a low probability of flooding?

• Use the SFRA to apply the Sequential Test identifying appropriate allocation sites and development.

• If the Exception Test needs to be applied, undertake a Level 2 SFRA

Assess alternative development options using Sustainability Appraisal,

balancing flood risk against other planning objectives

• Use the Sustainability Appraisal to inform the allocation of land in accordance with the Sequential Test

• Include a policy on flood risk considerations and guidance for each site allocation. Where appropriate, allocate land to be used for flood risk management purposes

Include the results of the application of the Sequential Test, and Exception Test where appropriate in the Sustainability Appraisal Report.

Yes

No

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Figure 9: Applying the Sequential Test and assessing the likelihood of passing the Exception Test

Identify sites 100% in FZ1

No action (*) (Sequential Test passed)

Identify sites (*) <20% in FZ 3a

and/or <40% in FZ 2

Fluvial flood risk is seen as a master-planning issue, which can be avoided by

substitution i.e. substituting higher vulnerable

development in lower flood risk communities or within

sites themselves

Identify sites >20% in FZ 3a

and/or >40% in FZ 2

LPA must consider avoidance

A greater understanding of risk is required for

development to proceed

Identify sites Within FZ 3b Avoid

Avoid

• Flood risk should be identified as development constraint in LDD.

• Include a policy on flood risk considerations and guidance for each site allocation.

• Include the results of the application of the Sequential Test where appropriate in the Sustainability Appraisal Report.

• Move on to the Exception Test if required

Assess alternative development options using

Sustainability Appraisal, balancing flood risk against other planning objectives to

pass Part "A"

Yes

Yes

No

Yes

No

Yes

No

No

Yes

Allocate Development

No

Is the site required for regeneration with significant planning justification?

LPA must consider avoidance

Is there planning justification for not relocating site in

lower risk areas?

Actual Risk • Are flood depths >1.5m? • Are flood hazards

dangerous for all? • Review climate change

sensitivity? • Are mitigation measures

significant? • Will compensatory

storage impact on development yields?

• Residual Risks • Are they acceptable? • Are mitigation measures

appropriate? • Is it an urban design

issue? • Are compensation works

possible?

Is there a high risk of flooding from other sources

including surface water?

* It may be appropriate to set these sites aside for lower vulnerability substitution at a late stage

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D.3 Likelihood of passing part C) of the Exception Test

Spatial Planners are required to assess the likelihood that a site will pass the Exception Test. To achieve this, the following questions should be addressed.

Figure 10: Likelihood of passing the Exceptions Test

What is the scale and nature of flood risk?

What is the scale of residual flood risks?

How many sources of flood risk are present?

Is the community currently served by defences or EA Flood Warnings?

Will access and egress be an issue?

Will the proposed development add more buildings and/or people within the flood risk

community?

Are mitigation measures likely to be large and/or costly?

Could mitigation measures reduce flood risk to the surrounding community?

Could the development site be re-allocated for FRM measures?

Review • SFRA asset database • Flood risk management measures

maps

Review • 1% fluvial depth & hazard maps • 0.1% fluvial depth & hazards maps • Surface water flooding maps • Reservoir Inundation map • Canal hazard zone maps • Climate change maps

Review

Appendix G

Appendix G

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Figure 11: Planning for development

•

D.4 The Sequential Test and Exception Test

If the proposed site is already identified in a Sequentially Tested LDD, the developer must still apply the sequential approach to site layout and land use vulnerability.

However, where a site has not been identified within a Sequentially Tested LDD, such as a windfall site for example, then the Sequential Test will need to be applied. To do this the developer will need to provide evidence to the LPA that there are no other reasonable available sites where the development could be located. The LPA will then use this information to apply the Sequential Test.

Developers will need to provide evidence that Part C of the Exception Test can be passed for both allocated and windfall sites, if required according to the vulnerability of the proposed land use, areas requiring redevelopment or regeneration, redevelopment of

SFRA

EA Flood Map

Sequential Test spreadsheet

SFRA

LDD Regeneration Strategies

SFRA mapping, depth hazard

and residual risk

PPS Practice Guide

Consultation process

EA standing Advice

PPS Practice Guide Chapter 3

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existing single properties or changes of use. Development Control will then need to review the evidence provided and decide whether a site passes the Exception Test.

D.5 Supporting FRA

In general, planning applications for development should be supported by a site-specific FRA prepared in accordance with the guidance provided in sections 3.70 to 3.89 of the PPS25 Practice Guide.

Development Control should refer developers to the SFRA, appropriate LDD and flood risk policies that may influence development proposals.

The EA's Standing Advice on flood risk should be referred to during preparation of an FRA. This can be accessed online at:

http://www.environment-agency.gov.uk/research/planning/82584.aspx

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E . Guidance for Developers

E.1 Introduction

The purpose of this section of the report is to provide guidance to Developers on using the SFRA.

The SFRA provides the evidence base for developers to assess flood risk at a strategic level and determine the requirements of an appropriate site-specific FRA.

Developers should liaise closely with the LPA in the first instance to determine if a site is suitable for development. If a site is considered suitable then developers should prepare a site-specific FRA, in close liaison with the LPA and EA.

Developers should consider all sources of flood risk when assessing the suitability of a site. Guidance on developing within CDAs and areas at risk from sources other than fluvial flooding is provided in this section.

