flood risk sequential test - windfall sites - Public forum - Planning Advisory Service (PAS)
flood risk sequential test - windfall sites
Should a windfall site fail the sequential test because of a sequentially preferable allocated site?
Is there an arguement for discounting allocated sites from those considered reasonably available?
The PPG seems to refer to site allocations and SHLAA when identifying alternative sites but our local plan housing targets considers windfall in addition to allocations. I understand 5 year supply isn't a consideration for the sequential test but our Local Plan was adopted with a significant housing shortfall.
In my view, yes a windfall site would fail the flood risk sequential test if there is a sequentially preferable, allocated site available for the same use. That is correct because we have a plan led system and the purpose is to avoid inappropriate development in high flood risk areas. If there is a need for windfall within a specific part of the district you could draw the boundary for the area of search to reflect that eg around a village or other settlement, so that makes it easier for the sequential test to be passed.