East Suffolk Council - Suffolk Coastal Local Plan (Adopted September 2020)

9 Climate Change

9.1 The National Planning Policy Framework sets out strong measures to address climate change as well as encouraging local planning authorities to set target contributions and promote the uptake of decentralised renewable or low-carbon energy in developments. Transitioning to a low carbon future, encouraging the reuse of existing resources (including conversion of existing buildings), and encouraging the use of renewable resources are measures which are promoted by the National Planning Policy Framework. The Government's recently published 25 year Environment Plan outlines a broader commitment to reduce emissions from 1990 levels by 80% by 2050. The Council will aim to contribute to this wider national commitment to address climate change.

Renewable Energy

9.2 East Suffolk is part of the Norfolk & Suffolk Energy Coast which is part of the wider East of England Energy Zone. The New Anglia Local Enterprise Partnership intends to maximise the energy opportunities in this area. This is an intention that the Council will endeavour to support, where possible. The former Suffolk Coastal area can contribute towards the generation of renewable energy, most notably through biomass and anaerobic digestion schemes, solar panel schemes and wind power, including turbines and landing points to serve off-shore provision. Proposals relating to offshore wind should also take account of relevant policies and guidance in the East Marine Plan.

9.3 The National Planning Policy Framework promotes and encourages schemes that utilise renewable energy resources. This should be in tandem with energy efficiency measures, particularly in any new development, and should be consistent with the need to safeguard residential amenity, the environment and the landscape.

9.4 National planning policy states that Local Plans should consider identifying suitable areas for renewable and low carbon energy development. Local planning authorities should also support community-led initiatives for renewable and low carbon energy taken forward through Neighbourhood Planning. The Government have stated that wind farm developments should only be granted planning permission if the site is identified as a 'suitable area' and the proposal has the backing of the local community. The level of local community support for low carbon and renewable energy proposals will be evaluated in terms of engagement related to planning applications and through the neighbourhood planning processes where applicable.

9.5 Proposals for wind energy and energy from biomass or waste of more than 50MW installed capacity are defined as nationally significant infrastructure projects and are determined by the Secretary of State. Policy relating to such proposals is contained in the National Policy Statement for Renewable Energy Infrastructure. Proposals for energy from waste schemes of less than 50MW will be determined by Suffolk County Council as Waste Planning Authority and policy for such schemes is currently contained in the Suffolk County Council Waste Core Strategy (2011).

9.6 Biomass and anaerobic digestion schemes can provide an important contribution to energy generation, in particular in areas not served by the national gas grid. However, there also exists the potential for such schemes to effect air quality. In this respect, proposals for energy generation from biomass will be supported in principle but particular consideration will be given to air quality impacts, transport impacts, proposals for associated buildings and, where relevant, grid connections.

9.7 Solar panel developments can range in scale from installations on individual buildings to solar farms, and can range in type, from in-built solar panels to mounted solar panels. Solar panel schemes will generally be supported, particularly in new development. Careful consideration will be given to the visual impact in sensitive locations including through design, siting and, where possible, natural screening.

9.8 In respect of wind power, much of East Suffolk's environment is a sensitive one and needs protection. Given the national and local recognition of the need to transition to a low carbon future, the option of resisting wind power generation entirely is not appropriate. The Local Plan will encourage onshore wind within the mix of the generation of renewable energy, most notably to serve local communities. Although generally encouraged, proposals will need to ensure they do not adversely affect the high quality landscape, natural beauty and special qualities of the Suffolk Coast and Heaths AONB, wildlife populations or habitats and avoid noise pollution across the former Suffolk Coastal District.

9.9 Reflecting the policy in the National Planning Policy Framework, applicants for wind energy development of one or more turbines will be expected to demonstrate how the local community has been involved in developing proposals and that the submitted scheme has the support of the local community. Where Neighbourhood Plans are produced, the opportunity exists to obtain local community support in the identification of suitable areas for renewable energy as part of the Neighbourhood Plan process. The Council aims to undertake a Supplementary Planning Document related to low carbon and renewable energy development, following completion of this Local Plan, to support this process.

9.10 Due to the potential for impacts on the landscape, the Suffolk Coastal Landscape Character Assessment (2018) and Settlement Sensitivity Assessment (2018), and any subsequent iterations, should be consulted when evaluating the landscape and visual impact of low carbon and renewable energy development. The cumulative impact of energy proposals could have potentially significant impacts on the East Suffolk countryside and the Council will be working closely with Government and other agencies to ensure issues related to the National Grid are considered comprehensively and not incrementally.