Confirm the type of development proposed:

� Confirm whether proposals are for a windfall development, allocated development within the LDF, planned development within a regeneration area, redevelopment of a single property or a building with a planned change of use - to identify if Sequential and Exception Testing are required

Check whether the Sequential Test and (or) the Exception Test have already been applied:

� Request information from the LPA on whether the Sequential Test or likelihood of the site passing the Exception Test have been assessed

� If not, provide evidence to the LPA that the site passes the Sequential Test and will pass the Exception Test

Consult with LPA Development Control and the EA to scope an appropriate FRA if required:

� Also refer to EA Standing Advice, CIRIA Report C624, PPS25 and its Practice Guide

� Guidance on FRAs provided in this SFRA � Are there any strategic mitigation requirements identified in LDD? � Consult LPA emergency planners if required

Submit FRA to Development Control and Environment Agency for approval

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Table 10: Development types and application of Sequential and Exception Tests

Development Sequential Test required

Who Applies the Test

Exceptions Test Required

Who Applies the Test

Allocated site Yes LPA, unless test not yet completed, in which case the developer should provide evidence that the test can be passed to the LPA

Dependent on vulnerability of land use (refer to Appendix B and C)

LPA assesses likelihood of test being passed. Dependent upon whether the site has been allocated for the proposed land use in the LDD through the application of ST and ET informed by an SFRA? Developer provides evidence that the test can be passed to the LPA through a detailed FRA

Windfall site Yes Developer provides evidence that the test can be passed to the LPA

Dependent on vulnerability of land use (refer to Appendix B and C)

Developer provides evidence that the test can be passed to the LPA through a detailed FRA

Regeneration sites

No Dependent on vulnerability of land use (refer to Appendix B and C)

LPA assesses likelihood of test being passed. Developer provides evidence that the test can be passed to the LPA through a detailed FRA

Redevelopment of existing single properties

No Dependent on vulnerability of land use (refer to Appendix B and C)


Changes of use No Dependent on vulnerability of land use (refer to Appendix B and C)


E.2 Site-specific Flood Risk Assessments

The principal aims of an FRA are to determine the level of flood risk to a site and to confirm that suitable flood management measures can be developed to control flooding, and safeguard life and property, without increasing risk to the surrounding area.

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Once the site has been Sequentially Tested, and has been identified as being likely to pass the Exception Test, a site-specific FRA should be undertaken. The LPA and EA should be consulted in order to determine the content and scope of the FRA.

There are three levels of FRA:

� Level 1 is a screening study used to identify whether there are any flooding or surface water management issues that need to be considered further;

� Level 2 is a scoping study that should be undertaken if the Level 1 FRA indicates that there are flood risk issues that need further consideration; and

� Level 3, which is a detailed study, where further quantitative analysis is required to fully assess flood issues and confirm that effective mitigation measures can be implemented to control flood risk.

The SFRA is an assessment of flood risk at a strategic level. This information can be used to provide evidence for Level 1 and Level 2 FRAs. Where a more detailed FRA is required, then a developer should undertake a detailed assessment of the flood risk at the site. The scope of the FRA should be agreed by the developer through consultation with the LPA and EA.

E.3 FRA Guidance

Flood Risk Assessments should follow the approach recommended by:

� The Environment Agency Standing Advice (http://www.environment-agency.gov.uk/research/planning/82584.aspx)

� CIRIA Report C624 Development and Flood Risk (Guidance for the Construction Industry) and;

� PPS25 and its Practice Guide These documents describe when an FRA is required and the general issues that should be considered. The key requirements of an FRA are provided in Section 3 of the PPS25 Practice Guide. In general, the FRA should address the following issues:

E.4 Development Description and Locations

� What is the type of development and where will it be located? � What is the vulnerability classification of the current and future building use?

(using Table D.2 of PPS25)? � Has the development site been assessed during the Level 1 and Level 2 SFRAs

and is it in keeping with LDDs? (If so has the Sequential and Exceptions Testing been completed already?)

E.5 Definition of Flood Hazard

� What are the sources of flooding at the site? � For each source how would flooding occur, referencing any historical records. � What existing surface water drainage infrastructure is present on the site?

(Consult with LPA, EA and Northumbrian Water)

E.6 Probability

� Confirm the FZ designation for the site (refer to the FZ Maps) � Determine the actual and residual risks at the site (refer to the FZ Maps, depth

and hazards maps and defences maps

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� What are the discharge rates and volumes generated by the existing site and proposed development?

E.7 Climate Change

� How will flood risk at the site increase as a result of climate change for the proposals over the lifetime of the development (refer to the climate change maps)

E.8 Flood Risk Management Measures

� How will flood risk be managed over the lifetime of the development?

E.9 Off Site Impacts

� How will runoff and offsite measures be controlled following development to ensure that flood risk is not transferred elsewhere?

E.10 Residual Risks

� What flood-related risks will remain after mitigation measures have been implemented to protect the site?

� What are the maintenance arrangements for the proposed flood mitigation measures?

E.11 Sources of flooding

� FRAs should take all sources of flooding into account.

E.12 Groundwater

� Although groundwater flooding has not been identified as a major risk within the Newcastle area, this mechanism of flooding should be considered particularly when determining the acceptability of SUDs schemes as a way of managing surface water drainage. Developers should consult with the LPA and EA at an early stage of the assessment.

E.13 Sewer systems

� Where the SFRA has identified a risk of surface water flooding, any water that escapes from the sewer system would tend to follow similar flow paths and pond in similar locations.

