Appendix 2 Area 2 Flood Risk Sequential Test

FLOOD RISK: PPS25

Sequential Test & Exceptions Test

Area 2 of the Central Elland SPD

There is a locally recognized need for a railway station in Elland to permit more sustainable travel patterns into and out of the town. The ambition to create a railway station is strongly supported by planning guidance at the national, regional and local levels, in addition to the Sustainability Appraisal and Strategic Environmental Assessment accompanying this SPD.

There is a locally recognized need for a railway station in Elland to permit more sustainable travel patterns into and out of the town. The ambition to create a railway station is strongly supported by planning guidance at the national, regional and local levels, in addition to the Sustainability Appraisal and Strategic Environmental Assessment accompanying this SPD.

However, the proposed facility as it stands in this SPD is only an indicative proposal. In order for a railway station development to actually come forward, Elland will need to be identified in the West Yorkshire PTE’s Rail Plan as requiring a r⁡       ilway station, and will then need to be selected ahead of other localities to have a Feasibility Study undertaken. This study, and any subsequent development, would be subject to the availability of funding.

The SPD encourages the eventual delivery of a railway station in Elland, and proposes an appropriate location for such a facility (“the Site”.)

The Site was formally used for industrial and employment purposes and now consists of a cleared Brownfield site. It has a combined area of 1.5 hectares. The Site lies adjacent to the Lowfields Business Park and is approximately 450 metres from the Town Centre.

It is a flat site, bounded by Wistons Lane to the west, Lowfields Way to the east, a slip road to the Calderdale Way to the south, and the Lowfields Business Park to the north. The Site is bisected by the Caldervale railway line, which runs on an east-west axis through the Site.

The Site is defined as a Primary Employment Area in the Replacement Calderdale Unitary Development Plan (RCUDP).

The Site is identified in the SPD as a potential location for an Elland railway station, owing to its relationship with a passenger-carrying railway line, and its proximity to Central Elland and the Lowfields Business Park, which is a major employment site. The Site is also highly accessible both by pedestrian and vehicular means, and the size of the Site is sufficient to permit the development of park and ride, and other facilities associated with a railway station.

The Site is defined within the SFRA (Calderdale, Kirklees and Wakefield Strategic Flood Risk Assessment May 2005), as Flood Zone 3a, High Probability, as set out in PPS25. This zone comprises land assessed as having a 1 in 100 or greater annual probability of river flooding. A number of tests within PPS25 therefore need to be applied to ensure that that the Site is appropriate for the proposed development.

Sequential Test

The sequential test aims to determine if there are any other sites that would be suitable for the proposed development that have a lower risk of flooding. To enable a true comparison the sites would have to accommodate the railway line itself, and be of comparable size.

Given these strict criteria for potential sites, there is only one other suitable site for the proposed facility. This alternative site is approximately 1.8km to the east of Elland Town Centre, and has an existing public highway access from Shaw Lane, which travels northwards towards the railway line from the Elland-Riorges Link. The southern, western and eastern extents of this site are within and surrounded by open space designated as Greenbelt. The northern extent of the site lies within the Lowfields Business Park, on land designated as primary Employment in the RCUDP.

The site is defined within the SFRA (Calderdale, Kirklees and Wakefield Strategic Flood Risk Assessment May 2005), as flood zone 1, Low Probability, as set out in PPS25. This zone comprises land assessed as having a 1 in 1000 or less annual probability of river flooding. A northern access to the site from Lowfields would however be on land defined as High Risk, flood zone 3a.

Shaw Lane is a predominantly narrow access, which proceeds to the site through Greenbelt land. A significant amount of upgrading would be required to allow for higher volumes of traffic and for larger vehicles to reach the site. Access to Lowfields could be permitted through the extension of a roadway, which currently terminates 300m to the north. This however, is a private access, and its use would not only require permission but also significant investment both to lengthen and to widen it for use by general traffic bound for the railway. A tunnel beneath the railway line may also then be required to link this roadway with Shaw Lane.

The infrastructure for pedestrian movements between Central Elland and the site would require significant investment to encourage pedestrians to travel to the site.

Reason for discounting

Name, Size, Current Use Constraints

  • Land off Shaw Lane, 1.5ha plus.
  • Poor road access through the Greenbelt would require significant upgrading;
  • Lack of access to Lowfields would require significant investment to rectify, and through developed land in third party ownership;

  • Distance from Central Elland and the site are too great to encourage movements between the two, especially by pedestrians;

  • The development of a station and associated facilities in the Greenbelt would conflict with planning policy objectives for the location.

These compelling arguments against the alternative site, lead to us to conclude that the Site would be the most appropriate location for the proposed development, despite the fact that there is a greater risk of flooding than at the alternative site. However, the nature of the proposed use, and its proposed location in Flood Zone 3a mean that the Exceptions Test must be applied.

Exceptions Test

The proposed use of the Site is identified as “Essential Infrastructure” in Table D2 of PPS25. Table D3 of PPS25 states that the development of Essential Infrastructure in Flood Zone 3a requires the application of the Exceptions Test.


Part A

The development would provide wider sustainability benefits to the community, which are considered to outweigh the flood risk. The site is currently a vacant Brownfield site, in close proximity to Central Elland and to the Lowfields Business Park.

The Site’s location and excellent road links make it ideal for the development of a railway station, which has been recognized by the local community and the Council as essential to Elland’s needs. The wider sustainability benefits are: -


Provision of much needed sustainable transport links

Currently, commuters into and out of Elland are encouraged to travel by car, particularly to and from more distant regional centres, such as Leeds and Manchester.

A railway service would reduce the need for people to travel by car, and would therefore be more socially, economically and environmentally sustainable.

Brownfield Land & Accessibility

The site is sustainable; it is a Brownfield site, approximately 450 metres from the Town Centre and a major employment site. The site is accessible by public transport and pedestrians travelling from Central Elland.

Regeneration

The provision of a highly sustainable public transport service would contribute to the regeneration of the area by encouraging more people to live in, work in and visit Elland. Inward investors would be more likely to locate in the area, creating employment opportunities.

Part B

The development is on previously developed land. Historically the site has been used for employment and industrial purposes. The benefits of the scheme, which include the redevelopment of a vacant Brownfield site and the provision of a highly sustainable form of public transport, are considered to outweigh the flood risk.

Part C

A Flood Risk Assessment would be required to accompany any planning application on the Site and would be the responsibility of the applicant. The FRA must demonstrate that the Site will be safe, and can be developed with minimal risk to the subsequent occupants and in a manner that would not increase flooding elsewhere, and where possible reduce flood risk overall.


The Flood Risk Assessment should include:

• Assessment of flood risk on site, including flow rates and depths;

• Proposed mitigation measures through design;

• Proposed mitigation measures in the form of floor warning, evacuation procedures, safe access and egress;

• Consideration of climate change precautionary sensitivity ranges, set out in Table B.2 of PPS25;

• Consideration of developer contributions for flood defence maintenance and or flood warning operation.


NB

In order for a development to pass Part C of the Exception Test outlined in PPS25 a flood risk assessment will be required as part of any future planning application. This flood risk assessment should be consistent with the requirements of Annex E of PPS25 and should demonstrate that the development will be ‘safe’ without increasing flood risk elsewhere. In particular this development should reduce the overall flood risk in the area as required by Part C.

The flood risk assessment should include details of how this development will achieve an overall flood risk reduction. If it cannot be clearly demonstrated that this development can be made safe or that flood risk is not reduced overall, the Environment Agency would object to the planning application.