Comment

Representation ID: 88

Received: 04/06/2009

Respondent: Environment Agency

Para 36. Where the requirements of the sequential test have been met and it can be demonstrated that there are no other less vulnerable sites, then a detailed Flood Risk Assessment will be required. This paragraph should make it clear that the Sequential test applies to all development (Seafront or otherwise), separating out flood risk mitigation and adaption.
Flood Risk Mitigation: The mitigation section should start with the positive making space for water ideas you have listed: flood storage, conveyance, re-creating functional flood plain, setting back defences. Then you can move on to other mitigation measures such as improved drainage systems, flood barriers and bunds.
Flood Risk Adaption: The recommendations on Flood Risk Adaption should be separated out into separate bullet point. This could include your point on flood proofing, but the CLG publication 'Improving the flood performance of new buildings', http://planningportal.gov.uk/uploads/br/flood_performance.pdf addresses much wider principles that should be listed in your document.