� Developers should take account of the guidance for development in CDAs. Where required, liaison with Northumbrian Water should be undertaken at an early stage in the assessment process to confirm localised sewer flooding problems that could affect the site.

� Future development should be designed so that it does not increase existing sewer flooding problems.

E.14 Critical Drainage Areas

In certain locations an increase in the rate of surface water runoff is known to make development susceptible to localised flooding. Insufficient capacity in the surface water drainage system may exacerbate localised flood risk in areas outside of the EA Flood Zones.

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A detailed FRA would be expected for planned development within these areas regardless of Flood Zone designation. This should demonstrate that new development is not at risk of flooding from existing drainage systems; will not increase risk to adjacent development or land; but will include appropriate mitigation measures to safely control surface water runoff.

CDAs have been mapped as part of the Level 1 SFRA. Ideally developers shall work closely with the LPA, EA and Northumbrian Water to develop strategies that manage surface water runoff. Where greenfield development is proposed, the aim should be to not increase runoff rates above the existing greenfield rate. Where brownfield development is proposed then the EA actually seek a reduction in the overall runoff rate.

Planning Policy Statement 19 allows local planning authorities to stipulate high levels of the code where there are local circumstances that allow and warrant it. As such, LPAs can designate CDAs as high flood risk areas.

Wherever possible, this should be achieved through the use of SUDs, constructed within the development site. The effectiveness of a flow management scheme within a single site is limited by site constraints including (but not limited to) topography, geology (soil permeability), development density, adoption issues and available area. The design, construction and ongoing maintenance regime of such a scheme must be carefully defined at an early stage.

9 DCLG (2007) Planning Policy Statement: Planning and Climate Change - Supplement to Planning Policy Statement 1

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F . Guidance for Development Control

F.1 Introduction

The purpose of this section of the report is to provide guidance to Development Control staff on using the SFRA.

The LPA are the decision-makers on planning applications for new development. Whilst it is the developer’s responsibility to fully consider flood risk issues, the LPA should be involved during any pre-application discussions.

Flood risk needs to be considered at a strategic level by Development Control officers, even though applications for proposed developments are submitted on a site by site basis. Applications may need to fit within a wider flood risk management strategy for an area rather than on a site by site basis.

Consideration of flood risk within the context of an individual planning application is shown on Figure 8. It highlights flood risks that may be taken into account using information provided within the Newcastle Level 1 SFRA, as well as the guidance provided in PPS25 and the EA's Standing Advice.

Check whether the Sequential and Exception Tests have already been applied

� Refer developer to LDD and supporting evidence that the Sequential Test has been applied (the site may have already been assessed)

� Refer developer to LDD and supporting evidence that it is likely that development can pass the Exception Test

� If so, Sequential Test and likelihood of passing the Exception Test have been assessed

Apply the Sequential and Exception Test if necessary, using evidence supplied by the developer, referring them to the following documents:

� The SFRA (to inform the Sequential Test) � Sequential Test Spreadsheet (to compare similarities with sites

already assessed) � SFRA maps (to review the scale and nature of flood risk)

Consult with EA and other relevant stakeholders to

� Assess flood risk constraints associated with a potential site Scope an FRA

� Determine the scale and nature of risk from all sources of flooding � Confirm whether the site is located within a CDA � Review and develop any strategic mitigation requirements identified in

the LDD? Consult with EA over FRA and

� Approve or reject

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If an individual site has been identified for development, Development Control should check that the development passes the requirements of the Sequential Test and is likely to pass the Exception Test, where applicable. The application should be supported by a detailed and site-specific FRA which meets the requirements of PPS25.

F.2 The Sequential Test and Exception Test

If the proposed site is already identified in a Sequentially Tested LDD, the developer must still apply the sequential approach to site layout and land use vulnerability.

However, where a site has not been identified within a Sequential Tested LDD, a Windfall Site for example, then the Sequential Test will need to be applied. To do this the developer will need to provide evidence to the LPA that there are no other reasonable alternative site, within a lower risk area, where the development could be located. The LPA will then use this information to apply the Sequential Test.

Developers will need to provide evidence that Part C of the Exception Test can be passed for both allocated and windfall sites. If required, and in accordance with the vulnerability of the proposed land use. Development Control will then need review the evidence provided and decide whether a site passes the Exception Test.

F.3 Supporting FRA

All applications for development should be supported by a site-specific FRA prepared in accordance with the guidance provided in sections 3.70 to 3.89 of the PPS25 Practice Guide.

Development Control should refer developers to the SFRA, appropriate LDD and flood risk policies that may influence development proposals.

If the site or community has been identified to be at risk of flood from any source, Development Control, and the developer, should consult the EA and other relevant flood risk consultees, such as Northumbrian Water, to identify known flood-related site constraints and agree the scope of the FRA.

The Environment Agency Standing Advice should be used at this stage. This can be accessed online at http://www.environment-agency.gov.uk/research/planning/82584.aspx

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G . Guidance for Emergency Planners

G.1 Introduction

This section provides guidance on how Local Authority Emergency Planners can use the outputs of the SFRA to update Multi-agency Flood Plans and provide advice on Flood Plans written by developers for new development.

G.2 Emergency planning overview

Under the Civil Contingencies Act (2004) the council is classified as a category 1 responder. During an emergency such as a flood event, coordination with the other category 1 responders (including the emergency services and the Environment Agency) is essential to guarantee the safety of residents. Under the Civil Contingencies Act, the Local Authority holds a statutory duty to provide civil protection to their communities to ensure human welfare; environmental stability and UK security are not affected. Under the Act, risk assessments and planning is arranged through Local and Regional Resilience Forums (LRF/RRF).

