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Draft TAN15: A move towards risk-based assessment?

Draft TAN15: A move towards risk-based assessment?

Helen Ashby-Ridgway 25 Oct 2019
The Welsh Government’s (WG) delayed draft Technical Advice Note 15: Development, flooding and coastal erosion and Consultation Document have now been published. It follows consultation on the draft National Strategy for Flood and Coastal Erosion Risk Management earlier this summer.
The impacts of flooding can be catastrophic to individuals, communities, businesses, the economy and to the natural and built environment. The effects of climate change cannot be denied and the evidence suggests that future fluvial and coastal flood events are likely to be more frequent and will present greater risks to us and to the environment.
Our understanding of these changes and the risks has evolved since TAN15 was originally published 15 years ago. There has been no change as to how flooding is considered in policy since it was first published. Whilst in the last 18 months clarification has been made on the application of the justification test for highly vulnerable uses, flood classifications and assessment has remained untouched. 
The publication of draft TAN15 follows a report (December 2018), prepared by JBA for the WG, on the performance of the existing TAN. JBA’s view was that when originally published the TAN was ‘ground-breaking’ in introducing flood zones and taking a precautionary approach. However, JBA concluded that due to technical advancements in understanding flood risk and management TAN15 ought to be reviewed. In particular, JBA recommended that TAN15 should: move from the precautionary approach to a risk-based assessment, to capture the sources of all flood risk including surface water flooding, to review the 4 tier Development Advice Maps that we use today and to provide an increased focus on assessing flood risk during development plan preparation and the making of site allocations. It also considered that the strong presumption against highly vulnerable developments in areas of greatest flood risk should remain.
In our June Planning News, we reported anecdotal comments which suggested that the emerging changes would take a more restrictive approach to developments within DAM Zone C2. Having now seen the draft TAN, it is clear that it’s not only Zone C2 where WG wants to take a more restrictive approach.
Here is a summary of some of the proposed changes:

1.   A Wales Flood Map (WFM) will replace Development Advice Maps (DAMs). There will be three flood zones:

  • 1 – Very low risk (less than 1 in 1000 year),
  • 2 – Low risk (less than 1 in 100 but greater than 1 in 1000 year),
  • 3 – Medium and high risk (greater than 1 in 100 year).

The draft states that the WFMs will be the starting point for consideration of risk.

2.  There will remain three categories of vulnerability of uses: highly vulnerable, less vulnerable and water compatible. Highly vulnerable uses will continue to include houses, caravans, schools, hospitals and vulnerable industrial e.g. power plants etc. The former emergency services category will become part of the highly vulnerable group and other than police stations etc they will also include buildings used as emergency shelters in times of flood (e.g. some leisure centres). The list of example uses for each category are greater and it’s made clear that any uses not listed are to be determined by professional judgment.

3.  Where a mix of uses are accommodated in a single building the vulnerability will be defined by the most vulnerable use. For larger developments with multiple buildings a single vulnerability category may not be appropriate and there will be some flexibility in how the vulnerability classifications can be applied e.g. in relation to proposed developments for housing and open space.

4.  In terms of the how the flood risks will be applied:

  • In Zone 1 all vulnerabilities of use will be acceptable in principle provided that there is no increase in flooding elsewhere and flood resistant and resilient design in locally defined areas of future or current flood risk are included.

  • In Zone 2 all vulnerabilities of use may be acceptable in principle but the proposal must pass a justification test and a series of consequences criteria will need to be met (e.g. evacuation, no increased risk of flooding elsewhere etc).

  • In Zone 3 no highly vulnerable development will be considered acceptable. The draft is explicit that FCAs should not be prepared for such uses and there will be no requirement for NRW to respond. Less vulnerable and water compatible uses may be acceptable subject to a separate justification test and a series of criteria on the acceptability of the consequences.

5.  Looking at those justification tests in more detail:

  • For Zone 2, the site will need to be in an area benefitting from flood defences OR must be part of a local authority initiative to sustain an existing settlement and is identified in an adopted Development Plan which has been prepared using a Strategic Flood Consequences Assessment (SFCA). Critically, to be acceptable in Zone 2, the development will also need to meet the definition of previously developed land.  So, essentially, any development in flood zone 2 must be on brownfield land.

  • The justification test for Zone 3 (for less vulnerable development, essential transport and utilities infrastructure) requires that the scheme be allocated or be part of an allocation or be identified in an adopted Development Plan i.e. Development in Zone 3 is essentially plan-led and the draft states that such development is a ‘last resort’.

6.  The draft recognises that due to industrial legacy there are places in need of major regeneration in areas at risk of flooding. Decisions to enable large scale regeneration of population areas at risk of flooding should be taken through the NDF and SDP.

7.  SFCAs should be undertaken as part of the plan-making process although these may be cross boundary assessments to better understand risks across river catchments. Development Plans must also be based on a sound understanding of the Emergency Services’ ability to respond.

