9.1 New development can be affected by climate change, but offers the opportunity to design-in measures to avoid or mitigate its effects at the outset. Therefore, the Local Plan can be instrumental in ensuring that future development is better equipped to deal with the impacts of climate as it will be in the future.
9.2 The low-lying and gently undulating topography of Fylde, together with the wet climate of North West England, means that, in Fylde, flood risk is the most commonly felt effect of climate change, and flood events are projected to increase. The sections on flood risk below cover what is therefore the most significant climate change effect for Fylde.
9.3 Other measures that can either reduce the impacts of climate change through prevention, or mitigate effects that occur, can be achieved through design policies. These are considered separately in Chapter 8 of this document.
9.4 The generation of renewable energy can reduce carbon emissions by providing a substitute source of energy supply to those emitting carbon. The section on renewable energy below addresses the issues for the Local Plan in the development of renewable energy schemes.
Flood Risk
9.5 Existing Local Plan policy states that the sequential risk-based approach to the location of development as required by the Framework will be taken, meaning that development will be directed to sites at low risk of flooding. The latest national policy retains a sequential approach to the location of development so this would remain unchanged. The sequential test now requires all sources of flooding to be considered in making the assessment.
9.6 All local planning authorities are required to conduct a Level 1 Strategic Flood Risk Assessment (SFRA) which assesses the risk to an area from flooding from all sources, now and in the future, taking account of the impacts of climate change, and how to address flood risk in development. Fylde Council, together with the other Fylde Coast authorities Blackpool Council and Wyre Council, undertook a Level 1 SFRA in 2024. The SFRA identifies flood risk areas for all types of flooding through a series of maps.
9.7 There are small areas of the Borough where individual streams enter the estuary where coastal flooding can potentially occur. This particularly affects some built-up areas within Lytham. Otherwise, the Environment Agency’s flood high-risk zones affect land surrounding major watercourses, the risk coming from fluvial flooding. The areas falling into the high-risk zones are shown on the Environment Agency’s Flood Map for Planning.
9.8 In addition to the areas affected by coastal and fluvial flooding, surface water flooding can affect many areas. Surface water flooding occurs when intense or prolonged rainfall leads to water collecting on the surface in certain areas. Due to Fylde’s low-lying gently undulating terrain, areas affected are very widespread throughout the Borough, and most if not all fields have an area where surface floodwater collects. Although the Council’s initial assessment of potential development sites is not yet complete, it is clear that most if not all sites that will be allocated will be at some risk of surface water flooding. It is therefore possible that the Council will need to conduct a Level 2 Strategic Flood Risk Assessment, to determine which sites would have the lowest risk of flooding.
9.9 Where an area of a site is at flood risk, development that is vulnerable to flooding should be directed to the parts of the site that are not affected. This can have the effect of substantially reducing the developable area of a site. Attenuation measures can moderate this, for instance through provision of water storage capacity within ponds; however, great care is needed with approaches to development that rely on changes to the site levels, and consultees are likely to require detailed modelling of the impacts on land downstream of the site before concluding that it is acceptable.
9.10 As well as the potential for flood risk on site, development sites that are not themselves at risk of flooding can have the effect of contributing to increased flooding elsewhere, through increased runoff from the site. Existing Local Plan policy requires attenuation measures through a sequential approach to minimise impact; however, this includes a clause that instead allows for surface water discharge to watercourses or existing surface drains or sewers, where other measures would adversely affect viability or are unfeasible. Given the critical importance to the Borough of avoiding excess discharges to sewers, which then could test the capacity of treatment plants and in turn affect bathing water quality, this element of the policy in particular will be reviewed for effectiveness.
Q55. Would you support an absolute requirement that all development sites result in no greater surface water runoff after development than when they were in their greenfield state?
Q56. Do you support the Council’s approach to site selection considering all sources of flood risk? Please add any further comments you have on the impact of flood risk on development sites.
Renewable Energy
9.11 The current government has prioritised the development of renewable energy projects to contribute to the overall national energy needs. Renewable and low-carbon energy can be generated through a range of methods – particularly relevant to Fylde are:
- Large-scale solar
- Onshore wind
- Offshore wind
- Microgeneration
9.12 The existing Local Plan policy relates to all types of onshore renewable energy development except large-scale onshore wind (for which there were no areas in the Borough where it would have community support, as was previously required). The policy set out a series of criteria which would need to be met for a proposal to be acceptable, including matters relating to aviation and defence navigation systems and communications.
9.13 The policy criteria for renewable energy development cross-refers to previous national policy protecting the best and most versatile agricultural land. Although national policy has changed, the Council could retain the sequential approach requiring the use of land of lower quality instead, given that the areas of such land that are available are extensive.
Q57. Do you support the retention of the main elements of the existing renewable energy policy that makes clear that approval will only be given where a proposal can demonstrably avoid harmful impacts?
Q58. Are there areas of the Borough where particular types of renewable energy development should not take place due to harmful impacts? Please specify and explain.
Q59. Should the new Local Plan retain the sequential approach to the use of agricultural land for renewable energy projects?
Building Efficiency
9.14 The Building Regulations set efficiency standards for completed buildings, in terms of energy use during operation. However, where a building is demolished and replaced by another, any carbon savings during its use by reduced energy consumption (reduction in operational carbon) can be dwarfed by the carbon released through the energy consumed in the demolition of the previous building on the site and the erection of the new building, including the materials used. This element is termed “embedded carbon”.
9.15 Where a development proposal relies on any statement of improved energy efficiency, this should only be accepted and given any weight in planning decisions on the basis of a positive benefit considered over the whole life of the building (whole life carbon). This takes account of both operational carbon and embedded carbon. Such policies have been adopted and are in use elsewhere in the country.
9.16 At present there is no Local Plan policy that takes account of whole life carbon, and building efficiency is mentioned in other policies and taken to mean only its operational efficiency. This can lead to perverse outcomes. A revision to relevant policies to make clear that any carbon/efficiency assessment should be based on whole life carbon could be considered.
Q60. Do you support a whole-life-carbon approach to the assessment of building efficiency?