The overall purpose of LRF/RRF is to ensure that there is an appropriate level of preparedness to enable an effective multi-agency response to emergency incidents that may have a significant impact on communities.

The aim of the SFRA so far has been to try an avoid development in flood risk areas in the first instance. However, it has also been accepted that there is current development in flood risk areas and there will need to be a level of continued regeneration. Minimising flood risk to people, property and the environment should be considered. Flood defences go some way in reducing current flood risks by providing a standard of protection. However there is still a residual risk associated with them from overtopping or failure. Flood Warning is an integral part of flood risk management. The Environment Agency is the lead authority and has responsibility for warning the public, local authorities and emergency services.

Along with the Environment Agency Flood Warning systems, there are a range of Flood Plans at a regional and local level, outlining the major risk of flooding and the tactical and

Emergency Planners should use the Guidance in this SFRA User Guide, PPS25 and its Practice Guide to: Update Multi-agency Flood Plans

� Using the overall assessment of flood risk provided in the Level 1 SFRA

� Using the assessment of residual risk in the Level 2 SFRA Provide advice on developer Flood Plans for new development

� Using outputs from the Level 1 and Level 2 SFRAs Raise awareness of flood risk from all sources

� Using outputs from the Level 1 and Level 2 SFRAs

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operation plan for key responders. These plans are incorporated in Local Authority Major Incident Plans.

This SFRA contains useful data to allow emergency planning processes to be tailored to the needs of the area and be specific to the flood risks faced. The detailed maps and GIS layers provided should be made available for consultation by emergency planners during an event.

G.3 The Sequential Test and Exception Test

The SFRA provides a number of flood risk data sources that should be used when producing or updating flood plans.

The Local Authority Emergency Planners are advised to consider and understand the possibility, likelihood and spatial distribution of all sources of flooding, including fluvial, tidal, surface water and sewer, man-made bodies of water including canals and reservoirs and groundwater flooding, as discussed in this SFRA and associated mapping. Key SFRA mapping to be reviewed include:

� Understanding the risk from different sources of flooding � Flood zone maps � Climate change maps � Flood depth maps � Consider and understand the residual risk associated with flood risk management

infrastructure � Flood defences, overtopping � Detailed surface water maps

Use the data in the SFRA to:

� Update the Local Authority Flood Plan to reflect the above findings � Consider the need for evacuation plans for existing vulnerable institutions in the

floodplain and other areas at high flood risk � Consider reviewing and updating safe evacuation routes and access routes for

emergency services from any existing area of flood risk to rest centres, avoiding routes that may be flooded

� Review the Newcastle Community Risk Register (CRR)

G.4 Planning Approval – Flood Plans including flood warning

As a condition of planning approval flood evacuation plans should be provided by the developer which aim to safely evacuate people out of flood risk areas, using as few emergency service resources as possible. These plans should detail any prearranged emergency arrangements including dry evacuation routes, flood warning, location of rest centres and safe havens. It is recommended that any flood evacuation plan written is prepared for review by the council and the EA.

According to the PPS25 Practice Guide, flood warning and evacuation plans should include the following information:

How flood warning is to be provided?

� Availability of existing flood warning system

� Rate of onset of flooding

� How flood warning is given

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What will be done to protect the development and contents

� How easily damaged items we be relocated

� The availability of staff/occupants/users to respond to a flood warning

� The time taken to respond to a flood warning

Ensuring Safe occupancy and access to and from the development

� Occupants awareness of the likely frequency and duration of flood events

� Designing and locating safe access routes

� Preparing evacuation routes

� Identify safe locations for evacuees

� Vulnerability of occupants

� Expected time taken to re-establish normal use following an event

G.5 Flood Awareness

Emergency Planners should also use the outputs from the SFRA to raise awareness within local communities. This should include raising awareness of measures that people can take to make their homes more resilient to flooding from all sources and encouraging all those at fluvial flood risk to sign up to the Environment Agency’s Flood line Warnings Direct service.

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H . Flood Risk Management Measures

H.1 Introduction

Throughout the risk-based sequential approach, opportunities should be taken to minimise flood risk at every stage of the planning process.

Mitigation measures should be seen as a last resort to address flood risk issues.

Mitigation measures must be designed to provide an appropriate level of protection to a site for the lifetime of the development. At many sites it may be technically feasible to mitigate or manage flood risk. However, the potential impacts of mitigation measures on flood risk to the surrounding community must always be considered. Where the depth of flooding is substantial, these mitigation measures may result in practical constraints to development with significant financial implications.

The minimum acceptable standard of protection against flooding for new property within flood risk areas is the 1% AEP flood event for fluvial flooding (0.5% if tidal), including allowance for climate change over the lifetime of the development.

H.2 Strategic Approach

Mitigation measures should be considered on a strategic basis to avoid a piecemeal approach and partnership is advocated between the LPA and EA. Measures should also be integrated with wider EA flood risk management works and strategies such as the CFMP.

Outline flood risk mitigation strategies should consider the wider, cumulative impacts of mitigation. This requires master-planning an area from a flood-risk perspective.