9.11 As not all renewable and low carbon energy installations require planning permission it is not always possible to monitor renewable energy capacity accurately. Therefore, actual installed capacity is likely to be higher than reported in the Authority Monitoring Reports.

Policy SCLP9.1: Low Carbon & Renewable Energy

The Council will support Neighbourhood Plans in identifying suitable areas for renewable and low carbon energy development, particularly where they relate to developments that are community-led. In identifying suitable areas, consideration should be given to the criteria listed below:

  1. They can evidence a sustainable and, ideally, local source of fuel;
  2. They can facilitate the necessary infrastructure and power connections required for functional purposes; and
  3. They are complementary to the existing environment without causing any significant adverse impacts, particularly relating to the residential amenity, landscape and visual impact, the natural beauty and special qualities of the AONB, transport, flora and fauna, noise and air quality, unless those impacts can be appropriately mitigated.

The Council will support low carbon and renewable energy developments, with the exception of wind energy schemes, where they are within an area identified as suitable for renewable or low carbon energy or satisfy the above criteria. Wind energy schemes must be located in an area identified as suitable for renewable or low carbon energy in a Neighbourhood Plan.

When the technology is no longer operational there is a requirement to decommission, remove the facility and complete a restoration of the site to its original condition.

Sustainable Construction

9.12 Buildings are no longer viewed as products of construction and engineering, but as products of place-making and design that reflect the environment in which they are situated. This is proven by the fact that sustainable construction does not solely relate to the physical structure of a building, it also relates to other aspects such as transport, waste and water management and in some cases, ecological value. Therefore, comprehensive sustainable construction that appropriately incapsulates the values of sustainability will be strongly supported by the Council. This will help to achieve the concept of 'environmental net gain' promoted in the Government's 25 year Environment Plan. Sustainable construction methods can also help to reduce the running costs of housing, helping to contribute towards objectives of improving the affordability of housing.

9.13 Sustainable construction methods, water efficiency standards and the energy consumption of buildings are largely controlled by Building Regulations. However, the Council is still able to require lower energy and water usage in new developments.

9.14 From October 2015, local planning authorities can require higher 'optional' Building Regulations standards to be met. For water efficiency the Government has introduced an optional technical standard that requires new housing to go further than Building Regulations and be designed to consume 110 litres/person/day, as opposed to 125 litres/person/day. The Environment Agency have identified East Anglia as an area of 'serious water stress' and the Anglian Water Resources Management Plan (2015) identifies lowering demand as one way in which this can be addressed. Requiring the optional standard to be met will contribute towards lowering demand for water use.

9.15 In the interests of mitigating climate change and to help achieve the objectives of the Suffolk Climate Action Plan, the Council will also implement higher energy efficiency standards and will expect all new developments of more than 10 dwellings to achieve a 20% improvement in C02 emissions performance above the Target Emission Rate of the 2013 Edition of the 2010 Building Regulations. Coastal development proposals should also take account of Policy CC2 of the East Marine Plan when minimising emissions. Higher energy efficiency standards need not be met if they amount to maladaptation, for example, designing buildings to maximise solar gain in winter without addressing the implications for overheating in summer.

9.16 For all non-residential development, the Council will expect compliance with BREEAM standards. BREEAM is a tool that allows the owners, users and designers of buildings to review and improve environmental performance throughout the life of a building. The Council expects all non-residential development to comply with these standards, as detailed in Policy SCLP9.2, to mitigate further against climate change.

9.17 Improved energy efficiency and a reduction in CO2 emissions in buildings can be achieved through various means including orientation, siting, photovoltaics and heat pumps. The Council supports viable and permissible methods of improving energy efficiency and reducing CO2 emissions in buildings.

9.18 The Council is mindful that local sustainable construction requirements lead to increased costs and may impact upon development viability (in this context defined as what is practical and affordable). On this basis and in exceptional circumstances where the additional costs attributed to achieving sustainable construction standards represent the overriding factor in preventing the site from being delivered, the Council will be prepared to consider detailed information on the viability of a particular scheme, where justified, to alter the sustainable construction requirements. The viability information must be compiled in line with viability guidance contained in Appendix G.

