Conwy Deposit Local Development Plan 2007 – 2022 (Revised edition 2011) BACKGROUND PAPER 17 Conwy Strategic Flood Risk Assessment March 2011 This document is available to view and download on the Council’s web-site at: www.conwy.gov.uk/ldp . Copies are also available to view at main libraries and Council offices and can be obtained from the Planning Policy Service, 26 Castle Street, Conwy LL32 8AY or by telephoning (01492) 575447. If you would like to talk to a planning officer working on the Local Development Plan about any aspect of this document please contact the Planning Policy Service on (01492) 575180 / 575181 / 575124. If you would like an extract or summary of this document on cassette, in large type, in Braille or any other format, please call the Planning Policy Service on (01492) 575180. CONTENTS Page Introduction ................................................................................................................ 4 Overview of potential flooding sources in Conwy ....................................................... 5 Planning Policy Wales 2010 (PPW) ........................................................................... 5 Technical Advice Note 15 (TAN15) ............................................................................ 6 Shoreline Management Plans .................................................................................... 8 Conwy Tidal Flood Risk Study ................................................................................... 9 Background .............................................................................................................. 10 Overview of the Conwy Tidal Flood Risk Study........................................................ 10 Development of the Conwy Tidal Flood Risk Study ................................................. 11 Benefits to Future Planning Decision Making........................................................... 12 Local Planning Authority Consultations .................................................................... 12 Consideration of Flood Risk by Proposed Land Use ................................................ 13 Housing Sites ....................................................................................................... 13 Social Club Llandudno Junction ........................................................................ 26 Plas Yn Dre Llandudno ..................................................................................... 28 Off Heol Martin Eglwysbach.............................................................................. 32 Employment Sites................................................................................................. 36 Goods Yard Llandudno ..................................................................................... 42 Mixed Use Employment & Housing allocations .................................................... 50 Waste Management Facility – Gofer..................................................................... 52 Conclusion ............................................................................................................... 52 3 Introduction This paper is one of a series of background papers accompanying the Revised Deposit Local Development Plan (LDP) document. When the Council publishes its Revised Deposit LDP, it must explain how the relevant policy has been formulated based on the evidence base available to the Council at the time. This background paper outlines the evidence considered by the Conwy County Borough Council during the preparation of the Local Development Plan (LDP) and the actions proposed by Council to ensure that the risk to new developments from flooding is minimised. The paper should be read in association with Local Development Plan Background Paper 21 - ‘Site Deliverability Assessment’ which records in detail the individual assessments undertaken of all the sites considered for allocation in the LDP. Flooding is a natural occurrence which is often hard to predict. It can pose a direct risk to human life and cause extensive damage to both property and infrastructure. The threat posed by climate change is likely to increase the risk of coastal and fluvial flooding due to a predicted rise in the sea-level and a more intense rainfall. Therefore the risk of flooding is a material consideration which influences both development control decisions and LDP site allocations. The aim of the SFRA is to inform the application of the sequential test to candidate development sites within the LDP. This will enable the Local Planning Authority to adopt the precautionary principle promoted in National planning guidance to direct development away from high flood risk areas. The Council is mindful of the current concerns regarding the risk of flooding and the effects of climate change. The Council does not wish to endanger life and property by proposing inappropriate development in areas at high risk from flooding. However, since 85% of the population of Conwy lives within coastal areas, the Council is also mindful that it has a responsibility to maintain the vitality of its settlements. Therefore the SFCA will demonstrate that the consequences of flooding are sufficiently understood and can be managed in an acceptable and sustainable way to permit development within areas of low risk in order to satisfy identified local needs. 4 Overview of potential flooding sources in Conwy Flooding can occur from a number of sources, including: • Tidal flooding which can occur during high tides and stormy conditions. A tidal surge can also occur when low atmospheric pressure coincides with a high tide, this can result in serious flooding. • Fluvial flooding can happen during heavy rainfall when water drains from the surrounding land into the watercourse which cannot cope with this additional volume of water. • Surface water flooding can occur when heavy rainfall overwhelms the drainage capacity of the local area and is unable to drain away sufficiently. • Sewer flooding can be caused by heavy rainfall which can block sewers. Sources of flooding within Conwy include: Tidal Flooding - Coastal Zone Fluvial Flooding - Afon Gele, Fluvial Flooding - Afon Bach, Fluvial Flooding - Afon Conwy, Fluvial Flooding – Afon Gyffin, Fluvial Flooding – Afon Hiraethlyn, Fluvial Flooding – Afon Ganol, Fluvial Flooding – Afon Elwy, Fluvial Flooding – Afon Ddu, Fluvial Flooding – Afon Collen, Fluvial Flooding – Min Afon, Fluvial Flooding – Afon Clwyd, Planning Policy Wales 2010 (PPW) The LDP has a significant role to play in promoting sustainable development (Sustainable development principles PPW 4.3). Planning Policy Wales states that Local Planning Authorities must adopt a proactive ‘sustainable approach to flooding’ by avoiding development within flood risk areas rather than relying on mitigation measures such as flood defences. Local Planning authorities must also ensure that new development does not increase the risk of flooding elsewhere. 