In summary, taking a strategic approach to flood risk management involves consideration of:

� Avoidance of development in flood risk areas; � Implementing a sequential approach to site layout, substituting higher vulnerability

development in lower flood risk areas; � Considering flooding from all sources; � Wherever possible, using open land or green infrastructure to reduce risk, (e.g. by

providing compensatory flood storage); � Adopting mitigation measures that contribute to the wider community objectives

for flood risk management in risk areas, (developers should aim to reduce risk to the wider community);

� The design and use of SUDs; and, � Preparing emergency flood plans.

H.3 Reducing Flood Risk through Site Layout and Design

Flood risk should be considered at an early stage in deciding the layout and design of a site to provide an opportunity to reduce flood risk within the development.

The PPS25 Practice Guide states that a sequential, risk-based approach should be applied to try to locate more vulnerable land use to higher ground, while more flood-compatible development (e.g. vehicular parking, recreational space) can be located in higher risk areas.

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Waterside areas, or areas along known flow routes, can be used for recreation, amenity and environmental purposes, allowing the preservation of flow routes and flood storage, whilst at the same time providing valuable social and environmental benefits contributing to other sustainability objectives. Landscaping should ensure safe access to higher ground from these areas, and avoid the creation of isolated islands as water levels rise.

The EA will have to consent any works within 5 metres of a main river. It is likely that the EA will require an unobstructed access and maintenance easement within these areas."

H.4 Modification of Ground Levels

Modifying ground levels to raise the land above the required flood level is an effective way of reducing flood risk to the site in question.

However, in most areas of fluvial flood risk, conveyance or flood storage may be reduced by raising land within the floodplain, adversely impacting on flood risk downstream. Compensatory flood storage must be provided, in general, on a level for level, volume for volume basis on land that does not currently flood but is adjacent to the floodplain. In general it should be in the vicinity of the site and within the red line of the planning application boundary (unless the site is strategically allocated).

Where the site is entirely within the floodplain it is not possible to provide onsite compensatory storage.

The need for compensatory storage must been discussed at the earliest stage of planning as this will be a major constraint as this requirement may have significant implications for the yields achieved for individual sites.

H.5 Raised Defences

Construction of raised floodwalls or embankments to protect new development is not a preferred option, as a residual risk of flooding will remain. Compensatory storage must be provided where raised defences remove storage from the floodplain.

Temporary or demountable defences are not acceptable flood protection for a new development.

H.6 Developer Contributions to Flood Defences

In some cases, it may be necessary for the developer to make a contribution to the improvement of flood defence provision that would benefit both the development and local community.

H.7 Building Design

Raising of floor levels within a development avoids damage to the interior, furnishings and electrics in times of flood. If it has been agreed with the EA that, in a particular instance, the raising of floor levels is acceptable, they should normally be raised to 600mm above the maximum water level during a 1% AEP event including allowance for climate change.

Making the ground floor of a building water-compatible (for example a garage), is an effective way of raising living space above flood levels.

Constructing a building on stilts is not considered an acceptable means of flood mitigation for new development. However it may be allowed in special circumstances if it replaces an existing solid building, as it can improve flood flow routes. In these cases attention should always be paid to safe access and egress and legal protection should be given to ensure the ground floor use is not changed.

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H.8 Resistance and Resilience

The 2007 document ‘Improving the Flood Performance of New Buildings’ provides further details on possible resistance and resilience measures10.

Temporary Barriers

Temporary barriers consist of moveable flood defences that can be fitted to doorways and windows. On a smaller scale It is likely that the EA will require an unobstructed access and maintenance easement within these areas, temporary snap-on covers for airbricks and air vents can also be fitted to prevent the entrance of flood water.

Permanent barriers

Permanent barriers can include built-up doorsteps, rendered brick walls and toughened glass barriers.

Wet-proofing

This involves designing interiors to reduce damage caused by flooding by, for example:

� Installing electrical circuitry at a higher level with power cables being carried down from the ceiling rather than up from the floor

� Using water-resistant materials for floors, walls and fixtures Resilience measures will be specific to the nature of the flood risk, and as such will be informed and determined by the FRA.

H.9 Making Development Safe

Safe Access and Egress

The developer must ensure that safe access and egress can be provided to an appropriate level for the type of development.

As part of the FRA, the developer should review the acceptability of the proposed access with the EA.

For the purpose of the SFRA it is considered appropriate to provide low hazard access and egress routes associated with new housing developments. Environment Agency guidance suggests that all development should have a dry access and egress in the 1% AEP event.

10 Communities and Local Government (2007) Improving the Flood Performance of New Buildings – Flood Resilient Construction

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Flood Warning and Evacuation

Emergency plans should be in place for all properties at residual risk of flooding. Those developments which house vulnerable people (i.e. care homes and schools) will require more detailed plans.

H.10 Making Space for Water

Opportunities for River Restoration and Enhancement

All new development close to rivers should consider the opportunity to improve and enhance the river environment. Developments should look at opportunities for river restoration and enhancement as part of the development. Options include backwaters, de-silting, in-channel habitat enhancement and removal of structures. When designed properly, such measures can have benefits such as reducing the costs of maintaining hard engineering structures, reducing flood risk, improving water quality and increasing biodiversity. Social benefits are also gained by increasing green space and access to the river.

Opportunities for Floodplain Restoration

It is an objective of PPS25 to safeguard land from development that may be required for current or future flood management. In areas of high flood risk there may be a strong case for allowing previously developed sites to return to functional floodplain in urban areas where they can convey and store flood water reducing the risk of flooding to development.