9.19 In order to allow for higher energy efficiency standards to be achieved, a meaningful proportion of the energy consumed by new builds or conversions should be provided from an on-site renewable source. The meaningful proportion should be considered on a case-by-case basis. Locally sourced, reused and recycled materials should also be used in the construction of new builds or conversions, where practicable. Where possible, circularity should be considered - that is the materials used in construction and the ability to deconstruct and reuse post use. Waste arising from construction itself should be minimised, where possible.

9.20 Major developments in particular, will have greater opportunities to incorporate high build standards due to economies of scale. Provision should also be made for 'environmental net gain' from new or conversion development, including infrastructure developments. Considering the fact that the principle of 'environmental net gain' is strongly promoted in the Government's 25 year Environmental Plan, this should be considered an imperative provision in new or conversion development, including infrastructure developments.

9.21 In recognition of the potential for conflicts between achieving sustainable methods of construction and conserving and enhancing the historic environment, Historic England's guidance relating to the application of the Building Regulations should be consulted when evaluating the energy efficiency of historic and traditionally constructed buildings.

9.22 As evidence of sustainable construction compliance for all new dwellings, the Council will require the submission of an interim compliance report prior to development commencement. A final compliance report will be required to be submitted upon development completion. This should be compiled in line with advice provided in the Building Regulations.

9.23 In order to demonstrate compliance with BREEAM standards, developers will be required to submit Design Stage Assessments and Post Construction Reviews, carried out by a qualified BREEAM assessor (as appropriate), for all planning applications for qualifying development.

Policy SCLP9.2: Sustainable Construction

All new developments of more than 10 dwellings should achieve higher energy efficiency standards that result in a 20% reduction in CO2 emissions below the Target CO2 Emission Rate (TER) set out in the Building Regulations. Exceptions should only apply where they are expressed in the Building Regulations or where applicants can demonstrate, to the satisfaction of the Council, that it is not viable or feasible to meet the standards.

All new residential development in the plan area should achieve the optional technical standard in terms of water efficiency of 110 litres/person/day. The use of locally sourced, reused and recycled materials, along with on-site renewable energy generation are encouraged in order to achieve environmental net gain in new build or conversion developments. Development proposals are also encouraged to set out measures for minimising waste arising from the construction process.

All new non-residential developments of equal or greater than 1,000sqm gross floorspace are required to achieve the British Research Establishment Environmental Assessment Method 'Very Good' standard or equivalent unless it can be demonstrated that it is not viable or feasible to do so.

Proposals should improve the efficiency of heating, cooling and lighting of buildings by maximising daylight and passive solar gain through the orientation of buildings.


Coastal Management policies

9.24 The coastal zone is a distinct part of the former Suffolk Coastal District containing a diverse range of interests such as Areas of Outstanding Natural Beauty, internationally and nationally important environmental areas, tourism destinations, Sizewell nuclear power plants, offshore wind infrastructure, Felixstowe Port, the largest container port in the UK, and some of the most productive arable land in the UK; playing a vital role in creating area-wide economic growth and tourism opportunities. However, this diverse and dynamic coast has the ever present threat of both coastal erosion and coastal flooding.

9.25 The Suffolk coast is known to be one of the fastest eroding areas in Europe and is vulnerable to major storm surges. These factors make it necessary to actively manage the coastal zone to ensure it is resilient50 in the face of coastal change, by incorporating the holistic principles of Integrated Coastal Zone Management into coastal policies. In this respect, the Council will work closely with coastal communities and other Risk Management Authorities such as the Environment Agency, the Marine Management Organisation, and Natural England. The Council also recognises the importance of partnership working and will continue to work with coastal and estuary partnerships going forward.

50 Resilience accepts, and as a result works with, rather than against, natural processes.

Coastal Change Management

9.26 Land affected by physical change to the shoreline through coastal erosion, coastal landslip or permanent inundation is defined in the National Planning Policy Framework as a Coastal Change Management Area. The boundaries are based on coastal erosion estimates and assumptions, with information taken from the current Shoreline Management Plans. The Shoreline Management Plans are integral to the formulation of planning policy and act as the primary evidence base for the policy in this area. Shoreline Management Plans reflect the long term intent of management towards coastal change in the form of epochs or time periods up to 2025, 2055 and 2105.

