We provide our views on the proposed changes to planning policy for flood risk in Wales, due to be finalised in September 2020.
TAN 15 revisited
As we reported last time, TAN 15 was first released in 2004. Much has changed since then in the understanding of flood risk management shared by all involved: regulators, local authorities and consultants.
It’s time for a change.
Following a review in 2018, TAN 15 was updated and released for consultation in autumn 2019. The consultation period expired in January 2020.
The Welsh Government are now considering the consultation comments received, with a view to final release of TAN 15 in late 2020. The outcomes of the consultation will also be published in a separate document.
We submitted a number of responses, based on our experience and understanding.
- We welcome the move from a precautionary to a sequential risk-based approach.
- We believe that replacing the Development Advice Map (DAM) and NRW flood map with the Wales Flood Map (WFM) to will improve clarity greatly. We also think it is vital to map areas with defences consistently, as most major conurbations in Wales are at some risk of flooding and are served by defence infrastructure.
- We recognize that TAN 15 now clarifies the main roles and responsibilities of key organisations in the planning system (e.g. Lead Local Flood Authorities) and we believe it would be useful to include the responsibilities for developers as well.
- We agree that the Welsh Government’s proposed holistic approach is necessary, building on the importance of Strategic Flood Consequence Assessments (SFCAs) as a tool to enhance flood risk assessment within development plans. We will be interested to monitor the consistency of implementation of this, as funding and resource constraints vary across planning authority boundaries. We all know that local authorities are significantly resource constrained.
- We are concerned that TAN 15 should clarify requirements for development where flood risk is primarily from watercourses that are not included on the WFM because their catchment area is too small.
- We believe a national policy on surface water risk management, consistent across authority boundaries, is preferable to allowing local authorities to determine their own policies.
- We welcome the increased flexibility of the new FCA checklist and updates to the applicability of the Justification Test, but we believe that replacing floodplain storage lost through development on a ‘level for level’ basis will be too restrictive, particularly for smaller developments in urban centres. Replacing storage lost with additional storage at the same flood level will necessitate excavation, which does not seem appropriate if modelling shows that a development will not increase flood risk elsewhere.
The last word
The 2019 update of TAN 15 has improved clarity in a number of key areas, particularly with the replacement of the DAM with the single, integrated Wales Flood Map.
We look forward to reviewing the consultation responses and seeing how far these are taken into consideration in the final release.