Buffer Strips

Developers should set back development from the landward toe of fluvial defences (or top of bank where defences do not exist) and this distance should be agreed with the EA. This provides a buffer strip to ‘make space for water’, and ensure access to defences is maintained.

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I . Consultation and Data Management

I.1 Introduction

To carry out an appropriate and comprehensive assessment of flood risk across Newcastle, it was essential to collate and build upon the best available data and studies already carried out.

The EA Flood Map is the main source of fluvial and tidal flooding information for England and Wales and is the basis of the PPS25 Flood Zones. However, the SFRA must also consider flooding from all sources and this is only achievable through consultation with those stakeholders with specific interest or knowledge in other sources of flooding. This data collection process is a key part of the SFRA. PPS25 outlines a number of key consultees to the planning process.

I.2 Data collection and review

A critical phase in the project delivery is the collection and review of existing data. This is done through the SFRA consultation process. The data sought relates predominantly to known or perceived flood risk issues within the area, development pressures and constraints, and current policy governing development within flood risk affected areas.

I.3 Assessment of current fluvial and tidal flood risk

Flood risk within the district of Newcastle City Council has been assessed, categorised and mapped to a level consistent with the nature and availability of existing data. In general the following key considerations were addressed:

� Identification of known and perceived flood risk areas, providing the initial ‘filter’ for key flood risk issue areas within the district.

� Review of the current Flood Zone Map and existing It is likely that the EA will require an unobstructed access and maintenance easement within these areas." hydraulic models, providing the broad (first pass) definition of High Risk Zone 3.

� Definition of the functional floodplain. � Location and definition of the standard of existing defences and identification of

areas that may be at risk from defence failure, requiring further investigation in Level 2.

� Identification of development areas which would is it is likely that the EA will require an unobstructed access and maintenance easement within these areas. charge surface water runoff to critical ordinary watercourses and/or known flooding issue areas, to ensure the impact upon upstream and downstream properties is adequately considered (irrespective of any flood risk posed to the proposed development).

� Definition of areas subject to development pressure and/or regeneration. � Review climate change and land use management impacts.

Climate change and associated sea level rise has the potential to significantly increase the consequences of flooding, and consideration must also be given to the sustainability of new development under climate change and extreme event scenarios.

The Tyne CFMP and the Climate Change Action Plan for the North East have also been used as a source of climate change information for Newcastle.

Consideration has been given to the implications of wider land management practices on flood risk in the area. This was based on existing information such as the Tyne CFMP.

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Flood risk from other sources and the potential for Sustainable Urban Drainage Systems (SUDs) have also been assessed.

This stage provided an indication of overland flow routes and areas prone to surface water flooding and sewer flooding.

I.4 Outputs and application of the Sequential Test

The results for the Level 1 SFRA have been used to produce maps and GIS layers of flood risk from all sources. Allocated development areas within Newcastle have then been combined with the identified Flood Risk Zones, and each site subsequently categorised in accordance with the PPS25 Sequential Test.

I.5 Key Stakeholders

Newcastle City Council

Newcastle City Council was the main stakeholder during the preparation of this SFRA. They focused the scope of the SFRA and provided the detailed information needed for its production.

An initial meeting was held to discuss the requirements of PPS25 in producing a Level 1 SFRA and to determine the main tasks needed to be completed. The meeting also outlined the Council’s own timetable for preparing an evidence base for their LDF process.

Much correspondence has occurred since the initial meeting, requesting information on historical events.

Newcastle City Council supplied numerous datasets including:

� SHLAA data; � Historical flood data; � Ordinary Watercourse data; and � OS MasterMap.

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Environment Agency

The EA is a statutory consultee for RSSs, LDDs, Sustainability Appraisals, Strategic Environmental Assessments and for all planning applications within Flood Zones 2 and 3 (except minor development) or over 1 hectare in Flood Zone 1.

With regards to the Newcastle City Council SFRA, the EA has discretionary powers under the Water Resources Act (1991) to manage flood risk and, as a result, hold the majority of flood risk data in the UK. Separate departments were consulted via the External Relations Team including Development Control, Flood Mapping and Reservoir Safety Teams on the SFRA approach and available data. A full list of data provided by the Environment Agency is available in the Data Register. Key information supplied by the EA is summarised below:

� Tyne Catchment Flood Management Plans; � Strategic flood risk mapping models; � LiDAR data (Geomatics Group); � Historical flood data; and � Flood warning data.

The EA was also consulted on the draft version of the Newcastle City Council SFRA and their comments and guidance have been included within Appendix M of this report.

Highways Agency

All trunk roads and motorways have the potential to impact on flood risk. This is especially the case in an urban environment when roads can form potential flow routes or major structures such as bridges or culverts can significantly reduce the capacity of watercourses and, therefore, increase flood risk. Road networks that are at risk of flooding also have the potential for wider impacts, reducing access and egress routes to and from sites which could increase the vulnerability of areas to flooding.

The Highways Agency were consulted on all known flooding incidents on their road network. However, no records were available for the Newcastle area.

Northumbrian Water

Sewerage Undertakers are identified as key consultees within PPS25 as they are generally responsible for foul and surface water drainage from developments. This SFRA should therefore take account of any information they may hold on public sewer capacity issues or known sewer-related historical flooding incidents.

Sewers are a significant source of flooding especially within urban areas. Flood risk data that Northumbria Water (NWL) hold on the public sewer network are seen as critical in getting an understanding of flooding from all sources in Newcastle.

