BASE HEADER

Yes

ID sylw: 108183

Derbyniwyd: 05/03/2025

Ymatebydd: Bellway Homes (West Midlands)

Asiant : Cerda Planning

We broadly support the provisions of Policy J and the objective of reducing flood risk.
However, we consider that the provisions of the policy are not consistent with the NPPF, specifically regarding the sequential approach to locating development.
The NPPF continues to apply the sequential test to locate development outside flood zones 2 and 3, including in relation to pluvial flooding, and this includes all parts of a development site. Policy J refers to applying an ‘internal’ sequential test, by first accepting a development site which is in flood zones 2 or 3 and then designing out vulnerable parts of a development to locate this in lower flood zone areas – which could include locating vulnerable uses in flood zone 2. This is not the approach required by the NPPF (or PPG in respect of undertaking sequential tests). The policy should be amended to make clear that all development sites should apply the sequential test at site selection stage rather than layout design stage.
This approach should be applied to both plan making and development management.