Support the application of the sequential test, which seeks to direct development to areas at least risk of flooding. The application of PPS25 exceptions test will only be applied when the sequential test has shown that there are no available locations for necessary development other than within areas of at risk of flooding.

However, do not support the statement that the majority of development necessary within the District can be accommodated within Flood Zone 1 (areas least at risk of flooding), although there may be exceptions involving previously developed land.

PPS25 does not caveat that the exceptions test can be overridden by previously developed land; flood risk needs to be considered along with other planning issues. Taking into consideration the aim to manage risk, the use of a previous developed site in an area subject to flood risk would put property and people at greater risk; particularly, when it would replace a less vulnerable use (employment), with a more vulnerable use (residential).

Amend text of third sentence of fourth paragraph of 'Appraising Risk':

'... As such, it is envisaged that the majority of new development necessary within the District can be accommodated within Flood Zone 1 (areas of least risk of flooding).'