Tyne & Wear Fire & Rescue Service

Emergency services are a good source of historical flood data. For instance the fire brigade keep a detailed register of all call-outs which include the source of flooding and the action taken.

The Tyne and Wear Fire and Rescue Service (TWFRS) provided this information (a database of over 300 flood-related call-outs dating back to January 2004).

SFRA Data Management & Review

This SFRA should be viewed as a ‘living’ document which is anticipated to be used in the day-to-day process of planning and development.

It is, therefore, important that datasets collected for the Newcastle City Council SFRA are transparent and accessible. A Data Register has been produced and supplied to Newcastle City Council listing all data received throughout the SFRA process.

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SFRA Data

Whilst this SFRA has been produced using the most up-to-date national guidance and flood risk data, it is recommended that the SFRA is updated on a regular basis. The Environment Agency has suggested that the SFRA should be reviewed every 3 to 4 years, unless there is a significant flood event or new information becomes available (which would justify an earlier review). A review of the SFRA should also be undertaken if there are any major national policy changes.

There are a number of key outputs from possible future studies and datasets which are known to be regularly updated. These should be incorporated in any update to the SFRA. 11 contains a list of SFRA review triggers.

Table 11 (SFRA Review Triggers)

Trigger Sources Possible Timescale

Tyne CFMP Environment Agency Updated every 5 years

Flood Zones Environment Agency Updated quarterly (significant change is not expected)

NFCDD Environment Agency Ongoing

Significant Flood Events All Unknown

Sewer Flood Data Northumbrian Water Unknown

Planning Policy Communities & Local Government

Unknown

Completion of SWMP/Drainage Strategy

Newcastle City Council Unknown

All datasets collected for the SFRA have been supplied to Newcastle City Council in the form of the SFRA report, Maps and Figures. GIS data used to produce the maps have also been supplied. Once maps or the SFRA document is updated it should be reissued to the relevant stakeholders.

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J . Newcastle City Council - Sequential Test Spreadsheet

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K Newcastle City Council - Data Register

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L SFRA Maps

� Set A: PPS25 Flood Zones � Set B: Flood Zone 3 Depths � Set C: Flood Hazards � Set D: Flood Risk Management Measures � Set E: Areas Naturally Vulnerable to Surface Water Flooding � Set F: Climate Change Sensitivity � Set G: Critical Drainage Areas

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M Response to EA Level 1 review comments

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Environment Agency - North East Region Tyneside House Skinnerburn Road Newcastle Business Park NEWCASTLE UPON TYNE NE4 7AR For the attention of Cameron Sked, Planning Technical Specialist Our Ref: HK\2009s0275-S-L005-1.doc 19 February 2010 Dear Sirs, Newcastle City Council Level 1 SFRA Thank you for your response to our SFRA, received by email 18 February 2010. We are pleased to read that, in general, your response is positive and would suggest that this SFRA actually exceeds the minimum requirements for a Level 1 assessment. I have summarised our response to each of your comments below. For reference I have included your original comments in italics. I hope this summary provides you with further clarification and assurance. I would appreciate your further response to this letter so that we may ensure that a positive SFRA that is fit for purpose is promoted by Newcastle City Council. “Functional Floodplain We are not entirely comfortable with the approach to Functional Floodplain in relation to Brownfield sites, i.e. no functional floodplain on Brownfield sites. As outline within the PPS25 Practice Guide developments on Brownfield land should not be discounted as they could potentially store and/or convey flood water. Also Brownfield sites could be used as an opportunity to enhance natural floodplains, where appropriate. Until further modelling has been undertaken to establish/rule out of Brownfield sites allocated in the council boundary could allow water to store or convey on site at the 1 in 20 year then the precautionary principle should apply and should be classed as Flood Zone 3b.” We are in agreement that a brownfield designation should not imply that a potential development site is outside of the Functional Floodplain. However, we are also aware that a presumption of 3b (where a 3b designation cannot be supported by historical or modelling results) could either: 1) Prevent by default any site that is within FZ3 from being put forward for development; and, 2) Potentially hinder key regeneration within an area, without first fully understanding flood risks. As part of this SFRA we have identified all current sites that are within 3b and the Council fully understands the constraints to development within these areas. Your letter correctly indentifies that eight sites are located, at least partially within 3b. However, these sites are for water compatible development. Any new or windfall sites will need to pass the PPS process and developers will obviously need to demonstrate that sites are not within the Functional Floodplain, irrespective of brownfield / greenfield designation.

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Newcastle Council has identified all sites that encroach into FZ3 as requiring more detailed assessment at Level 2. However, exiting brownfield sites should not, by default be considered as 3b. This is in keeping with sections 4.90 and 4.91 of the Practice Guide. The SFRA stipulates the need for developer to undertake further site specific assessment to confirm the level of risk. PPS Practice Guide:

“Paragraph 7.3 We support the approach that no other development than water compatible would be allowed in FZ3b.” In accordance with the PPS25 our statement will be updated to include “Essential Infrastructure” “8 allocations are sited partially in FZ3b and as such would have principle objection to development in this area if it is not water compatible use. Sequential approach and implementation of buffer strips and enhancing floodplains should be considered in these areas.” Of these sites four are categorised as Strategic and encompass significant areas of land. The Council are not proposing development, other than water compatible, within the 3b element of these areas. As these are large Strategic areas of land and we would envisage a pragmatic response, rather than an objection in principle, to development planning. Of the 4 ELR sites, construction is either underway, planning has been approved or water compatible development, including wind turbines, is planned. Since submission of our SFRA to you in December the Council have continued to review and comment on individual development sites. The Council have also removed inappropriate or unnecessary development in higher risk areas. Those areas that remain are either undergoing further assessment or are subject to a Level 2 appraisal. Again the Council fully understands the constraints to development within 3b areas. We also understand that the Ouseburn model is due to be updated by JBA to take account of revised hydrology. This updated modelling will improve definition of 3b areas.