9.27 The current Shoreline Management Plan for the Suffolk coast was prepared between 2007 and 2010. However, it is recognised by all Risk Management Authorities that there is a need to regularly review and update key information within the Shoreline Management Plan on erosion and flood risk. The approach to defence management may change, which may change the delineation of the Coastal Change Management Areas. This policy affords a level of flexibility to allow for consideration of changes in the evidence base over the plan period. To help inform responses to coastal management proposals on the Areas of Outstanding Natural Beauty, specialist advice is available and should be consulted.

9.28 Infrastructure such as access roads and pipelines needs to be fully considered when delineating Coastal Change Management Areas. This can lead to properties that are not within a Coastal Change Management Area becoming inaccessible when an access road, for example, is lost to coastal erosion. It is the aim of the Council, going forward, to fully consider the existing infrastructure and topography of an area when delineating a Coastal Change Management Area and evaluating sites for rollback.

9.29 National planning guidance suggests that new permanent residential structures are not permitted in a Coastal Change Management Area. Therefore, the Council will continue to implement this policy.

9.30 Although Coastal Change Management Areas exist to highlight where rates of shoreline change are significant over the next 100 years and new residential development is generally avoided in these areas, there are some cases where development exceptions are permitted. Temporary or seasonal developments or extensions to properties are often considered as exceptions, subject to certain assessments. The Council will aim to facilitate appropriate development in the Coastal Change Management Area and to divert inappropriate development away from the Coastal Change Management Area. Policy SCLP9.3 details development considered appropriate in the Coastal Change Management Area.

9.31 Coastal Erosion Vulnerability Assessments are the primary means of assessing the coastal erosion impacts of proposed developments in and within a specified distance landward of the Coastal Change Management Area. The Coastal Erosion Vulnerability Assessment should consider the management proposals for the coastline and the likelihood of investments being made and the risk of erosion impacting upon the development in light of these factors. The assessment should be undertaken by the developer to demonstrate that the development will not be at risk from coastal change for the lifetime of the development or at risk as a result of the expected life of relevant coastal defence. In this regard, the assessment should comply with policy CC1 of the East Inshore and Offshore Marine Plans. The assessment will also need to demonstrate that the proposed development will not increase the risk of erosion (e.g. from surface water run-off). It is considered essential to liaise with the Council's Coastal Management team in carrying out this assessment.

9.32 There currently exists a 30 metre risk zone landward of areas identified as Coastal Change Management Areas in order to ensure that developments take account of the coastal erosion risk in the general vicinity. Added to this, the Council will implement a 30 metre risk zone landward of areas where the intent of management is to Hold the Line (HTL) and where, consequently, no Coastal Change Management Area has been identified. This is to ensure that access to coastal defences is not inhibited by new and/or replacement development. However, this measure should not be used in such a manner that precludes development from coming forward.

9.33 Where known geological information demonstrates that soft cliffs51 located behind coastal defences are likely to adversely affect the capacity of said defences, a Coastal Erosion Vulnerability Assessment should be considered. As a starting point, development up to 60 metres landward of coastal defences should consult the Council's Coastal Management team as to whether or not a Coastal Erosion Vulnerability Assessment is required. This will allow for greater consideration of both coastal erosion and the threat of soil degradation when considering proposed developments in defended areas.

9.34 The National Planning Policy Framework requires the delineation of the Coastal Change Management Area to be informed by, amongst many other things, Estuary Plans. It is the intention of the Council to expand the boundary and principles of Coastal Change Management Areas to the estuaries of the plan area in order to fully address coastal change along the Suffolk coastline which, by law, extends to the mean low water mark in the estuaries. This will involve consideration of both the Deben and Alde & Ore Estuary Plans and will be undertaken as part of any review to the Shoreline Management Plan which ultimately identifies the Coastal Change Management Areas.

9.35 Coastal Squeeze is the term used to describe habitats on the coast that are 'squeezed' between man-made barriers, such as river walls, sea walls and farmland, and an eroding coast. In a natural system, areas of saltmarsh or shingle 'move' inland as sea levels rise, and the animals and plants that depend on them migrate with the habitat.

9.36 Realignment is one answer to the problems caused by coastal squeeze because it gives the coast room to evolve. This can be done in both a managed and unmanaged way. An example of this being the construction of walls inland of historic defences to protect land and property behind them, while in front, natural processes take over and saltmarsh, for example, is allowed to develop. Innovative approaches such as this that are in keeping with the natural processes of the coastline will be supported, where appropriate, by the Council.

Policy SCLP9.3: Coastal Change Management Area

The Coastal Change Management Area is identified on the Policies Map. Reputable and scientifically robust evidence that emerges over the lifetime of this plan which effects the delineation of the Coastal Change Management Area should be considered when applying this policy.