5 Technical Advice Note 15 (TAN15) Technical Advice Note 15 supplements the policy contained within PPW in relation to development and flood risk. It sets out a precautionary framework which is governed by a development advice map which consists of three zones; A, B and C which subdivided into C1 and C2 areas as detailed in Figure 1 below. Proposed development within these zones will require the appropriate planning test as outlined in TAN15. Figure 1. (TAN 15 2004) Use within the precautionary Description of Zone Considered to be at little or no risk of fluvial or tidal/coastal flooding. Areas known to have been flooded in the past evidenced by sedimentary deposits. Based on Environment Agency extreme flood outline, equal to or greater than 0.1% (river, tidal or coastal) Areas of the floodplain which are developed and served by significant infrastructure, including flood defences. Areas of the floodplain without significant flood defence infrastructure. framework A Used to indicate that justification test is not applicable and no need to consider flood risk further. B Used as part of a precautionary approach to indicate where site levels should be checked against the extreme (0.1%) flood level. If site levels are greater than the flood levels used to define adjacent extreme flood outline there is no need to consider flood risk further. C Used to indicate that flooding issues should be considered as an integral part of decision making by the application of the justification test including assessment of consequences. C1 Used to indicate that development can take place subject to application of justification test, including acceptability of consequences. C2 Used to indicate that only less vulnerable development should be considered subject to application of justification test, including acceptability of consequences. Emergency services and highly vulnerable development should not be considered. The precautionary framework of TAN 15 sets out definitions of vulnerable types of development as detailed in Figure 2 below. Figure 2. (TAN 15 2004) Development category Types Emergency services hospitals, ambulance stations, fire stations, police stations, coastguard stations, command centres, emergency depots and buildings used to provide emergency shelter in time of flood Highly vulnerable development all residential premises (including hotels and caravan parks), public buildings (e.g. schools, libraries, leisure 6 centres), especially vulnerable industrial development (e.g. power stations, chemical plants, incinerators), and waste disposal sites Less vulnerable development General industrial, employment, commercial and retail development, transport and utilities infrastructure, car parks, mineral extraction sites and associated processing facilities, excluding waste disposal sites Emergency Services are described as facilities that need to be operational and accessible at all times. Highly vulnerable development describes development where the ability of occupants to decide on whether they wish to accept the risks to life and property associated with flooding, or be able to manage the consequences of such a risk, is limited. It also includes industrial uses where there would be an attendant risk to the public and the water environment should the site be inundated. Less vulnerable development describes development where the ability of occupants to decide on whether they wish to accept such risks is greater than that in the highly vulnerable category. Section 6 of TAN 15 – ‘Justifying the location of development’ - further advises that new development should be directed away from zone C and that development in zone C will only be justified if it can be demonstrated that: i. Its location in zone C is necessary to assist, or be part of, a local authority regeneration initiative or a local authority strategy required to sustain an existing settlement; (The Deposit LDP is an example of a local authority strategy) or, ii Its location in zone C is necessary to contribute to key employment objectives supported by the local authority, and other key partners, to sustain an existing settlement or region; and, iii It concurs with the aims of PPW and meets the definition of previously developed land (PPW fig 2.1); and, iv The potential consequences of a flooding event for the particular type of development have been considered, and in terms of the criteria contained in sections 5 (of the PPW – see also Figure 2 above) and 7 and appendix 1 (of the PPW) found to be acceptable. 7 Table 9 of TAN 15 provides a summary of the technical guidance and Figure 3 contains extracts from that Table: Figure 3. DAM A B Development Type Emergency services Highly vulnerable development Less vulnerable development Other Emergency services Highly vulnerable development C1 Emergency services Highly vulnerable development Less vulnerable development C1 Other C2 Emergency services Highly vulnerable development C2 Less vulnerable development C2 Other Development Advice No constraints relating to river or coastal flooding, other than to avoid increasing risk elsewhere. Generally suitable for most forms of development. Assessments, where required, are unlikely to identify consequences that cannot be overcome or managed to an acceptable level. It is unlikely, therefore, that these would result in a refusal of planning consent on the grounds of flooding. Plan allocations and applications for all development can only proceed subject to justification in accordance with section 6 and acceptability of consequences in accordance with section 7 and Appendix 1. Plan allocations and applications for development should only be made if considered acceptable in accordance with section 7 and Appendix 1. The flooding consequences associated with Emergency Services and highly vulnerable development are not considered to be acceptable. Plan allocations should not be made for such development and planning applications not proposed. Plan allocations or applications for less vulnerable development can only proceed subject to justification in accordance with section 6 and acceptability of consequences in accordance with section 7 and Appendix 1. Plan allocations and applications for development should only be made if considered acceptable in Shoreline Management Plans A Shoreline Management Plan is a policy document for coastal defence management. It takes account of other planning initiatives and legislative requirements and is intended to inform wider strategic planning. It does not set policies for the management of issues such 8 as development or land drainage, though all land use, especially in the future, should consider the SMP. Conwy County Borough Council lies within sub cell 11a of the North West England and North Wales Shoreline Management Plan 2. The main objective of an SMP is to identify sustainable long-term management policies for the coast. It is inevitable that the plan will recommend changes to the current approach in some areas, however, it will help manage these so that the people, places, industry and wildlife affected can adapt at a reasonable pace. This approach avoids tying future generations into inflexible and expensive options for defence. The shoreline management policies that will be considered are those defined by DEFRA and WAG guidance, as detailed in Figure 4.. Figure 4. (Table 2 of the North West England and North Wales Shoreline Management Plan 2) Policy Option Description Policy Option Description Hold the Line By maintaining or changing the current standard of protection. This policy includes those situations where work is carried out in front of the existing defences (such as beach recharge, rebuilding the toe of a structure, building offshore breakwaters and so on) to improve or maintain the standard of protection provided by the existing defence line. It also includes work behind existing defences (such as building secondary flood defences) where this work would form an essential part of maintaining the current coastal defence system. Advance the Line By building new defences on the seaward side of the original defences. Use of this policy is limited to those policy units where significant land reclamation is considered. Managed Realignment By allowing the shoreline to move backwards or forwards, with management to control or limit movement (such as reducing erosion or building new defences on the landward side of the original defences). No Active intervention Where there is no investment in coastal defences or operations. Conwy Tidal Flood Risk Study The following section outlines the role that the “Conwy Tidal Flood Risk Study” takes in informing the decisions taken by the Planning Authority and highlights the benefits of the study in terms of controlling development within areas at risk of flooding both now and in the future as the effect of climate change has an increasing influence over development strategies. 