8.  TAN14 (Coastal planning) will be cancelled and coastal erosion will be dealt with in TAN15. The draft states that development should be avoided where there is a risk of it being impacted by coastal erosion over the lifetime of the development. Zones of development and no development should be identified in the LDP although acceptable uses can also be identified in the LDP.


It seems that there are a few critical points arising from the consultation:

1.  It’s not yet clear on the extent of zone designations for a particular site or area compared with current mapping. The DAMs were not solely connected to NRW’s own flood risk mapping and the new maps will include a central climate change allowance. Proposals will need to demonstrate the acceptability of the proposal using a range of scenarios including upper limits. Until we have the maps it’s almost impossible to predict what the changes will mean for individual projects.

2.  WG is pushing the planning system further towards a previously developed land and plan-led approach to development. Whilst national planning policy already focuses on these it has hitherto not entirely removed the realistic potential for development to come forward by other means e.g windfall development. The emerging TAN could be seen as putting up hurdles to certain development (such as housing and tourist accommodation). The preparation of local development plans is not a quick process and there have been more than a few instances where plans have stalled, gone back to the drawing board, been withdrawn and/or have taken years to adopt. There have also been concerns regarding the lack of delivery against strategic growth requirements in plans that have been adopted.

3.  Historically towns have grown around coastal and river locations – some of these are in significant need of regeneration. The draft TAN proposes mechanisms to facilitate windfall development in less and highly vulnerable development in such towns falling under Zone 2 and it creates a framework for development in such areas falling under Zone 3.

4.  There is no mention of how the WFM might be challenged if the data used to inform the zoning is found to be inaccurate.

5.  Draft TAN15 and the National Strategy had originally been due for consultation together. For reasons unknown the TAN was published late – but not late enough for the consultation responses to the National Strategy to have been digested by WG and to inform the draft TAN.

There are no easy decisions to make when it comes to flood risk and it’s even more difficult when different sides of sustainability are in tension with one another. It is important, indeed, in some instances, it is vital, that there are measures to protect areas at risk of flooding. However, until the WFMs are published it is unclear what impact the approach proposed in the consultation documents will have on achieving sustainable development (under all measures) if the TAN is adopted as drafted.  
The consultation of draft TAN15 closed on 17 January 2020.


