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

Do not support the statement that previously developed land within Flood Zone 3 should be considered ahead of greenfield land that has a lower flood risk. 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 first paragraph of policy to:

'We seek to direct development away from areas at risk of flooding by applying the sequential test and, where appropriate, the exceptions test, as per PPS25. It is envisaged that the majority of development can be accommodated in areas at least risk of flooding (Zone 1).'