9 Background In 2004, the Welsh Assembly Government published guidance in the form of ‘Technical Advice Note 15’ (TAN15) which sets out planning policy guidance for Wales in relation to development and flooding. The guidance provides a framework within which risk arising from both river and coastal flooding, and from additional run-off from development in any location, can be assessed. The overarching aim of TAN 15 is: • To direct new development away from those areas which are at a high risk of flooding; • Where development has to be considered in high risk areas, only those developments which can be justified are located within such areas. As part of TAN 15, Development Advice Maps were provided to use to determine when flood risk issues needed to be taken into account when planning for future development. These maps were based on the best available information, making use of the Environment Agency’s extreme flood outlines and the British Geological Survey (BGS) drift data. Conwy County Borough Council has made a commitment to its communities to enhance and protect the local environment and has outlined this as a key priority in corporate documents such as The Community Strategy and Corporate Plan, where the focus is to ensure the sustainability of future generations. With Climate Change now featuring as a key threat to sustaining communities, the impacts, such as increased flooding, have been recognised as a high risk requiring action to manage in the present and plan for the future. In response, through the work undertaken by the Environmental Services Department on the Conwy Tidal Flood Risk Study, Conwy County Borough Council is now well informed about the risks of tidal flooding both now and in the future and the result offers an invaluable tool for informing the planning decision making process. Overview of the Conwy Tidal Flood Risk Study The Conwy Tidal Flood Risk Study offers guidance on a significantly more local and more accurate scale than the Development Advice Maps provided in TAN 15. The study initially assessed the risk of tidal flooding in three popular coastal towns, namely Llandudno, 10 Towyn and Kinmel Bay. The level of detail offered in the study provides specific information relating to the risk of tidal flooding on an almost property by property scale, which allows significantly for more informed decision making in terms of appropriate and inappropriate development areas within the three towns. The study was subsequently expanded to take account of the effects of Climate Change. Current predictions show an increase in sea levels, rainfall and storm events. These predictions were extrapolated within the study models to produce flood risk maps for both 50 and 100 years time. This innovative process provides developers and the Planning Authority with a facility to measure tidal flood risk on a detailed scale for the present day and to witness potential risk, taking into account the effects of Climate Change, in both 50 and 100 years time. With this information and with collaboration between Environmental Services and the Planning Department, Conwy can improve the sustainability of communities in that development decisions in Llandudno and shortly Towyn and Kinmel Bay can be made based on full consideration of the predicted effects of Climate Change. Development of the Conwy Tidal Flood Risk Study The overall objective of the Conwy Tidal Flood Risk Study was to provide a robust, scientific appraisal of the risk of flooding from tidal inundation categorising the risk in the three coastal towns of Llandudno, Towyn and Kinmel Bay. The study was conducted in two stages: Stage 1 A detailed review of the coastal defences boarding flood plains was undertaken. This was supplemented by a review of past flood events and analysis of waves and water levels. The results of these studies provided a sound basis for undertaking detailed assessment of flood inundation modelling proposed for stage 2, and highlighted defences likely to be the most important in terms of their flood defence function. Stage 2 In stage 2, detailed numerical modelling was carried out to simulate different flood scenarios in Pensarn to Kinmel Bay, Llandudno West Shore and North Shores, Penrhyn Bay / Rhos on Sea. Overtopping only scenarios from all the defences in the three areas 11 were examined to assess the effect of overtopping on the hinterland. Breach scenarios were then examined for the same purpose. A separate scenario, reflecting the breaching of the Towyn defence was also undertaken, given the serious flooding in 1990. The model outputs were used to produce detailed interactive flood risk maps which provide accurate information relating to flood depth, rate of rise, speed of inundation and velocity, in accordance with TAN 15 guidance. The maps will shortly be made available for any developer as well as the Planning Authority to use through the Conwy County Borough Council website. Benefits to Future Planning Decision Making The Conwy Tidal Flood Risk Study is an innovative and valuable tool for the Planning Authority in driving better, more informed planning and development decisions with greater accuracy and more appropriate allowance for the effects of Climate Change than was traditionally allowed for within the framework of TAN 15. The study enables identification of where future breaches are likely to occur, so that not only can coastal defences be planned for the future, but also Planning policy and decisions can deter development in high risk areas. This information has informed the selection of sites for development within the LDP. Local Planning Authority Consultations The Council’s Planning Policy Service has considered the merits of many sites for possible allocation in the LDP and for different forms of development. The Planning Policy Service has also consulted widely on sites but did not consult on sites which were clearly unsuitable. As explained in the Introduction to this Background Paper, Background Paper 21 - ‘Site Deliverability Assessment’ records in detail the individual assessments undertaken of all sites considered for allocation in the Local Development Plan (LDP), including the risk from flooding. As regards to the risk from flooding, the Planning Policy Service has: • Taken account of the advice contained in PPW and TAN 15. • Examined the Development Advice Map issued with TAN 15. 