Planning for better mental health

Planning for better mental health

Justine Matchett 23 Oct 2019
I have recently completed an RTPI training module looking at the role town planning can play in promoting good mental health in the United Kingdom (UK) and thought that there were some simple, useful messages worth sharing, which could make us all better at our jobs, irrespective of the area of planning within which we work.
There is known to be a close interrelationship between physical health and mental health. Poor physical health can exacerbate mental health issues and there is clear evidence of the benefits of physical exercise on mental health. The same correlation of the impact of the spatial environment on physical and mental health applies. Mental health in the UK is known to be poor, with reporting that one in four people are believed to be affected by a mental health problem in any year. Mental health conditions including anxiety, depression, bipolar, schizophrenia and stress can be more common, long lasting and impactful than many physical conditions. There are also large numbers of people affected by progressive neurological disorders such as dementia as well as autism spectrum conditions. Poor mental health has significant economic costs and it is estimated that mental ill health is responsible for the loss of 72 million working days at a cost of £35 billion each year in the UK. This strengthens the need for planners to take a more preventative role in addressing mental health.
Where you live can have a direct impact on your mental health. The charity MIND surveyed 2,000 people in 2017 and found that four in five people with mental health problems have lived in housing that has made their mental health worse. Of these 70% reported experiencing an issue with the quality of their housing such as damp, mould, treat of eviction, overcrowding or unstable tenancies. The links between poor quality housing and mental health cannot be ignored and the RTPI and others have reported that the increase in permitted development rights is making the situation worse.
Particularly worrying is that half of all mental health issues (excluding dementia) are established by the age of fourteen. According to the Mental Health Taskforce, the quality of housing is important but equally so is the opportunity for play. This is also recognised by the World Health Organisation (WHO). The RTPI is currently working alongside the Real Play Foundation to develop a tool to identify the ‘play gap’ in cities where there is inadequate access to appropriate play spaces for children. One developed this will be used to help assess and understand the complexity of play in cities, identifying interventions and measuring outcomes. Publication is expected sometime in 2020.
It is also important to consider the mental health of teenagers as a specific group. Providing safe schools and communal spaces where they cab interact safely is something we should be planning for. This approach should continue into higher education provision as mental health problems are estimated to affect one in four university students, with suicides having reached a record high and the number of dropouts significantly increasing. Research has been undertaken by Burohappold exploring how the built environment can affect the mental health of students. This found that connectivity is key, connection within and between buildings, across campuses and within University City Masterplans. The key outcome of this work was the recognition of the need to use the built environment to promote social interaction and mindful activity and for movement and transport to be a pleasant experience. This research noted the importance of designing to create ‘sticky points’ which encourage social interaction between students. It supported the ‘mind the gap’ principles developed by the Institute for Mental Health, based around creating places which are safe, green, active and prosocial where people can bump into each other for informal interaction.
There is also currently much debate about how to build housing appropriate for our aging population. Older people are generally more vulnerable to loneliness and social isolation, particularly resulting from living along, and this can have a major impact on their mental health. According to Age UK more than one million people go a month without speaking to a neighbour, friend or family member. The Alzheimer’s Society currently estimates there are 850,000 people with dementia in the UK. This is predicted to rise to one million in 2021 and to two million by 2051. Staying active, both physically and mentally, is vital for people with dementia and helps them stay well for longer. There is therefore an increasing need for planners to work to create places that are familiar, legible, distinctive, accessible, comfortable and safe. The local environment is a fundamental factor contributing to the quality of life of older people, it can either be enabling or disabling. Having access to amenities like local shops, doctors, post offices and banks within easy, safe and comfortable walking distances contributes to people with dementia being able to live independent and fulfilling lives for longer. Access to greenspace and nature is known to have particular benefits for people with dementia and in June 2019 the NPPG changed to include a strengthening of advice on planning with people with dementia. It also provides helpful guidance on the characteristics of a dementia friendly community.
Good, carefully considered design is even more important inside the home, whether this is a family home, extra care housing, residential care or nursing care. Often small changes can be enough to help someone living with dementia to be more independent by providing an environment that is clearly defined, easy to navigate, and feels safe. Whilst the internal layout of buildings is usually beyond the scope of the role of planners, it is still worth being aware of the key principles of good design, which include:
  • Safe environment – avoid trip hazards, provide handrails and good lighting;
  • Visual clues – clear signage, sightlines and routes around the building; Clearly defined rooms – so the activities that take place there can be easily understood;
  • Interior design – avoid reflective surfaces and confusing patterns. Use age and culturally appropriate designs;
  • Noise – reduce noise through location of activities and soundproofing. Provide quiet areas as people with dementia can be hyper-sensitive to noise;
  • Natural light or stronger artificial light – many people with dementia have visual impairment or problems interpreting what they see;
  • Outside space – access to safe outside space, with good views from inside the building as daily exposure to daylight improves health.
These features of good design reflect the Housing our Ageing Population Panel for Innovation (HAPPI) principles, which are based on ten key design criteria. Many are recognisable from good design generally, but they have particular relevance to older persons' housing which needs to be able to adapt over time to meet changing needs.
Also of relevance to the consideration of the impact of planning on mental health is an understanding of autism. Autism is a spectrum disorder which affects how people see the world and interact with others. All autistic people share similar characteristics but being autistic will affect them in different ways. Whilst there are around 700,000 autistic people in the UK there is still a lack of awareness about how the physical environment can affect people with autism. Things to think about in planning new urban spaces include acoustics in terms of minimising background noise and spatial sequencing, providing a logical order of spaces to help people with their routine. The provision of ‘escape’ places where they can experience respite from the over stimulation of the built environment is also important. This is handled particularly well by Disney where their theme parks include quiet spaces where people can relax when they become over stimulated or want some down time. Also important is compartmentalisation to define the use of spaces so the user knows what to expect when they enter. Sensory zones and safety are also particularly important for people with an altered state of their own environment.
There is much evidence of the therapeutic benefits of spending time in the natural environment, with MIND reporting that spending time in a green space or bringing nature into everyday life can benefit both your mental and physical wellbeing. In this context it is important to create natural settings in people’s neighbourhoods and in their daily routines. Something as simple as reducing the frequency of cutting grass verges can lead to wildflower displays which can be beautiful and uplifting.
Whilst national policy stresses the importance of physical health interventions it says very little about mental health. However national and local planning policy does talk a great deal about ‘wellbeing’ without really defining what wellbeing is. According the WHO there is no universally accepted definition of wellbeing as this depends upon culture and situation. However the organisation ‘What Works Wellbeing’ describes it as “about people and creating the conditions for us all to thrive. Its quality of life and prosperity, positive physical and mental health, sustainable thriving communities.”
What is clear is that planning interventions to create good mental health cannot be taken in isolation. It requires a joined up approach, with integrated and effective partnerships developed with care and service providers including social care, housing providers, health and wellbeing boards, NHS Trusts, public health authorities and charities. We can play our role in developing and maintaining these partnerships.
Overall, planning for mental health meets a number of existing objectives, such as revitalising high streets, preserving biodiversity, promoting arts and culture and tackling air quality and obesity. What is needed is a little more thought about how we integrate these things together. For example adding more greenspace into a development not only improves the mental health of people using the space but it can tackle air quality, enhance biodiversity and can improve the vitality and aesthetics of our environment.
With the quality of our environment inherently linked to our state of mental health, the RTPI is currently carrying out research to explore policies and practices that enable healthy placemaking with a particular emphasis on accommodating and tackling mental health issues. It is anticipated that this will lead to the publication of practice guidance for RTPI members an a centralised store of evidence of best practice that planners can use and interpret in their own work. In the meantime, the main message from this training is that essentially much of planning for good mental health is about good town planning, and that is something that all of us at Lichfields can contribute to.