Policy EN7: Flood Risk and Development

This policy needs to state that the Sequential test will be informed by the hazard mapping contained within the Strategic Flood Risk Assessment (SFRA). An example of this approach is contained within Shepway DC's Core Strategy submission document which has proposed in Policy SS3 c.1:

"that no residential development, other than replacement dwellings should take place within areas identified as "extreme risk" as shown on the SFRA 2115 climate change hazard maps."

These areas are generally shown to be on parts of Romney Marsh. Although Rother DC's own SFRA does not have an extreme risk zone, a similar policy that limits the type of development that would be acceptable in those areas of high hazard under present day conditions needs to be included to guide developers. This kind of approach can be very helpful with the ST at the planning application stage.

Reference is made in Policy EN7 to incorporate sustainable drainage systems (SuDS) into new development. However, this is a broad subject and more guidance for developers needs to be provided. For example, policy CS20 of the Ashford Borough CS is supported by a Sustainable Planning Document on SuDS. This describes how not only should SuDS be used to restrict runoff to the appropriate discharge rate, but they should be used to maintain or improve the quality of the receiving watercourse. They can also be used to enhance local biodiversity and public amenity and therefore, potentially make an important contribution to Local Authority responsibilities under the Water Framework Directive. The Ashford SPD recognised these benefits and also provides guidance on future responsibility for maintenance of SuDS.

In addition it should be noted that the Cuckmere and Sussex Havens and Rother and Romney Catchment Flood Management Plans (CFMP) that proposed actions for a number of existing settlements within Rother District are to reduce run-off and to develop a Surface Water Management Plan (SWMP). We strongly recommend a policy on details of SuDS and responsibility for subsequent management, similar to that within the Ashford CS, be developed as part of the Rother CS in order to help meet the objectives of the CFMPs.

Policy EN7 relates to Flood Risk and Development. This policy is supported as a whole, however it is suggested that text be added to provide reference to flood defence schemes which can alleviate the risk of flooding. It is suggested that additional text could be provided in section (i) as follows:

....the applicant will be required to submit a site-specific Flood Risk Assessment, including details of existing or proposed flood defences which demonstrates that the development will be safe, will not increase the risk of flooding elsewhere and, where possible, will reduce flooding

Similar recognition (see repesentation on EN6) of designated sites and natural process that support them needs to be reflected in policy EN7 in relation to development and flood risk where appropriate.