12 • Consulted the Environment Agency Wales (EAW). • Consulted with Welsh Water (WW). • Consulted with the Council’s Environmental Services Department for technical advice on flood risk. • Liaised with neighbouring local planning authorities through the North Wales Policy Officers Group and individual meetings with neighbouring Councils. Consultation with the EAW has enabled the Planning Policy Service to access more up-todate information than available on the original DAM map issued with TAN 15 in 2004, and information from the Conwy Clwyd Catchment Management Plan. Consultation with Welsh Water has enabled the Planning Policy Service to access information on the availability of water supply and the capacity of the sewerage network, including both surface and foul water and the capacity of sewage treatment works. Consultation with the Council’s Environmental Services Department has enabled the Planning Policy Service to access information from the Conwy Tidal Flood Risk Study, Local Area Reports and Shoreline Management Plans. Consideration of Flood Risk by Proposed Land Use Housing Sites TAN 15 defines housing as highly vulnerable development, which should not be located within zone C2 flood risk areas unless it can be justified. However, since 85% of the population of Conwy lives within coastal areas, the Council is mindful that it has a responsibility to maintain the vitality of its settlements through new developments. Therefore a small number of housing sites which lie partially within zone C2 have been proposed within the LDP. This section seeks to explain the rationale behind the following housing allocations and the mitigating measures which will be put in place to overcome the risk of flooding. The following series of tables indicates the location of new housing development and its vulnerability to flooding. They also contain relevant mitigation measures as recommended by the EAW. Where a site is identified as lying partially within a C2 flood zone, development will be avoided within that designated area where ever possible. For those sites which cannot avoid development within the designated flood zone a justification test has been 13 undertaken in line with TAN 15 requirements. The Social Club in Llandudno Junction is the only housing site on which development within the C2 zone cannot be avoided. However, the Environment Agency has indicated that the proposed development would satisfy TAN 15 requirements. 14 Urban Development Strategy Area - Housing Urban Settlement Site Housing Allocation Abergele Llanfair Road, Abergele 70 Dwellings Abergele Abergele Abergele Land South of Siamber Wen, Abergele Rhuddlan Road, Abergele Tandderwen Farm 120 Dwellings 150 Dwellings 300 Dwellings Flood Zone Mitigation Officer Comment TAN 15 Zone A – small section of zone C2 on the eastern boundary adjoining the river. The site is considered suitable as there is a low risk of flooding. No objections raised No development will take place immediately adjacent to the river, within the C2 flood zone. TAN 15 Zone A – small section of zone C2 on the eastern boundary adjoining the river. Flood risk from River Gele (Main River) but no know risk from ordinary watercourse at south of site). No objection but no residential development immediately next to the main river No development will take place immediately adjacent to the river, within the C2 flood zone. TAN 15 Zone A Parts of the site are at low risk of flooding. Flooding from the ordinary watercourse North West of the site due to blockage of inlet to the Rhuddlan Road culvert. No objection but flood mitigation proposals will be required prior to development commencing Suitable. Mitigation measures will be outlined within the development brief EA Flood Zone 2 – low to medium risk in the north east corner TAN 15 Zone A EA flood zone 1 – low risk. No objection from No development Environment Agency or will take place the Council’s Environment immediately and Technical Service, but adjacent to the both recommend no river. residential development immediately adjacent Afon Gele (known previous TAN 15 Justification Test Needed No No No No 15 flooding). No objection, but avoid developing immediately adjacent to the Afon Gele. Llandudno Junction Penrhyn Bay Social Club/Youth Club, Llandudno Junction Plas Penryhn, 50 Dwellings 30 The site is split between TAN 15 Flood Zones A and C2. No issues Attach condition to any application to ensure surface water arrangements are acceptable and do not increase flood risk elsewhere in the catchment. Watercourses - no ground raising within min.4m from edge. Following the extensive flooding from the Afon Wydden in 1993, a Flood Alleviation Scheme was carried out on the watercourse. The standard of protection afforded for the area as part of the scheme was that of a 1 in 200 year at the time of completion in 1995. The easterly section of this site is within TAN 15 flood risk zone C2 and although the Environment Agency would suggest the proposals would satisfy TAN 15 requirements, the extreme event (0.1% annual probability flood) should also be considered. No Objection. Yes Suitable No 16 Llandudno Llanfairfechan Penrhyn Bay Dwellings Plas yn Dre, Llandudno 40 Dwellings Adjacent to Glanafon, Llanfairfechan 20 Dwellings TAN 15 Flood Zone C1. The site is partially with TAN 15 flood risk zone C2 EA flood zone 3 high risk (North East corner only) Llanfairfechan Llanfairfechan West of Penmaen Park, Llanfairfechan 75 Dwellings TAN 15 zone A; Opposite Bryn Y Neuadd, Llanfairfechan 150 Dwellings TAN 15 zone A EA flood zone 1 – low risk EA flood zone 1 – low risk. Although the Council has carried out the ‘Llandudno Inundation Modelling’ exercise (as part of the Conwy Tidal Flood Risk Assessment) which indicate that for current day values the site would be flood free during the 0.5% AEP, due consideration is required for the impacts of climate change and sea level rises. Suitable. The EA have modelled climate change scenarios to show that the flood risk for this site can be managed and therefore development will be acceptable. Residential development shouldn't be considered within the North East corner of the site, the site boundary has been amended to exclude that area identified as C2 fluvial >1/100.; no objection to remainder of site. Suitable. No development within the North East corner of the site. No objection from the Council’s Environment & Technical service. Suitable No known previous flooding, no main rivers issues. No objection from Environment Agency Wales or the Council’s Environment & Technical service. Suitable Yes No No No 17 Penmaenmawr Rhos-on-Sea Rhos on Sea Colwyn Bay Cwm Road, Penmaenmawr Dinerth Road, Rhos-on-Sea Dinerth Hall Farm, Rhos on Sea BT Exchange, Colwyn Bay 60 Dwellings 70 Dwellings 90 Dwellings 70 Dwellings TAN 15 Zone A. No objection from the Council’s Environment & Technical service. No known flooding history on site. There is a drain/watercourse running within the site. Suitable No known previous flooding. No comment from Environment Agency Wales. No objection from the Council’s Environment and Technical service. Suitable Part of the site (western extent) is within a TAN 15 flood risk zone C1; the western half of the site is in Environment Agency flood zone 3 – high risk, fluvial > 1/100. Half of the site is within the Afon Ganol flood zone. Flooding to fields on regular (1 in 1 year) basis. The Council’s Environment and Technical service suggest no development in the flood zone; no objection to remainder of the site. The Environment Agency Wales states that until a broad level Flood Consequences Assessment is done and accepted it is strongly advised not to allocate this site. Suitable. No development within the Afon Ganol flood zone. TAN 15 Flood Risk Zone A; Environment Agency flood zone 1 – low risk. No known previous flooding. No objection from the council’s Environment and Technical service EA flood zone 1 – low risk. TAN 15 Zone A; EA flood zone 1 – low risk. No No Yes Suitable No 18 Colwyn Bay Colwyn Bay Colwyn Bay Old Colwyn Llanrwst Lawson Road, Colwyn Bay (Colwyn Bay Masterplan Site) 35 Dwellings Douglas Road, Colwyn Bay (Colwyn Bay Masterplan Site) 20 Dwellings Lansdowne Road, Colwyn Bay (Colwyn Bay Masterplan Site) 30 Dwellings Ysgol y Graig, Old Colwyn 30 Dwellings Bryn Hyfryd/Ffordd Tan Yr Ysgol, Llanrwst 50 Dwellings TAN 15 Flood Risk Zone A; Environment Agency flood zone 1 – low risk. No objection from the Council’s Environment and Technical service and the