1.0 With climate change and increases in the frequency and severity of extreme weather events there should be no development allowed in river flood plains. Water compatible development type zoning such as Open Space should be used for lands in river flood plains at risk of flooding. Section CPO 14.10 in the County Development Plan states the following: "To prohibit development in river flood plains or other areas known to provide natural attenuation for floodwaters except where the development can clearly be justified with the Flood Risk Management Guidelines ‘Justification Test’."
This section needs to be amended to the following to exclude the exception as this would result in bad planning and unsustainable development: “To prohibit development in river flood plains or other areas known to provide natural attenuation for floodwaters. Water compatible development type zoning such as Open Space should always be used for lands in river flood plains at risk of flooding”.
2.0 With climate change and increases in the frequency and severity of extreme weather events there should be no development allowed in flood risk areas. Section CPO 19.10 states the following:
“To prohibit the development of habitable structures below 3m (OD Malin), in the interest of public safety and the protection of property and residential amenity.”
The latest Intergovernmental Panel on Climate Change (IPCC) Report states that "Coastal areas will see continued sea level rise throughout the 21st century, contributing to more frequent and severe coastal flooding in low-lying areas and coastal erosion. Extreme sea level events that previously occurred once in 100 years could happen every year by the end of this century."
The 3m (OD Malin) is an outdated and insufficent level and needs to be amended under the Precautionary Principle change to the following:
“To prohibit the development of habitable structures below 6m (OD Malin), in the interest of public safety and the protection of property and residential amenity. This level includes a climate change and land movement allowance and is above the 1-in-200 year return period coastal flood event level.”
3.0 With climate change and increases in the frequency and severity of extreme weather events there should be no development allowed on soft shorelines. Section CPO 19.11 states the following:
“To protect both public and private investment by prohibiting any new building or development (including caravans and temporary dwellings) within 100m of ‘soft shorelines’ i.e. shorelines that are prone to erosion, unless it can be objectively established based on the best scientific information at the time of the application, that the likelihood of erosion at a specific location is minimal taking into account, inter alia, any impacts.”
The level of 100m of soft shorelines is insufficient and needs to be increased under the Precautionary Principle. Also the exception as drafted is incomprehensible and should be ommitted. The following is the suggested redrafted policy:
“To protect both public and private investment by prohibiting any new building or development (including caravans and temporary dwellings) within 600m of ‘soft shorelines’ i.e. shorelines that are prone to erosion, notwithstanding coastal defences built upon the shoreline.”
Coastal defences are not sustainable protection measures in the medium term due the impacts of climate change, in particular rising sea levels and increases in the frequency and severity of extreme weather events.