Planning applications for all development within and 30 metres landward of the Coastal Change Management Area and within and 30 metres landward of areas where the intent of management is to Hold the Line, identified on the Policies Map must be accompanied by a Coastal Erosion Vulnerability Assessment.

In areas of soft cliff located up to 60 metres landward of coastal defences where known geological information indicates that the capacity of coastal defences are likely to be adversely affected by development, a Coastal Erosion Vulnerability Assessment should be considered.

In parts of the Coastal Change Management Area expected to be at risk from change within a 20 year time horizon, only temporary development directly related to the coast, for example beach huts, cafes, car parks and sites used for touring caravan and camping will be permitted.

In parts of the Coastal Change Management Area expected to be at risk from change beyond a 20 year time horizon, other commercial and community uses will be permitted providing they require a coastal location and provide economic and social benefits to the local community.

Proposals for new or replacement coastal defence schemes will only be permitted where it can be demonstrated that the works reflect the management approach for the frontage presented in the relevant Shoreline Management Plan and/or endorsed Coastal Strategy, and there will be no material adverse impact on the environment, including exacerbation of coastal squeeze.

Proposals for new or replacement estuary defence schemes will only be permitted where it can be demonstrated that the works reflect the management approach for the frontage presented in the endorsed estuary plans/strategies, and there will be no material adverse impact on the environment, including exacerbation of coastal squeeze.

Essential infrastructure, including transport infrastructure, utility infrastructure and wind turbines will only be permitted in the Coastal Change Management Area where no other sites outside of the Area are feasible and there is a management plan in place to manage the impact of coastal change including their future removal and replacement.

Planning permission for all development within the Coastal Change Management Area will be time-limited according to the risk identified in the Coastal Erosion Vulnerability Assessment.

51 Soft cliffs are formed in less resistant rocks such as shales or in unconsolidated materials such as boulder clay; being unstable they often form less steep slopes and are therefore more easily colonised by vegetation. Soft cliffs are subject to frequent slumping and landslips, particularly where water percolates into the rock and reduces its effective shear strength (JNCC, UK Biodiversity Action Plan Priority Habitat Descriptions, 2016).

Adapting to a Changing Coast

9.37 The Council recognises that the coast will change and there are both properties and infrastructure at risk. Coastal adaptation is generally considered as a response to coastal change, and can be defined as 'making changes to prepare for and negate the effects of climate change, thereby reducing the vulnerability of communities and ecosystems. By adapting to cope with the effects of climate change, communities, enterprises and institutions can build up their climate change resilience' (Action on Climate Today).

9.38 This approach is being pursued in coastal locations worldwide, and it is through the initiative of both coastal stakeholders and communities that the Council aims to achieve effective coastal adaptation in Suffolk.

9.39 Facilitating coastal relocation52 or rollback53 has been one of the main approaches undertaken to implement coastal adaptation in the East Suffolk area in recent years. The Council will continue with the exception policy of facilitating rollback or relocation for sites under threat from coastal erosion which demonstrates that the Council is able and willing to adapt to coastal change. In doing so, the Council will aspire to long term thinking in affecting this approach in order to properly and effectively prepare for coastal adaptation, and to allow communities to thrive in their coastal locations.

52 An approach of allowing relocation to areas where development would normally be refused planning permission (NPPF).

53 Rollback of assets inland away from the risks posed by coastal change (Coastal Change Pathfinder).

What is Currently Anticipated to be at Risk?

9.40 Suffolk has some of the fastest eroding coastline in Europe. Over the next 20 to 100 years there is the potential for properties, agricultural land and conservation land in some of our more vulnerable areas to be considered 'at risk' or lost to increased coastal erosion.Taking a Proactive Approach

9.41 The Council aims to take a proactive approach in dealing with loss of land and/or property to coastal erosion by encouraging rollback or relocation before the land or property is lost.

9.42 The National Planning Policy Framework states that Local Plans should make provision for development and infrastructure that needs to be relocated away from Coastal Change Management Areas. The National Planning Practice Guidance advises that either formally allocating land in a Local Plan or allowing for relocation where planning permission would normally be refused are two ways in which this can be achieved. The Council considers it feasible, in this respect, to relocate and replace agricultural buildings that are required to meet the essential needs of an agricultural development.

