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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. Commentary 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 is open until 17 January 2020.

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How can placemakers help to reduce loneliness?

How can placemakers help to reduce loneliness?

Helen Ashby-Ridgway 21 Jun 2019
Last week was Loneliness Awareness Week, a week established by the Marmalade Trust to raise awareness of loneliness and social isolation, to reduce the stigma of loneliness and to help people connect. This will be its third year and the movement is growing. This isn’t surprising when studies have shown that in the UK more than 9 million people always or often feel lonely[1]. The Costa Book Award winning novel Eleanor Oliphant is Completely Fine was written by its author Gail Honeyman after she had read an article on the subject of loneliness which reported on an interview with a young lady who said she would come home from work on a Friday and then wouldn’t speak to anyone again until Monday morning. Such a situation seems incredibly sad but worse yet, extensive research shows that loneliness poses a number of risks to physical and mental health, including: Increased risk of developing coronary heart disease and stroke (Valtorta et al, 2016), Increased risk of high blood pressure (Hawkley et al, 2010) Greater risk of cognitive decline (James et al, 2011) Higher risk of the onset of disability (Lund et al, 2010) More prone to depression (Cacioppo et al, 2006) (Green et al, 1992) Predictive of suicide in older age (O’Connell et al, 2004); and, One study concludes that lonely people have a 64% increased chance of developing clinical dementia (Holwerda et al, 2012). Some of the studies are more worrying. Not long ago a stark headline was being carried by a number of newspapers. A meta study (a study of studies) of some 3.4 million people by Professor of Psychology Julianne Holt-Lunstad and her research team[2] had concluded that weak social connection has the same risk of death as smoking 15 cigarettes a day. Moreover, according the findings it doesn’t matter whether the loneliness is perceived or actual the risk to health remains the same[3].The NHS ‘Behind the Headlines’ critique of this particular study concluded that the research ‘provided some evidence that the isolation was causing ill health, rather than the other way round, but we can't be certain[4]’. Whether or not this particular headline is as troubling as it appears the remaining evidence that suggests that loneliness and social isolation can have adverse impacts upon our health and well-being and upon the UK economy. Research reported by the Co-op suggests that loneliness costs UK employers £2.5 billion per year. Causes of loneliness The causes of loneliness are not surprising. They include but are not limited to: Changes in day-to-day routines (such as retirement), A lack of or loss of friends (such as through bereavement or divorce), Restricted mobility, cognitive and sensory impairment or other causes of poor physical health (which then create a vicious circle), Financial limitations (limiting ability to participate in activities), Personal characteristics (such as age, stage in life, ethnicity, sexual orientation); and, Neighbourhood characteristics (such as a lack of amenity, layout of streets, crime). Loneliness is not only restricted to those who are alone or are of a particular age group.  “Young or old, loneliness does not discriminate” said the late Jo Cox MP who, with her colleague Seema Kennedy MP, set up a cross-party Loneliness Commission in 2016. Source: ONS analysis of Community Life Survey August 2016 – March 2017 Creating spaces that reduce social isolation National and many local planning policies seek to ensure that developments create healthy and safe communities. Many of the recent call to action publications by a variety of respected organisations, charities and commissions focus on a wide range of measures to improve loneliness and to reduce social isolation. However, not as much has been written in these documents about how the built environment can contribute to tackling its causes. As place makers we can help to create places that encourage social connection and to create spaces that people want to use and are able to use that are safe and secure and that are accessible to all.  These are just a selection of ways that creating spaces and places can help to increase both formal and informal social interaction which may in turn help to reduce loneliness: Making dementia-friendly spaces that are designed to encourage people out of their homes, with connections and routes that are accessible and safe (The RTPI has published practice advice on this); Ensuring that amenities and facilities are in walking distance and the routes to these places are safe, legible and encourage more people to use them; Delivering a range of places for leisure activities and where people can meet - from community halls to bowling greens, and from public squares to public footpaths; Including facilities for physical activity such as formal parks and informal open spaces, playgrounds for children where parents can mingle, as well as allotments for all ages; Ensuring that the spaces to meet are safe, with excellent natural surveillance through active frontages and well-considered layouts; Creating jobs and educational opportunities with further enhancements by creating dedicated indoor and outdoor spaces for people to meet during lunch breaks (rather than eating a sandwich at a desk); and, Places for cultural activities through formal and informal spaces such as heritage assets, coastal paths and outdoor theatres. Understanding why places and spaces are important in helping to combat loneliness is a good starting point. Indeed, many of the measures are integral to high quality urban design decisions but can be easily missed although our experience, from working on health impact assessments for a number of projects, is that the measures can be simple and often not costly. Whilst we cannot solve the factors causing loneliness entirely, placemakers can be part of a range of measures that help.  [1] https://www.gov.uk/government/news/pm-commits-to-government-wide-drive-to-tackle-loneliness [2] https://www.aging.senate.gov/imo/media/doc/SCA_Holt_04_27_17.pdf [3] https://www.ahsw.org.uk/userfiles/Research/Perspectives%20on%20Psychological%20Science-2015-Holt-Lunstad-227-37.pdf [4] https://www.nhs.uk/news/mental-health/loneliness-increases-risk-of-premature-death/  

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