The Planner introduced the report which provided details of the Sequential Test for Swale which had been prepared to demonstrate the flood risk on the sites that could be considered for development, as required by the National Planning Policy Framework (NPPF) as part of the Local Plan review.  The Planner stated that the aim of the Sequential Test was to steer new developments to the areas with the lowest probability of flooding.  He reminded Members that a Level 1 Strategic Flood Risk Assessment (SFRA) had been completed and reported to the Panel in November 2019.

The Planner drew attention to the Sequential Test document which was set-out at Appendix I of the report, and provided the results for each individual site.  The Planner reported that 200 of the 235 sites promoted for development had passed the test. He added that the sites that passed the Sequential Test should be considered first. 

The Chairman invited Members to make comments.

Councillor Eddie Thomas asked whether increased flooding from climate change had been considered as part of the Level 2 SFRA?  The Planner explained that the Level 1 SFRA included data on climate change, however the Sequential Test was just about flood risks as they were currently.

Councillor Benjamin Martin asked at what stage had utility companies been consulted.  The Planner explained that the Sequential Test was set-out in a specific way and once sites had been selected these issues could be addressed by the Level 2 SFRA.

Councillor Benjamin Martin asked how could the climate change work be linked to the SFRA work?  The Planner advised that Members needed to consider the Level 1 SRFA and Sequential Test separately when selecting sites. 

Councillor Angela Harrison raised concern that “exception test” sites might be agreed for development.  This would mean that at the planning application stage Members might have to agree developments on sites that were not suitable.  The Planner explained that the Environment Agency (EA) would be consulted and any issues would need to be resolved before the Local Plan was progressed. 

Councillor Mike Whiting raised concern about several sites on the Isle of Sheppey which were prone to flooding and the impacts this would have on park homes.  He also raised concern about the erosion at Eastchurch and other areas of the Isle of Sheppey.  He stated that it was important to ensure that park homes would not be at-risk from coastal erosion in years to come.

The Planner stated that park homes were classed as a more vulnerable development and the classification table included in Appendix I set-out what flood zones were not acceptable.  He explained that the Sequential Test only considered tidal and fluvial flooding risks.

Councillor Monique Bonney asked when flooding caused by surface water run-off would be considered as this was an issue with new developments, particularly in rural areas?  The Planer advised that included in the tables in Appendix I was information from the Level 1 SFRA which identified the percentage risk for each site from surface water flooding.  Any significant at risk sites identified would need to be considered as part of the Level 2 SFRA.

Councillor Monique Bonney spoke about local ancient drainage watercourses and would officers know about these?  The Planner advised that if Members were aware of any to contact the policy team direct.  These could then be included in the detailed Level 2 SFRA.

Recommended:

(1)      That Members note the content of the Sequential Test and that it be published and used as part of the evidence base for the Local Plan Review.