9.43 In order to benefit from the exception rollback or relocation policy, properties must be at risk from erosion within a 20 year period. This enables property owners to take a pro-active approach to relocate to an alternative location well before erosion becomes an imminent threat. In order to maintain the sustainability of coastal settlements, relocation should take place close to the existing community, where possible. Relocation of residential properties should also be to land which is outside of the Coastal Change Management Area. Alternative land uses within Coastal Change Management Areas that contribute to the sustainability of coastal communities and also reduce the risk of the development being adversely impacted by coastal erosion are encouraged. Such uses will be evaluated on a case by case basis.

9.44 It is important to ensure decisions with long-lasting consequences do not create obstacles for future adaptation, known as avoiding 'lock-in'. As an example, siting new buildings and infrastructure in low flood risk areas where possible, will have a long term benefit. Therefore, it is important to consider both flood risk and coastal adaptation policies concurrently when evaluating development on the coast.

Policy SCLP9.4: Coastal Change Rollback or Relocation

Proposals for the relocation and replacement of community facilities, commercial, agricultural and business uses affected by coastal erosion will be permitted in the countryside, provided that:

a. The proposed development replaces that which is within the Coastal Change Management Area as identified on the Policies Map and is forecast to be affected by erosion within 20 years of the date of the proposal;

b. The new development is located at an appropriate distance inland with regard to Policy SCLP9.3 on the Coastal Change Management Area;

c. The new development is in a location that is accessible to the coastal community from which it was displaced; and

d. The existing site is either cleared and made safe or put to a temporary use beneficial to the local community.

Proposals for the relocation and replacement of dwellings affected by coastal erosion will be permitted in the Countryside where:

e. The development replaces a permanent building which is within the Coastal Change Management Area as identified on the Policies Map and is forecasted to be affected by erosion within 20 years of the date of the proposal;

f. The relocated dwelling should be in a location which exhibits a similar or improved level of sustainability with respect to access to services and facilities as the original dwelling;

g. The relocated dwelling is outside of the Coastal Change Management Area as identified on the Policies Map; and

h. The existing site is either cleared and made safe or put to a temporary use beneficial to the local community.

Flood Risk & Holistic Water Management

9.45 The Council, in its capacity as a Flood Risk Management Authority, ensures that flood risk related to development is effectively managed through the planning system, and have the power to carry out flood risk management works on ordinary watercourses and works on coastal defences. Other Flood Risk Management Authorities include Suffolk County Council, the Environment Agency, Internal Drainage Boards and Water and Sewerage Companies. The responsibilities of each Flood Risk Management Authority can be seen here: https://www.gov.uk/guidance/flood-risk-management-information-for-flood-risk-management-authorities-asset-owners-and-local-authorities#managing-flood-risks-who-is-responsible

9.46 The low-lying nature of the coastline means that Suffolk is no stranger to flooding - flood events over the last few generations have resulted in infrastructural damage and, in some cases, loss of life. Flash flooding, estuarine and coastal flooding, partly induced by climate change, have been the main cause of this. The Council will work with flood risk stakeholders to lessen the impacts of flooding going forward by recognising and assessing the flood risk, mitigating against it and providing resilience measures to alleviate it. Working together with communities and stakeholders, the Council will look to help combat flood risk, particularly in coastal areas where national funding for flood protection is limited.

9.47 Government guidance advocates various flood risk assessments and approaches to guide new development to areas with the lowest probability of flooding. Notwithstanding this, it is appreciated that development in areas at some risk of flooding is sometimes unavoidable, as many of the towns in the Local Plan area such as Aldeburgh, Woodbridge and Felixstowe are located in high risk areas. To address this, mitigation will be required to ensure no net increase in the risk of flooding.

Addressing Flood Risk across the District

9.48 The National Planning Policy Framework requires Local Planning Authorities to prepare a Strategic Flood Risk Assessment to inform the Local Plan. A Strategic Flood Risk Assessment has recently been completed for East Suffolk and has identified areas at risk from flooding both now and in the future after taking climate change into account. This includes flooding models prepared by the Environment Agency as well as modelling from other Risk Management Authorities, which helps to attain the most up to date understanding of risk.

9.49 The Strategic Flood Risk Assessment should be used in assessing the flood risk of new development proposals. All sources of flooding should be considered including surface water flooding and flooding from sewers.

