23 Flood risk and water management

23 Flood risk and water management

National policy

23.1 NPPF is clear that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk. All plans should apply a sequential, risk-based approach to the location of development, taking into account all sources of flood risk and the current and future impacts of climate change so as to avoid, where possible, flood risk to people and property.

23.2 Strategic policies should be informed by a strategic flood risk assessment and should manage flood risk from all sources.

23.3 Development which could affect drainage on or around the site should incorporate sustainable drainage systems (SuDs) unless there is clear evidence that this would be inappropriate. SuDs should also provide multifunctional benefits wherever possible, through facilitating improvements in water quality and biodiversity, as well as benefits for amenity.

23.4 Planning policies should contribute to and enhance the natural and local environment helping to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans (NPPF paragraph 187e). 

Evidence base

Key issues

  • The Council is currently preparing an update to the Strategic Flood Risk Assessment (SFRA), to collate information on all known sources of flooding that may affect existing or future development within the borough. 
  • Ensuring that all new development is directed away from areas of highest risk of flooding (with an emphasis that this should be flooding from all sources) following the sequential and exceptions tests where applicable.  
  • Ensuring that all applications (not just major developments) which could affect drainage on or around the site incorporate SuDs.
  • Promote the multifunctional benefits of SuDs to provide improvements to water quality, biodiversity and amenity to deliver high quality, interconnected and multifunctional green and blue infrastructure.
  • Ensuring the existing flood storage area (Finchett’s Gutter) is retained. If needed, additional areas will be safeguarded informed by the update to the SFRA, LFRMP in liaison with the LLFA and Environment Agency. 
  • Ensuring that development proposals and the quantum of development proposed does not cause unacceptable deterioration to water quality or have an unacceptable impact on water quantity (including drinking water supplies) or waste water infrastructure capacity. 

Current adopted policy

Local Plan

Policy reference

Policy summary

Local Plan (Part One)

ENV 1 Flood risk and water management

Seeks to reduce flood risk, promote water efficiency measures, and protect and enhance water quality.

Local Plan (Part Two)

DM 40 Development and flood risk

Sets out the requirement (where necessary) for a borough-wide sequential test and sequential approach at site level. The policy also lists the requirements of a site-specific flood risk assessment. 

Local Plan (Part Two)

DM 41 Sustainable Drainage Systems (SuDS)

Sets out the requirements for managing drainage and surface water from new developments through the implementation of SuDs. 

Local Plan (Part Two)

DM 42 Flood water storage

Sets out the requirements for development within or adjacent to a flood water storage area. 

Local Plan (Part Two)

DM 3 Water quality, supply and treatment

Sets out that development proposals will be supported where it can be demonstrated that the proposal will not cause unacceptable deterioration to water quality or have an unacceptable impact on water quantity or waste water infrastructure capacity.

Suggested policy approach

23.5 The existing policy approach in Local Plan (Part One) policy ENV 1, which seeks to reduce flood risk, promote water efficiency measures, and protect and enhance water quality will be retained and updated.

23.6 The suggested policy approach is to amend and update Local Plan (Part One) policy ENV 1 to incorporate the Local Plan (Part Two) polices DM 40, DM 41, DM 42 and DM 43 to ensure that:

  • the risk of flooding from all sources arising from new development is minimised; 
  • the outputs from the SFRA update (2025) (in preparation), are used to identify areas of highest risk of flooding from all sources;
  • the policy is aligned with the application of the sequential and exceptions tests set out in the National Planning Policy Framework and planning practice guidance;
  • the requirements for a site-specific flood risk assessment (FRA) are clearly set out;
  • the removal of the requirement, in current Local Plan (Part One) policy ENV 1 and Local Plan (Part Two) policy DM 41, for Sustainable Drainage Systems (SuDS) to be limited to major development in line with NPPF. The suggested policy approach should ensure that new development is designed to manage surface water run off through the use of SuDS, unless there is clear evidence that this would be inappropriate;
  • where needed, additional flood storage areas are designated in liaison with the Environment Agency (EA) and Lead Local Flood Authority (LLFA);
  • high quality, interconnected and multifunctional green and blue infrastructure are delivered in accordance with the Local Nature Recovery Strategy (LNRS);
  • development proposals do not cause unacceptable deterioration to water quality or have an unacceptable impact on water quantity (including drinking water supplies) or wastewater infrastructure capacity.