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“Climate Change We agree with the approach that has been undertaken i.e. where a model is available then 20 % increase in flows for fluvial and Tidal PPS25 and UKCIPO9 has been used. Where there is no model Flood Zone 2 will be used. We consider Table 2 will be a useful tool for practitioners, planners and developers.” No comment “SUDS It is recommended that site specific developments should investigate sustainable drainage options for sites that are susceptible to Surface Water flooding but there has been little indication of site investigations. We would recommend that the Level 2 investigations consider further the suitability of the soils for the allocation sites instead of passing this responsibility and cost to the developer. Also it is sited in Newcastle LDD Policy that no development should increase the risk of flooding, including drainage, and suitable sustainability mitigation should be used. A map showing the soil types in the catchment would be very useful and has been provided in other SFRA we have been consulted on.” The basis for development and the Council’s approach to surface water management, as outlined in the SFRA, is that new development will not increase the volume of surface water being discharged from a site. Wherever possible new development should lead to a reduction in surface water discharge. The soils map for Newcastle does not provide any meaningful information as the area is highly urbanised. We have consulted with the British Geological Survey and appreciate the limited benefit of understanding general ground conditions, in the absence of other key information such as ground water levels, and 3 dimensional variations in ground conditions etc. Many Councils consider storm water attenuation tanks and oversized surface water drainage systems as a viable SUDs techniques particularly when located in highly urbanised and confined areas. Whilst we do not consider it appropriate for the Council to undertake the long-term monitoring of ground conditions for all potential development sites, we have recommended to the Council that some further assessment at key Strategic Sites is undertaken. Surface Water Issues and SWMP We are concerned that 22 of the 26 development sites are susceptible to surface water flooding. 8 of these are of great risk and we would recommend that these developments do not come forward until sustainable drainage options have been appraised and investigated fully, again as part of the SFRA Level 2 process. Within this SFRA our Areas Susceptible to surface water Flooding is referred to and maps are produced in the Appendices. It is agreed this level of detail is insufficient and it will be expected for the Level 2 SFRA or Site Specific FRA’s, which ever comes forward first, will appraisal this risk for the each proposed allocated development site. Again the Council has reviewed the sites and those remaining are subject to further assessment at Level 2. We have already recommended to the Council that they consider more detailed surface water mapping, including assessing the implication of development and buildings on flow routes and depths etc as part of the Level 2 assessment. It should be noted, however, that it is not necessarily the number of sites susceptible to flooding that is the principle concern. It is rather the identification of those sites where significant depths of flooding are predicted. These are the sites that need to be avoided. In this instance the percentage areas at higher risk of flooding are low (the council has reviewed the sites on numerous occasions since submission of the draft text). More detailed assessment at Level 2 will enable sites with ‘moderate risks to be evaluated more fully.

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“Critical Drainage Areas These are mapped in the appendices and the process of identifying these is logical and reasonable. We agree that refinement of these areas will be needed as part of the SWMP. We agree and have knowledge of the CDA identified in the table provided in the SFRA.” No comment “Flood Hazard criteria We recommend that the Flood Ratings and thresholds for Development Planning and Control purposed should be used – DEFRA Science and Research Project Table 13.1 of FD2320/TR2 AND Figure 3.2 of FD2320/TR1.” Flood hazard to be developed at Level 2 “Paragraph H.4 “Where the site is entirely within Floodplain it is not possible to provide on site compensation.” We accept this would be the case but we would have an in principle objection to any development of this nature in fluvial flood risk areas until “off site “storage was located and proven to work (hydrologically and hydraulically connected). This is based on our national floodplain compensation policy and we consider that development should not lead to an incremental loss of flood plain. We would recommend if there are any sites that are fully in floodplain and compensation will be problematic then the SFRA Level 2 should look strategically where land could be allocated for this purpose.” Agreed for Level 2 Paragraph H.10 We would recommend that buffer strips be 10 metres. If this is EA policy please can you provide a copy of the relevant policy document? Appendices Set A PPS25 Flood Zones Good map that shows an overview of the allocations, SHLAA Sites and Employment Land Review Sites. Set B Flood Depths in Flood Zone 3 Scale shown provides as over view but no great “site level” detail. As intended, Council to be provided with digital deliverables. Set C Flood Hazard Map “Our observations are it’s a very “ busy” map and the Combined SHLAA and ELR colour legend and Flood Depth 0.5-1.0 legend are very similar and could be confusing/ misinterpreted.” Already amended “Set E SW Flooding Map Very busy map and we would recommend this map to be spilt into two showing the different surface water problems -i.e. map showing sewers capacity limits, DG5 info and historical data etc.” The available information of historical and DG5 flood data is rather poor, to separate out the information at this stage will not help to pinpoint areas of surface water flooding. Perhaps this

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would most appropriately be developed during the Level 2 SFRA when Northumbrian Water are likely to provide more detailed information. If you require any further information please give me a call to discuss further. Yours faithfully, For Jeremy Benn Associates Limited Howard Keeble Project Manager [email protected]

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