Sequential Test for East Suffolk Planning Applications

Where flood risk applies in East Suffolk

The council's 2018 Level 2 Strategic Flood Risk Assessment describes the risk in Lowestoft, the district's largest town:

• Tidal surgesLowestoft lies on the estuary of the River Waveney, known locally as Lake Lothing. The main flood risk is tidal, from surges that build in the North Sea along the east coast, which flooded the town with devastating effect in 1953 and again in December 2013.
• DefencesThe 2018 SFRA found Lowestoft had very limited tidal flood defences, with no formal defences on the Environment Agency's asset records, and described the temporary barriers installed in 2016 and the Lowestoft Flood Risk Management Project then being developed.
• Surface waterLowestoft is also vulnerable to surface water flooding, particularly around Kirkley Stream, Aldwick Way and Velda Close, as the significant flooding of July 2015 showed. Many local drains discharge into the tidal river, so high tides can make surface water flooding worse.
• The rest of the districtTidal and river flood risk also affects the other estuary towns and the river valleys inland. The Environment Agency's flood zones, which our reports use, cover the whole district.

What East Suffolk Council will look for

East Suffolk Council applies the national tests in NPPF Chapter 18 and the Planning Practice Guidance, supported by its Strategic Flood Risk Assessment. A Sequential Test submitted with a East Suffolk application should normally:

• Confirm the flood zone and vulnerabilityUse the current Environment Agency Flood Map for Planning and the NPPF Annex F vulnerability class for the proposed use.
• Justify the area of searchNational policy says the area of search should reflect the catchment for the type of development and the need it serves. East Suffolk is a large district, from Lowestoft and Beccles in the north to Woodbridge and Felixstowe in the south, so for smaller schemes a narrower area matching the town or former district served is often more defensible than the whole planning area.
• Assess the council's own sources of sitesthe Suffolk Coastal (2020) and Waveney (2019) Local Plan allocations and neighbourhood plan allocations, each with the council's housing land supply phasing and annual progress record, and the Brownfield Land Register are the obvious places to start, and omitting them is a common reason for challenge.
• Evidence every discounted siteWhere an alternative is ruled out as unsuitable, too small or not available in a similar timeframe, give the reason and the evidence. Ownership alone is not enough.
• Screen for the Exception TestState whether the Exception Test applies under Annex F Table 3, and if it does, provide it, drawing on the site-specific flood risk assessment.

East Suffolk-specific pitfalls

• Reliance on defencesCoastal towns in East Suffolk depend on defences, but the Sequential Test uses flood zones as if the defences were not there. The defences matter for the site-specific flood risk assessment, not for choosing between sites.
• The Broads boundaryLand in the Broads, in parts of the Waveney valley and around Oulton Broad, is planned by the Broads Authority. Our East Suffolk reports search the district outside the Broads; tell us if your scheme's catchment crosses the boundary.
• Allocations already being builtOur reports use each allocation's latest progress record and leave out sites the council records as under construction or complete, as they are not available for another scheme.
• Sites outside the allocationsEast Suffolk has no up-to-date land availability assessment published as data, so sites outside the Local Plan and neighbourhood plan allocations are included only where they are on the brownfield register.

Fixed-fee Sequential Tests for East Suffolk

We have built our East Suffolk Sequential Test on published Environment Agency and East Suffolk Council data. Plot your site on our East Suffolk Sequential Test page and we'll deliver a submission-ready report within 24 hours of payment for £300. Exception Tests are £450 within 48 hours.

New to the subject? Start with our general guide: what is a flood risk Sequential Test? We also cover other council areas at the same fixed fee. For wider planning help, see planning consultants in East Suffolk.

Source: Suffolk Coastal and Waveney District Councils Level 2 Strategic Flood Risk Assessment (AECOM, 2018).

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