Environment Agency Wales. Suitable TAN 15 Zone A. No objection from the Council’s Environment and Technical service and the Environment Agency Wales. Suitable No objection from the Council’s Environment and Technical service and the Environment Agency Wales Suitable No objection from the Council’s Environment and Technical service or the Environment Agency Wales Suitable TAN 15 Zone A. TAN 15 Flood Zone A. The site is partially within TAN 15 Flood Zone C2. Previously known problems downstream on unnamed watercourses in this area. Current situation is improved by connection to Afon Bach flood alleviation scheme. Flooding to Cae Craig and Y Berllan previously estimated at 1/5 year RP. No No No No Suitable. Sustainable Drainage will be recommended in the development brief No No objections but Sustainable Drainage would be important as surface run-off from this 19 area contributed to the flooding problems downstream. The Afon Bach scheme may not have fully solved the problems here as this was not the major aim of the scheme. Llanrwst Llanrwst North West of Llanrwst, Llanrwst Off the A470, Llanrwst 55 Dwellings 20 Dwellings The site was originally in C2 zone for TAN15 maps but updates to Environment Agency flood maps now show the site is outside the flood zone. No comment from Environment Agency Wales. The Council’s Environment and Technical service state that there are known flooding problems downstream on unnamed watercourse due to bank overtopping. No objections but Sustainable Drainage would be especially important. Suitable. Sustainable Drainage will be recommended in the development brief The Council’s Environment and Technical service state that the site was originally in C2 zone for TAN15 maps but updates to Environment Agency flood maps, following drainage improvement works in the area, now show the site is outside the flood zone. No objections but Sustainable Drainage would be especially important. No objection from Environment Agency Wales following revision to Llanrwst area flood risk maps – the site can be safely developed in line with TAN15 requirements. Suitable. Sustainable Drainage will be recommended in the development brief No No 20 Llanrwst East of Llanrwst, 25 Llanrwst Dwellings TAN 15 Zone A. Environment Agency Flood Zone 1 – low risk. Flood risk on land immediately adjacent to the river. Surface water disposal arrangements will need to be agreed to ensure that any future development at this location will not create flooding problems elsewhere. No objection from Environment Agency Wales or the Council’s Environment and Technical service Suitable. Surface water disposal arrangements will be implemented on site as detailed within the site development brief Mitigation Officer Comment No Rural Development Strategy Area- Housing Urban Settlement Site Allocation Flood Risk TAN 15 Justification Test Required Tier 1 Main Villages Glan Conwy Llanddulas Llanddulas Top Llan Road, Glan Conwy (Mixed-use housing and community facility) 80 Dwellings Pencoed Road, Llanddulas 20 Dwellings South of the Mill, Llanddulas 20 Dwellings TAN 15 Flood Zone No objection from the A; Council’s Environment & Technical service. Suitable. TAN 15 flood zone A No objection in principle from the Environment Agency Wales – no known history of flooding at this site Suitable. No objection in principle from the Environment Agency Wales – no known Suitable. TAN 15 flood zone A No No No 21 history of flooding at this site Llysfaen Llysfaen Ty Mawr, Llysfaen 255 Dwellings TAN 15 Flood Zone A No objection from Environment Agency Wales at application stage. Suitable. Ysgol Cynfran, Llysfaen 40 Dwellings TAN 15 Flood Zone A No known previous flooding. No objection from the Council’s Environment & Technical service. Suitable. Environment Agency flood zone 1 – low risk. Llysfaen Dwygyfylchi Dwygyfylchi Adjacent to former Rectory, Llysfaen 30 Dwellings Off Ysguborwen Road, Dwygyfylchi 15 Dwellings Adjacent to Vardre, Dwygyfylchi 20 Dwellings TAN 15 Flood Zone A TAN 15 flood zone A TAN 15 flood zone A. No No No objection from Environment Agency Wales or the Council’s Environment & Technical service. Suitable. No No objection from Environment Agency Wales or the Council’s Environmental & Technical service. Suitable. No No objection from Environment Agency Wales or the Council’s Environment & Technical service Suitable. No Tier 2 Main Villages Llanfair TH The Smithy, Llanfair TH 15 Dwellings TAN 15 Flood Zone A. There is a small section of Suitable. No C2 flood risk zone to be development will avoided to the east, take place adjoining the main river. adjoining the No objection from the main river, within Council’s Environment & the C2 flood No 22 Technical service. Eglwysbach Off Heol Martin, Eglwysbach 10 Dwellings The western half of the site is in TAN 15 Flood Zone C2. EA flood zone 3 – high risk (western half only); fluvial >1/100. Llansannan Llangernyw East of Aled View, Llansannan Coed Digain, Llangernyw 15 Dwellings 15 Dwellings TAN 15 Flood Zone A; Environment Agency flood zone 1 – low risk. TAN 15 Flood Zone A EA flood zone 1 – low risk. Cerrigydrudion Land Fronting B5105, 10 Dwellings TAN 15 Flood Zone A. In the absence of a broad level assessment that demonstrates consequences of flooding can be managed, the Environment Agency Wales objects to this site being allocated. There was flooding in 2004 affecting properties in the Heol Ffynnon area zone. Locate housing outside of the identified C2 flood zone Yes No known previous Suitable. Details flooding. No objection of surface water from the Council’s and foul drainage Environment and disposal will be Technical service. No included within objection in principle from the development the Environment Agency brief. Wales, subject to attenuated surface water and satisfactory foul drainage disposal No No known previous Suitable. Details flooding. No objection of surface water from the Council’s and foul drainage Environment and disposal will be Technical service. No included within objection in principle from the development the Environment Agency brief. Wales, subject to attenuated surface water and satisfactory foul drainage disposal No No objection in principle from the Environment No Suitable. Details of surface water 23 Cerrigydrudion Dolgarrog Tan Y Ffordd, Dolgarrog 30 Dwellings Agency Wales, subject to attenuated surface water and satisfactory foul drainage disposal. and foul drainage disposal will be included within the development brief. TAN 15 Flood Zone A. The Council’s Environment and Technical service states that the flood risk zone from the Afon Conwy is adjacent to the eastern site boundary. The Environment Agency Wales state that the site is on the boundary of the C1 flood risk zone. There is an element of fluvial flooding associated with the area. Prior to allocating in the LDP, a broad scale assessment of flood risk should be carried out to ensure that the allocation is acceptable. Suitable. Development will be avoided immediately adjacent to the C1 flood risk area No Dolgarrog Gwydr Road, Dolgarrog 10 Dwellings TAN 15 Flood Zone A No issues. Betws yn Rhos Ffordd Llanelwy, 5 Betws yn Rhos Dwellings TAN 15 Flood Zone A; Environment Agency flood zone 1 – low risk. No known previous Suitable. Details flooding on site. No of surface water objection in principle from and foul drainage the Council’s Environment disposal will be & Technical service. No included within objection in principle from the development the Environment Agency brief. Wales, subject to attenuated surface water and satisfactory foul drainage disposal. No EA Wales are not aware of any known history of No Betws yn Rhos Minafon, Betws 5 TAN 15 Flood Zone A; Environment Suitable. Suitable. No 