FW 1

Flood risk and water management

Flood risk
  • Where relevant all development must consider its vulnerability to flooding, taking account of all sources of flood risk and the impacts of climate change. 
  • Apply a borough wide Sequential Test where required in line with the National Planning Policy Framework (NPPF) and the Planning Practice Guidance (PPG). Proposals for development must seek to utilise land at lowest risk of flooding from all sources. 
  • In the application of the sequential test the search for alternative sites should be borough-wide and should not be restricted to sites only capable of accommodating the proposed scale of development. Opportunities to provide development on more than one, sequentially preferable site should be explored where suitable. More guidance on the application of the sequential test is anticipated in future updates to the Flood Risk and Coastal Change PPG. 
  • Where development is necessary in areas of greater flood risk, the development should be made safe for its lifetime without increasing flood risk elsewhere. 
  • Where required, the Exception Test will also be applicable in line with the NPPF and the PPG. Flood resilient construction should be utilised to manage any residual risk. 
  • For development proposals where only part of the site is affected by flooding, including any future flood risk, a sequential approach should be applied to the layout of development avoiding vulnerable uses and site accesses being located in areas at higher risk. If this is achieved, a sequential test may not be necessary and will be subject to case by case assessment. 
  • The assessment of flood risk in relation to any proposed development, should take into account the Cheshire West and Chester Strategic Flood Risk Assessment (SFRA) update (in preparation at the time of writing) and its mapping in addition to the updated mapping provided nationally through the national flood risk assessment (NaFRA2) (Environment Agency). 
Flood Risk Assessment
  • The policy will set out the requirements for a site-specific flood risk assessment in line with NPPF and PPG. 
Sustainable Drainage

The policy will detail the standards and requirements to manage surface water drainage effectively and reduce the risk of flooding elsewhere including:

  • how surface water runoff should be appropriately managed (in accordance with the Cheshire West and Chester Sustainable Drainage Systems (SuDS) Guidance or any subsequent replacement standards;
  • how development proposals should manage and discharge surface water through a sustainable drainage system (SuDS). The preference will be for new development to incorporate surface level SuDS with multi-functional benefits, as opposed to underground tanked storage systems, for the management of surface water;
  • the requirement for approved development proposals to be supplemented by appropriate maintenance and management regimes for surface water drainage schemes;
  • that development proposals should not result in the loss of open watercourse, and culverts should be opened wherever possible;
  • the use of SuDS to enhance the site design and sense of place and where it is incorporated in open space, provide a safe naturalised system without the need for fencing or barriers in line with the Design Code. 
Flood Storage
  • The outputs from the SFRA update will be used to identify the need for additional flood storage areas in liaison with the LLFA and EA. 
Natural flood management

The policy will detail the standards and requirements to deliver natural flood management solutions in accordance with the Local Nature Recovery Strategy (LNRS) including:

  • the design and layout of the SuDS to prioritise nature-based solutions and be designed to incorporate surface water management features as green and blue infrastructure wherever possible; maximising multifunctional benefits for biodiversity, amenity, cooling and water quality;
  • the requirement for natural flood management features such as SuDS to be incorporated into design of schemes providing amenity value and / or biodiversity improvements;  
  • the requirement for watercourses and riverside habitats to be conserved and enhanced, where necessary through management and mitigation measures.
Water quality, supply and treatment
  • The current policy requirements to ensure that development proposals do not cause unacceptable deterioration to water quality or have an unacceptable impact on water quantity (including drinking water supplies, water for industry and managing drought) or wastewater infrastructure capacity will be retained.

Question FW 1

Do you agree with the suggested policy approach towards flood risk and water management, as set out in FW 1 ‘Flood risk and water management’ above? If not please suggest how it could be amended?

Question FW 2

Should the SuDs element of the suggested policy approach include a requirement for nature-based solutions to maximise multifunctional benefits? 

Question FW 3

Should new areas for flood storage be identified and designated?

Question FW 4

How should the new Local Plan address any potential future impacts on water quality, supply or waste water infrastructure?