Data provided by the Environment Agency shows that in 2012 to 2013, the majority of planning applications objected to on flood risk grounds were rejected specifically because of an unsatisfactory FRA (Flood Risk Assessment) or FCA (Flood Consequence Assessment).
We analysed the data provided by the EA and found that, of the 2638 planning applications objected to on flood risk grounds, 997 (38%) were due to the submission of an “unsatisfactory FRA/FCA” whilst a further 601 (23%) were specifically due to an unsatisfactory “surface water” FRA/FCA. In total 61% of planning applications objected to on flood risk grounds were rejected due to the provision of an unsatisfactory FRA or FCA.
19% failed to provide an FRA when required to do so
Further analysis of the data shows that the 3rd most common objection is “PPS25/TAN15 – Request for FRA/FCA”. PPS25 (now superseded by NPPF) provides the policy framework for England and sets out the criteria for when a Flood Risk Assessment is required. TAN15 is the equivalent for Wales. “Request for FRA/FCA” indicates that 19% of planning applications failed to provide an FRA or FCA when they were required to do so in line with the policy set out in PPS25 or TAN15 guidelines.
9% of objections relate to the Sequential test
A sequential test helps to steer development to areas with the least probability of flooding. Again, PPS25 & TAN15 provide guidelines on the application of the test. After analysing the EA’s data we found that 108 planning applications (4%) were objected to on the grounds that “no sequential test” was provided. A further 5% were objected to because the test was not “adequately demonstrated” or because “the vulnerability [is] not appropriate to the Flood Zone”.
2% of objected applications relate to the Exception test
Policy guidelines allow development to be permitted in certain cases despite the flood risk, however, an Exception test must be passed. In 2012-13, 41 applications (2%) were objected to because Part C of the test was not demonstrated adequately.
5% of objections relate to culverts or proximity to watercourses
In 2012-13, 110 planning applications (4%) were objected to as the development potentially threatens the EAs ability to maintain watercourses or because existing flood defences may be compromised. A further 26 planning applications (1%) were objected due to culverts. The least common of all EA objections, culverts are cited as an issue because they can back up flows in a watercourse in times of a flood.
How to avoid planning objections on flood risk grounds
The EA’s data highlights a number of key issues which planning and property professionals need to be aware of.
Avoiding the types of planning objections noted here can be achieved by:
- Running interim flood risk reports to check if an FRA is likely to be required
- Using a reputable and experienced FRA specialist when an FRA or FCA is required
- Consider commissioning a Flood Risk Scoping Report (FRSR) to assess the suitability of a development site and to inform build at the earliest stage of development
Ambiental’s team of flood risk specialists have experience across a wide range of situations, from small domestic extensions to large scale developments and we have an extremely high planning approval rate. For further details get in touch via our contact form.