Comment: At present, the Environment Agency has only reviewed a draft of the Level 1 and 2 SFRA, as part of the Local Plan Regulation 19 consultation. The SFRA’s currently does not clearly demonstrate how high and medium flood risk site allocations have been justified by applying the Sequential Test, and where appropriate, the Exception Test. There remain some site allocations located in areas at high risk of flooding (either existing or in the future) which are inappropriate and go against both national planning policy and guidance.

Currently the Environment Agency has not reviewed the final draft of the flood defence infrastructure report. Additionally, there may be a requirement to provide further guidance outside of the flood defence report to assist in supporting planned development. Proposed wording changes are below:

‘The Environment Agency are working with the Council to produce further details which will include, but are not limited to, a flood defence infrastructure report. These details will help support planned development.’