Flood risk assessments for planning applications

Planning for flood risk in England is underpinned by a sequential, risk-risk based approach to development. This must be informed by up to date evidence that considers all sources of flood risk, including the current and future impacts of climate change.
Flood risk assessments (FRAs) are therefore an important component of the evidence base for planning applications, and are vital for planning officers to make an assessment of the suitability of proposals.
This webinar recording gives an overview of the role of flood risk assessments and when they are required; and clarifies roles and responsibilities for developing and reviewing FRAs for all sources of current and future flood risk.
Featuring Sandrine Thomas, Flooding and Coastal Risk Management Advisor and Andrew Pattinson, FCRM Development Planning Advisor at the Environment Agency. The session was chaired by TCPA Director of Policy, Hugh Ellis.

[@DrRobSaunders]

Hi Hugh and team
I'm a consultant flood risk assessor and would like to say that these slides are just what are needed so as to allow all LPA's to achieve consistency in their approach to FRA reports across England - thanks.
I have some comments:
The first comment I'd like to make is in relation to the suggested Condition at 38:43 on the video.
You are indeed wholly correct in respect to the six tests under NPPF:56 (which many LPA officers are not as it happens) however points 3 and 5 (flood proofing and emergency planning) while I agree are 100% required these items, I'd suggest, are not currently enforceable (being one of the six tests) under the T&CP Act.
Flood proofing measures:
There is no possible way for a LPA to "in practice, detect a contravention" and furthermore, the only information of such measures is currently no more than the Government's "General Advice" as per the widely cited "Improving the flood performance of new buildings" and Ciria guidance. It don't believe it to be possible to enforce "general advice" or "guidance".
This is however controlled under the Building Act 1984, as amended by Section 40 FWM Act 2010, making it not "Relevant to Planning".
Hence, I'd suggest Point 3 actually fails the NPPF:56 tests and could not be lawfully applied.
Emergency planning (flood plans and text services etc):
Again, I fully agree with the rationale here and always recommend such measures however, as with the last point, such measure cannot be enforced under the T&CP Act hence Point 5 would also fail the six tests. A LPA could not, in practice, detect a contravention.
I'm not wholly convinced that Point 4 could be enforced under the T&CP Act either. There is no contravention possible when part of that which is sought ("Precisely") is "identification" and also there is no lawful definition of "safe haven" in respect to the T&CP Act. I have found very subjective definitions as to what qualifies as "safe" haven - and there lies the problem, all too subjective.
Points 3, 4 & 5 should be only an informative on any Approval in my opinion.
And a point regarding LLFA's:
My understanding is that these currently have no "Authority" whatsoever on Minor or Non-major development. They are empowered only as Statute consultees in respect to the T&CP Act on Major development with surface water drainage implications (as of 15th March 2015) so as to provide "technical advice" - but have no powers in respect to fluvial flood risk for such applications.
Any comments currently made by a LLFA to a LPA in respect to flood related matters where they have no lawful Authority can be nothing more than requests rather than Requirements. All to often I see comments where a LLFA "Requires that...." on Minor or Non-major development. On such developments the LLFA officers are no more than the FRM team or similar offering guidance only.
Finally, on the last point of freeboard.
+600mm is without question where single storey sleeping accommodation is required. However, the issue arises with variations to this in many a SFRA, with some SFRA very out of date. These do however form part of the Evidence Base for an application to be assessed against and it's therefore a very hard win to get a developer to raise more than the +300mm typically cited in the SFRA reports. Personally, I think such reference to freeboard should be removed from all future SFRA reports and placed wholly within PPG, for consistency sake if nothing more.
Hope of use
Dr Robin D Saunders CEng, C BuildE, BEng, PhD.