9.50 National planning policy seeks to mitigate the risk of flooding by restricting vulnerable new development within areas at risk from flooding. It does this by requiring development proposals in areas at risk from flooding to be subject to a sequential test where it has to be proven there are no suitable areas of land with a lesser risk of flooding and an exception test which identifies sustainability benefits of development and ensures the development is safe for its lifetime.

9.51 A site-specific flood risk assessment should be provided for all development in Flood Zones 2 and 3. In Flood Zone 1, an assessment should accompany all proposals involving:

  • Sites of 1 hectare or more;
  • Land which has been identified by the Environment Agency as having critical drainage problems;
  • Land identified in a Strategic Flood Risk Assessment as being at increased flood risk in future;
  • Land that may be subject to other sources of flooding, where its development would introduce a more vulnerable use.

9.52 Reflecting the conclusions of the Habitats Regulations Assessment, project level flood risk assessment should also consider any potential risks of flooding to designated European sites.

9.53 If development is to be constructed with less vulnerable uses on the ground level, covenants need to be put in place to prevent future alteration of these areas to 'more vulnerable' uses without further consideration of the associated flood risk.

9.54 The Shoreline Management Plan proposes various management approaches such as 'managed realignment' and adaptation measures. This method of actively managing the shoreline allows for, or creates, conditions for the coast to move. An example of this would be to relocate a linear flood defence back from the active coastal zone to a more secure long term position and, therefore, allow the shoreline to re-adjust naturally. It can bring benefits including the creation or recreation of valuable and threatened inter-tidal habitats as well as more robust flood defence for the community, but may result in the loss of some agricultural land and, in a number of limited cases, property. If it is not carefully managed it could have a major impact on the economic and social infrastructure, as well as the everyday operation of communities.

9.55 The Local Plan will need to take account of any review of the Shoreline Management Plan. It may be necessary to ensure that development to be permitted in areas at risk from coastal erosion or flooding by the sea is proportionate to the level of risk.

9.56 Developments should be designed to incorporate natural flood management measures that sustainably utilise natural capital, in line with the Natural Capital Committee's advice. By working with natural processes, we can better protect ourselves from hazards such as flooding. Natural flood management involves the use of a variety of measures including tree planting, river bank restoration, building small-scale woody dams, reconnecting rivers with their flood plains and storing water temporarily on open land. Of course, such measures should be complementary of traditional flood defences in the interests of integrated flood management. However, where flood risk measures result in significant depreciation of natural capital, the creation of compensatory natural capital will be required.

Policy SCLP9.5: Flood Risk

The Strategic Flood Risk Assessment should be the starting point in assessing whether a proposal is at risk from flooding.

Proposals for new development, or the intensification of existing development, will not be permitted in areas at high risk from flooding, i.e. Flood Zones 2 and 3, unless the applicant has satisfied the safety requirements in the Flood Risk National Planning Policy Guidance (and any successor). These include the 'sequential test'; where needed the 'exception test' and also a site specific flood risk assessment that addresses the characteristics of flooding and has tested an appropriate range of flood event scenarios (taking climate change into consideration). This should address as a minimum: finished floor levels; safe access and egress; an emergency flood plan; identification and provision of surface water exceedance routes; flood resilience/resistance measures; any increase in built or surfaced area; and any impact on flooding elsewhere, including sewer flooding.

Developments should exhibit the three main principles of flood risk, in that, they should be safe, resilient and should not increase flood risk elsewhere. In this respect, single storey residential developments will not be permitted in areas of high risk of flooding within or outside Settlement Boundaries.

Developments are encouraged to include natural flood management measures that complement existing flood defences if pre-existing flood defences are in place, in the interests of integrated flood management.

Any new flood risk measures that result in significant depreciation of natural capital will be required to create compensatory natural capital.

Neighbourhood Plans can allocate land for development, including residential development, in areas at risk of flooding providing it can be demonstrated:

  1. There are no alternative available sites appropriate for the proposed use within the Neighbourhood Area;
  2. The development provides sustainability benefits which outweigh flood risk; and
  3. Evidence is provided that it is possible for flood risk to be mitigated to ensure development is safe for its lifetime and the lifetime of the relevant flood defence.

Sustainable Drainage Systems

9.57 It is important to ensure that new development does not impede flood flows, reduce flood storage capacity, or exacerbate problems of flooding in areas downstream through an increase in run-off from impermeable surfaces such as roofs and paved areas. A common way of achieving this is through use of sustainable drainage systems (SuDS). Sustainable drainage systems can take up large areas of land on development sites and therefore significantly influence the layout through good design which responds to built, historic and natural surroundings.