24 yn Rhos Dwellings Agency (EA) flood zone 1 – low risk. flooding. No objection from Environment Agency Wales and the Council’s Environment & Technical service. Application of TAN 15 Justification Test - Housing Site Flood Risk Social Club/Youth Club, Llandudno Junction The site is split between TAN 15 Flood Zones A and C2. Plas yn Dre, Llandudno TAN 15 Flood Zone C1. Off Heol Martin, Eglwysbach The western half of the site is in TAN 15 Flood Zone C2. TAN 15 6.2 i D D D TAN 15 6.2 ii TAN 15 6.2 iii TAN 15 6.2 iv U U D D U U D D D 25 Social Club Llandudno Junction The Social Club in Llandudno Junction is the only housing allocation on which development within the C2 zone cannot be avoided. To understand the consequences of flooding on this site, and to ensure the necessary mitigation measures can be implemented in order to manage the risks of flooding sustainably the following modelling data has been assessed. EA flood maps show medium risk in yellow and high risk in red. For river flooding medium risk is greater than 0.1% chance per year (1 in 1000 year return period) and high risk is greater than 1% chance per year (1 in 100 year return period). This is based on the natural floodplain extent with no defences being in place. A red line denotes an EA main river. The easterly section of this site is within TAN 15 flood risk zone C2 and although the EA have suggested the proposals would satisfy TAN 15 requirements, the extreme event (0.1% annual probability flood) should also be considered. The raising of floor levels above the 1% AEP (1 in 100 year) fluvial flood level will ensure that the damage to property is minimised. This is likely to result in floor levels being be situated a minimum of 300mm above the 1% AEP (1 in 100 year) plus climate change flood level, or 600mm above the 1% AEP (1 in 100 year) flood level if no climate change data is available. The height that the floor level is raised above flood level is referred to as the ‘freeboard’, and is determined as a measure of the residual risks at this location. . 26 Social Club Llandudno Junction 27 Plas Yn Dre Llandudno The Plas Yn Dre site in Llandudno is the only housing allocation on which development within the C1 flood zone cannot be entirely avoided. To understand the consequences of flooding on this site, and to ensure the necessary mitigation measures can be implemented in order to manage the risks of flooding sustainably the following modelling data has been assessed. The Environment Agency have advised that the Conwy Tidal Flood Risk Assessment climate change modelling data indicates that the Plas Yn Dre site would have a probability of flooding of between 0.001 – 0.005. This indicates that for the lifetime of the development the site would be flood free for the 0.5% event but may be affected in future years during the 0.1%. As the site would be flood free for the 0.5% event, the Environment Agency would not oppose the allocation of this site. However, appropriate flood mitigation measures e.g. raising of floor levels above pavement level 300-450mm, and/or flood resilient construction techniques, would be necessary to ensure that flood risk can be managed acceptably. 28 abcde N Environment ¿ Probabilities of having any flood depth 1 EM CL 11 EN U EN AV 5 Flood return period 18 T 34 Less than 1 in 1000 years 1 in 200 to 1 in 1000 years 1 in 100 to 1 in 200 years 1 in 10 to 1 in 100 years Ash Hotel E Dunoon 8 EN 13 EM CL t en em Cl dge Lo Lansdowne Hotel Hotel T AG SS 9 PA 8.4m E 15 3 HI W O ST N A SS PA G E 5.6m 1 R YO Ormside Grange K A RO 5 D 6 G s-y Pla - dr D LO H ET DA ET RE ST e 34 21 29 2 LB 29 1 UR Car Park Y RO DE AD N 28 GA A 23 24 Y W E 26 34 28 U a N VE B TC 5.3m 27 25 31 Sea Court Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 Loretta DO NOT SCALE Plas Yn Dre Llandudno 29 abcde Environment N Probabilities of having any flood depth Adjusted for 50 years climate change ¿ 1 EM CL 11 EN Any Flood Depth A 5 T 18 UE Hotel Cl Lansdowne Hotel 0 to 1/1000 (436) 1/1000 to 1/200 (323) 1/100 to 1/10 (168) Ash N VE 34 t en em ge d Lo EN 8 EM CL 13 Dunoon Hotel T AG SS 9 PA 8.4m E 15 3 W H IS TO N A SS PA G E 5.6m 1 R YO Ormside Grange K A RO 5 D 6 G Pla s-y D LO DA H ET RE ST ET dr e 34 21 29 2 LB 29 1 BU Car Park RY RO DE AD N 28 GA Y W N VE 23 24 A B TC E 28 a U 26 34 5.3m 27 25 31 Sea Court Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 Loretta DO NOT SCALE Plas Yn Dre Llandudno 30 abcde Environment N Probabilities of having flood depth >= 600mm Adjusted for 50 years climate change ¿ 1 EM CL 11 FD_600mm_or_more U EN AV 5 T EN 18 34 0 to 1/1000 (647) 1/1000 to 1/200 (278) 1/200 to 1/100 (1) 1/100 to 1/10 (44) Ash Hotel E E CL t en em Cl dge Lo Lansdowne Hotel EN 8 M 13 Dunoon Hotel T AG SS 9 PA 8.4m E 15 3 W H TO IS N AG SS PA E 5.6m 1 R YO Ormside Grange K A RO 5 D 6 G Pla D LO H ET DA RE ST ET e - dr s-y 34 21 29 2 LB 29 1 UR SB Car Park Y RO DE AD N 28 GA Y W N VE 23 24 A B TC E 28 a U 26 34 5.3m 27 25 31 Sea Court Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 Loretta DO NOT SCALE Plas Yn Dre Llandudno 31 Off Heol Martin Eglwysbach The housing site located off Heol Martin, Eglwysbach is partially with a C2 flood risk zone. To understand the consequences of flooding on this site, and to ensure the necessary mitigation measures can be implemented in order to manage the risks of flooding sustainably the following modelling data has been assessed. EA flood maps show medium risk in yellow and high risk in red. For river flooding medium risk is greater than 0.1% chance per year (1 in 1000 year return period) and high risk is greater than 1% chance per year (1 in 100 year return period). This is based on the natural floodplain extent with no defences being in place. Development on this site will be located within the area of the site which is outside of the designated flood risk zone. However, the site is subject to a medium and partially high risk of surface water flooding. Mitigation measures including land raising will be implemented on site to overcome these issues. Sustainable Urban Drainage systems (SUDs), via infiltration or attenuation, will also be necessary on site to ensure that any increase in surface water flooding does not runoff into the river and cause flooding elsewhere (as advised in TAN15, Section 8). Through these mitigation measures it is considered that the risk of flooding can be sustainably managed on this site to enable development. The consideration of soil type at pre-planning application stage will provide an indication of the suitability for the type of SUDs to be implemented on site. It should be stressed that whilst the permeability of the soil is an important consideration for infiltration techniques at this location, some SUDS techniques can be used on impermeable soils and could help aid attenuation by reducing conveyance time. 32 Surface Water Flooding Map The Environment Agency surface water maps show low flood risk in sky blue, medium risk in pink and high risk in blue. The raindrop symbol on the river downstream is where a flood feasibility study has been recently carried out due to known flood risk from the river. 33 Site off Heol Martin Eglwysbach 34 Surface Water Flooding Heol Martin Eglwysbach 35 Employment Sites Employment and general industrial development is classified in TAN 15 as less vulnerable development; however it will only be permitted within C flood zones where it can be justified. As detailed within TAN 15, less vulnerable development such as general industrial types may be justified within C1 and C2 flood zones where it is necessary to contribute towards achieving key employment objectives and sustaining existing settlements. The following series of tables indicate the location of proposed employment sites and their vulnerability to flooding. The tables will also justify developments which fall within flood risk areas and detail the mitigation measures in place to overcome any identified risks. The Goods Yard site in Llandudno is the employment allocation on which development within the C2 zone cannot be avoided. However, the Environment Agency has indicated that the proposed development would satisfy TAN 15 requirements. 36 Urban Development Strategy Area – Employment Urban Settlement Site Strategic Hub location - Llandudno Junction North East 0.4 Hectares of Former of B1 Goods Employment Yard, Llandudno The former Goods Yard Allocation 1.4 Hectares of B1 Employment Flood Risk Mitigation Officer Comment The eastern corner of the site (approximately 0.05 ha) is within a C2 flood risk zone where only less vulnerable development, as defined in TAN 15 , would be permitted. The Council’s Environment and Technical service state that the completed Flood Consequences Assessment for the Brickworks site to the south may suffice for this site. The Environment Agency Wales envisage that the flood risk to this site could be managed to an acceptable level and meet TAN 15 requirements since the main flood risk is from the Afon Wydden which has a flood alleviation scheme in place. Suitable. Development on this site is deemed suitable in line with EA comments The site is within a C2 flood risk zone as defined by TAN 15. It is in the Environment Agency’s Flood Zone 3 which means a high risk tidal flooding, over 1/200. The Llandudno defences have a maintained shingle bank with the promenade and rear wall which is at risk of overtopping in extreme storm and tidal events. The Council’s Environment and Technical Service state that the south east third of the site fails TAN 15 criteria according to the Conwy Tidal Flood Risk Assessment, however, the remainder of the site passes subject to a Flood Consequences Assessment. The Environment Agency Wales also suggest that no buildings or structures be erected in the southern part of the site. Suitable. No development within the Southern part of the site. TAN 15 Justification test required No Yes 37 Rural Development Strategy Area– Employment Urban Settlement Site Allocation Tier 1 Main Village, Land at Orme View Filling Station, Dwygyfylchi Tier 2 Main Village, Flood Risk Mitigation Officer comments 2.7 Hectares Part of the site is of B1/B2/B8 located in a TAN Employment 15 Flood Zone C2 (directly adjacent to the watercourse on the boundary); the same area is Environment Agency flood zone 3 – high risk (eastern site boundary – 30 to 40m) fluvial >1/100 year RP. There is known previous flood risk from the Afon Gyrach. The Council’s Environment and Technical service states that less vulnerable development in the C2 zone is subject to justification tests (see TAN 15). They have no objection to the remainder of the site. The Environment Agency Wales states that flood risk is an issue which needs addressing both for current day risk and future risks associated with climate change. Therefore a Flood Consequence Assessment will need to be carried out to determine what will be acceptable with regards to allocating the site for employment purposes. Obviously development would be restricted adjacent to the watercourse. However, with sea level rises, parts of the site adjacent to the A55 may also be at risk of flooding. The Allocated site is outside the C2 Flood zone (contingency site is in C2 zone) Land at 0.3 Hectares There is a degree Memorial Hall, of BI/B2 of flood risk Dolgarrog Employment associated with this site and it is reflected in the fact that part of the existing memorial hall is The Environment Agency Wales suggest that the flood risk needs to be investigated further to fully understand the risks associated with the proposal. The additional work should concentrate on the channel capacity of the Afon Porthlwyd for a range of flood events (up Suitable. The development will be in the form of a conversion rather than Tan 15 justification test required No No 38 within the development advice map zone C2 as per TAN 15 Tier 2 Main Village, Land at Llansannan 1.2 Hectares TAN 15 flood of B1/B2 zone A Employment EA flood zone 1 – low risk. to the 0.1% AEP). This will then enable the authority to determine if the flood risk is acceptable or requires to be managed in the form of flood mitigation measures etc. No objection from the Council’s Environment and Technical Service to the remainder of the site. anew build. No known history of flooding at this site. No objection from the Council’s Environment and Technical service. Although there are no constraints affecting this site, the Environment Agency Wales state that it is not within a sewered area. There is a sewered area not very distant from the site so connection may be possible. The EAW recommend that a connection to the mains should be made if at all possible and recommend consultation with the sewerage undertaker to discuss if this is a possibility prior to allocation. If not possible and a private means must be provided, there will be a requirement to obtain the necessary Environmental Permits from EAW before any discharges are made. Suitable. Suitable. Tier 2 Main Village, Site R44 Llangernyw 0.3 Hectares Flood Risk: TAN of BI/B2 15 flood risk zone Employment A No objection from Environment Agency Wales or the Council’s Environmental & Technical service. Tier 2 Main Village, Land at Scout Hut, 0.3 Hectares of The Environment Agency Wales identified no constraints on site. TAN 15 flood zone A. No No Suitable. Sustainable No 39 Tier 2 Main Village, Llansannan BI/B2 Employment Surface water disposal should be Drainage will designed with consideration given be to the suitability of Sustainable recommende Urban Drainage System (SUDS) for d in the the disposal and attenuation of development surface waters. If SUDS are shown brief to work for the site, and subject to the appropriate agreements being in place with regard to adoption, this system should be implemented for the site allocation. Land off the B1505, Cerrigdrudion 1.2 Hectares TAN 15 Flood of BI/B2 Zone A Employment EA flood zone 1 – low risk. No known previous flooding. No objection from the Environment Agency Wales or the Council’s Environment & Technical service. The environment Agency Wales states that there is an ordinary watercourse running through the site. It is emphasised that the EAW resists culverting on conservation and other grounds, and consents for such works will not normally be granted except for access crossings. This site is also outside a sewered catchment area and so consideration should be given to the method for foul drainage disposal. EAW also recommend consultation with the sewerage undertaker to see if connection to the mains system nearby would be possible. Suitable. Details of surface water and foul drainage disposal will be included within the development brief. No 40 Application of TAN 15 Justification Test - Employment Site Flood Risk The former Goods Yard, Llandudno The site is within a C2 flood risk zone as defined by TAN 15 Land at Memorial Hall, Dolgarrog There is a degree of flood risk associated with this site and it is reflected in the fact that part of the existing memorial hall is within the development advice map zone C2 as per TAN 15 (Conversion) TAN 15 6.2 i TAN 15 6.2 ii TAN 15 6.2 iii TAN 15 6.2 iv D D D D D D D D 41 Goods Yard Llandudno The Llandudno Goods Yard site is the only employment allocation located within a C2 flood risk zone. The Southern part of the site fails TAN 15 according to the Conwy Tidal Flood Risk Assessment; however the Council’s Environment and Technical Service state that the remainder of the site would be acceptable in line with the TAN. The Environment Agency Wales also suggest that no buildings or structures be erected in the southern part of the site. The following series of flood models indicate that the risk and consequences of flooding on the site can be sustainably managed. The Conwy Tidal Flood Risk Assessment indicates that the Goods Yard Llandudno site would have a 1 in 200 to 1 in 1000 probability of flooding. The Southern part of the site has a 0 to 1/1000 probability of flooding to a depth of 600mm or more, therefore development will be avoided on this part of the site in line with the recommendations of the Environment Agency. 