9.58 Sustainable drainage systems should be integrated into the green infrastructure provision on the site and complement the overall landscaping scheme of the site. They should not be surrounded by palisade fencing and where restrictions to access are required due to safety considerations, these should be innovatively designed by low impact barriers such as landscaping or planting. Sustainable drainage systems should also incorporate 'Blue Corridors', where possible, to create a network of corridors designed to facilitate natural hydrological processes that help to minimise flooding.

9.59 Well designed drainage systems can deliver environmental improvements including water quality, biodiversity and reduced flood risk. Discharges of surface water should be designed to deliver water quality improvements to help meet the objectives of the Water Framework Directive relating to deterioration and improvement in water body status. Surface water should be discharged as high up the drainage hierarchy as possible in line with the concept of the SuDS management train. Presently, there is a tendency for required attenuation volumes to be accommodated below ground. In order to discourage this, preference should be given to the installation of blue-green surface infrastructure, as opposed to hardscape or underground solutions, due to the wider benefits attained through ecosystem services provided by natural capital. This includes habitat provision, recreational benefits and mitigation against the urban heat island effect, where relevant.

9.60 The latest advice from the Lead Local Flood Authority at Suffolk County Council, the CIRIA SuDS Manual and the latest Suffolk Flood Risk Management Strategy should be consulted when considering SuDS planning, design and maintenance.

Policy SCLP9.6: Sustainable Drainage Systems

Developments should use sustainable drainage systems to drain surface water. Developments of 10 dwellings or more, or non-residential development with upwards of 1,000 sqm of floorspace or on sites of 1 hectare or more, will be required to utilise sustainable drainage systems, unless demonstrated to be inappropriate. Sustainable drainage systems should:

  1. Be integrated into the landscaping scheme and green infrastructure provision of the development;
  2. Contribute to the design quality of the scheme; and
  3. Deliver sufficient and appropriate water quality and aquatic biodiversity improvements, wherever possible. This should be complementary of any local designations such as Source Protection Zones.

Runoff rates from new development must be restricted to greenfield runoff rates wherever possible. Where a site is previously developed, the proposed runoff rates should be restricted as close to the greenfield rates, or at the very minimum a betterment of at least 30% should be considered over the brownfield runoff rates.

No surface water connections should be made to the foul system and connections to the combined or surface water system should only be made in exceptional circumstances where there are no feasible alternatives. Foul and surface water flows should also be separated.

Holistic Water Management

9.61 In recognition that water does not respect administrative boundaries, the Council will work with neighbouring authorities and other relevant stakeholders to devise a catchment-based approach to holistic water management. In respect of implementing holistic water management, and applying the conclusions of the Habitat Regulations Assessment that underpins the Local Plan, to assure the timely delivery of required infrastructure and treatment capabilities, new developments will be required to be phased to allow water and wastewater infrastructure to be in place when needed. There will however not always be a requirement for development to be phased, for example, where there are no identified water and/or wastewater improvement works required to serve the development, or where measures are or will be in place in a timely manner. The Council will work with the water companies, Natural England and the Environment Agency to ensure that water related matters and required infrastructure needs are continually reviewed and resolved to meet the needs arising from growth, as set out in the Monitoring Framework (Appendix C) of this Plan.

9.62 The Deben Holistic Water Management Pilot Project provides a best practice example of holistic water management, in that, it involves the re-use of water that would normally be pumped into the river system which adds to flow velocity and ultimately the rate of erosion. Through holistic water management methods such as attenuation ponds and managed aquifer recharge, the pilot project will filter excess water from flooding into the groundwater tables which will help to improve river flows and water quality. The Council supports this approach to holistic water management and will aim to complement such an approach, where possible.

Policy SCLP9.7: Holistic Water Management

All development will be expected to demonstrate that water can be made available to support the development and that adequate foul water treatment and disposal already exists or can be provided in time to serve the development. Development will be phased to allow water and water recycling infrastructure to be in place where needed.

All new developments will be expected to incorporate water efficiency and re-use measures to maximise the opportunities to reduce water use. This includes, but is not limited to:

  1. Grey water recycling;
  2. Rainwater harvesting; or
  3. Water use minimisation technologies.

Infrastructure that leads to a reduction in the amount of water released to the sewer system and allows for natural infiltration into groundwater tables will be favoured in this instance.