42 abcde N Environment ¿ 2 RO AD 6 2 Y 8 A L od 1 3 18 PH 32 5 T EE 1 8a VA 5 9 4 1 8b UG N HA R ST T EE The M os ty n Ga ll e ry 5 R ST 34 ge 7 h an 19 1 NW ce Pla Less than 1 in 1000 years 1 in 200 to 1 in 1000 years 1 in 100 to 1 in 200 years 1 in 10 to 1 in 100 years rt 30 CO u gh 32 oro Flood return period 11 Offi c e ou Va ug 7 12 13 C E NU VE YA He ad Po s t 4 .5 m N IO INIT TR LB TCBs 4 .8 m ds 4 .9m B AL 41 Ev a ns Hote l ET i fre e RE ST Win St ntr Ce ON yl l h Ga ra ge LT AR Arg ut Yo CH CK Sta no e BA 23 El b Su L al d n du ss Pa s ta ag to 29 gu Au 31 29 Ty J u s ti n 6 8 2 G T 1 20 10 EE TR arlb DS WAR M ED 25 43 12 1 Probabilities of having any flood depth 3 ou nH W 5 se O EH AR 4 1 40 15 LB io Alb 6 E US 10 Ha v e l oc k Cottag es 3b TCB Dep ot 39 2 36 43 1 ST ST 25 2 1 TCB N OH .J 'S PL E AC Gara ge G AG AR E ST ET RE Gara ge 46 Pos t Th Ort e C h o Ch o do p ti c u rc x h TA Cen tre T EE TR Work s 1 to 7 3 1 S O Llandudno Station AR 29 t AD 16 OA D Cl i ni c El Su b Sta Pol i c e Stati on f 24 lo a pe st Ch Re 3 8 AV R t en nm v er e s Go Off ic Y 37 IT IN E TH TR U EN LL GY RO eC D ile 8 OR XF EE J ub JU BIL 2 32 14 OR P RE ST ET Tel ep ho ne Ex c h an ge M ag is tra tes ' Cou rt Ox ford Hou s e 28 1 17 8 5 Po s t 16 PA SS AG E N / RT u Cl b OR XF D CR O Y ST U MO C O N R GE T Y RO OS M T R R CW GE RO 1 Ysgol Tudno 8 EE BIL JU El Sub Sta RO AD 41 LLAND 10 25 N R NT LO CE Wo rk s E DO 3 15 BIN N,S SO 5 15 12 13 29 10 5 33 1 1 SB SP M P3 V DA S' IE W H AY AR OW D RO AD 25 5 5 Dep ot 27 IL E BU G SA try Sta S PA an Sub S' lG T EE IE 7 na Sig R ST V DA 12 Work s R El 26 15 10 DE AD 1 RO E AN N 3 M OR 31 2 Cen tra l Hou s e N 11 LA El Su b Sta 1 rt a l Un Pal its ce 20 19 33 HM Coa s tgu ard Res c u e Equ i pm e nt 16 Ce n AN 13 1 H AC PL 47 M OR 19 C FA AL 45 Wa reh ou s e N AY W 9 39 ED y Bd LB Sup ers to re 20 El Sub Sta 19 14 3 Work s 1 15 5 CA E 1 CIL S T EE TR W 21 T ES er a th He ra e B H AR OW D AC PL E Depot O FF Mast P R EN N HY 'S 7 14 M C R CE ON CW LA Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De po t 14 15 16 6 12 Fa c tory 8 D RD 13 CO UN 8 H Dia m o nd Hou s e 6 C BA Work s Boa s e Ya rd DO NOT SCALE Goods Yard Llandudno 43 abcde N Environment ¿ 2 6 AD 2 8 RO ds 1 rt h an 3 19 18 ge PH 32 5 T EE 1 8a VA 5 9 4 1 8b UG N HA R ST T EE The M o s ty n Ga ll e ry 5 R ST 7 34 L od 7 Va ug UE EN 1 Y ce Pla ifre 0 to 1/1000 1/1000 to 1/200 1/200 to 1/100 1/100 to 1/10 Offic e ou 30 Depth 600mm or More 11 A u gh Hea d Pos t C V YA 13 NW 4.8 m CO ET 32 RE ST oro ON to LT AR Win St CH 4.5 m N IO INIT TR 12 Gara ge yl l 4 .9m B AL 41 e CK e ntr Ce ag Arg o uth oY ss BA 23 ta bS El Su L al dn n du Pa s ta LB TCBs 1 29 gu Au Ev an s Ho te l arlb 6 31 29 Ty J u s ti n 8 2 G T M 20 10 EE TR 25 ED DS WAR 12 1 Probabilities of having flood depth of 600 mm or greater 43 3 ou nH W 5 se O EH AR 4 1 40 15 LB io Alb 6 E US 10 Hav el o c k Co tta ge s 3b TCB Dep o t 39 2 36 43 1 ST ST 25 2 1 TCB . HN JO 'S PL E AC Ga ra g e G AG AR E ST ET RE Ga rag e 46 Po s t Th Ort e C h o Ch o do p ti c u rc x h TA Ce n tre T EE TR Wo rk s 1 to 7 3 1 S OR XF Llandudno Station AR 29 t AD 16 24 f lo a pe st Ch Re OA D Cl in i c El Su b Sta Po li c e Sta ti o n 3 8 AV R t en nm v er e s Go Off ic Y 37 IT IN E TH TR U EN LL GY RO eC D ile 8 EE BIL J ub JU O 14 2 32 OR P RE ST ET Tel e ph on e Ex c ha ng e M a gi s tra tes ' Co u rt Ox ford Ho us e 28 1 17 Pos t 5 8 16 PA SS AG E / N Y RT ST OU MO C R YN GE ST RO M O T R ER CW O G R 1 Clu b OR XF D CR O Ysgol Tudno 8 EE BIL JU El Sub Sta RO AD 41 LLAND 10 25 N R NT LO CE Work s E AY 20 19 3 15 BIN N,S SO 5 15 1 12 10 5 5 5 33 1 1 SB SP M P3 V DA IE W S' H AY OW AR D RO AD 25 Dep ot 27 DE IL E BU G SA try S PA an T EE S' lG Sta 29 7 na Sig VIE DA 12 Wo rk s R ST S ub El 26 15 10 R AD E N RO N 3 13 11 AN 31 2 Cen tra l Ho us e M OR LA El Su b Sta 1 tra l Un Pal its ce W DO 16 Ce n AN 33 M OR 13 1 H AC PL 47 N 19 C FA AL 45 Ware ho us e HM Coa s tg u ard Res c ue Eq ui p m e nt 9 39 ED Bd y LB Su pe rs to re 20 El Sub Sta 19 14 3 Work s 1 15 5 CA E 1 UN T EE TR 21 T ES W er a th He ra e B H AR OW D AC PL E Depot O FF Mas t P R EN N HY ON 'S C 14 R CE M CW LA 7 Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De po t 14 15 16 6 12 Fac tory 8 D RD 13 CO S 8 H Di a m o nd Ho us e CIL 6 C BA Wo rk s Bo as e Yard DO NOT SCALE Goods Yard Llandudno 44 abcde N Environment ¿ Probabilities of having Flood Velocity of 0.15 m/sec or more 6 2 Ty J us ti n RO AD 2 Y 8 A ds 1 C ou L od 3 19 18 ge PH 32 5 T EE VA 1 8b UG N HA R ST T EE Th e M o s ty n Ga l le ry 34 5 5 R ST 0 to 1/1000 1/1000 to 1/200 1/200 to 1/100 1/100 to 1/10 7 h an 8 rt Va ug 1 8a 9 4 V=0.15m/sec or More 11 Po s t Offi c e yl l 1 NW ce Pla He ad ifre Arg 30 CO 4 .8 m gh ON 32 LT AR u oro CH Win Ga rag e 7 12 e E N IO 41 ag 13 4 .5 m B AL TR NU VE YA ss LB TCBs St ta 4 .9 m INIT Pa CK bS u nd Yo s ta BA 23 El Su L al o dn ntre Ce ut h 29 Ev a n s Ho te l ET to 29 gu Au 31 RE ST 1 6 arlb 20 T 12 EE TR M ED DS WAR 25 43 3 ou nH 36 40 5 W se O EH AR 4 1 15 LB io Alb 6 E US 10 Ha v e l oc k Co ttag e s 3b TCB De p o t 39 2 43 1 ST . ST 25 2 1 TCB HN JO 'S A PL CE Ga ra g e G AG AR E ST ET RE Ga ra ge 46 Pos t Th Ort e C o h Ch o do p ti c u rc x h TA Ce n tre Wo rk s 1 to 7 3 T EE TR O 1 S AR 29 t AD 16 D Cl i n i c El Su b Sta Po l i c e Sta ti o n of l a pe st Ch Re 24 AV OA t en nm v er e s Go ff ic O 3 8 Y 37 IT IN E R TH TR U EN LL GY RO eC D ile 8 OR XF Llandudno Station J ub JU EE BIL 2 32 14 OR P RE ST ET Te l e p h o ne Ex c h a n ge M a g i s tra te s ' Co u rt Ox fo rd Ho u s e 28 1 17 8 5 Pos t 16 PA SS AG E / N Y RT STOU MO C R YN GE ST RO O T M R ER CWO G R 1 Clu b OR XF D CR O Ysgol Tudno 8 EE BIL JU El Su b Sta RO AD 41 LLAND 10 25 N R NT LO CE Work s E AN W AY 20 13 1 H AC PL 47 19 33 M OR 19 C FA AL 45 3 N DO 15 5 RO 10 5 De p o t 5 33 1 1 SB SP M P3 S' VIE DA W H AY OW AR D RO AD 25 BU 5 try Sta 27 an T EE E lG Sub 29 7 na Sig R ST AG SS PA S' VIE DA 12 Wo rk s R El 26 15 10 DE IL AD 1 12 AN E M OR N LA 3 13 Ce n tra l Hou s e N 11 31 2 tra lP Un al ce i ts N,S SO 15 El Su b Sta 1 Ce n BIN HM Co as tg u a rd Re s c u e Eq ui p m e n t 16 Wa re h o u s e 9 39 ED y Bd LB Su p e rs to re 20 El Su b Sta 19 14 3 Wo rk s 1 15 5 CA E 1 UN CIL 21 T ES W er a th He ra e B H OW AR D AC PL E Depot O FF M as t D RD P R EN N HY 13 CO T EE TR 8 H Di a m o n d Ho u s e S 6 C BA Wo rk s Bo as e Ya rd ON 7 14 M 'S CW E Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De p o t Fa c to ry 14 15 16 6 12 DO NOT SCALE Goods Yard Llandudno 45 abcde N Environmental Services ¿ 2 RO AD 6 2 Y 8 A ce P la d ifre 0 to 1/1000 1/1000 to 1/200 1/200 to 1/100 1/100 to 1/10 s Offi c e 1 rt ug h an 3 19 18 ge PH 32 5 T EE 1 8a VA 5 9 4 1 8b UG N HA R ST T EE Th e M o s ty n Ga l l e ry 5 R ST 7 34 L od 7 Va E 1 RR=0.1m\hr or More 11 Po s t ou 30 NW gh He a d C NU VE YA CO 4 .8 m 32 ON u oro LT AR to CH 13 4 .5 m N IO IT IN TR 12 Ga ra ge LB TCBs Win St 4 .9 m B AL 41 e yl l dn ag Arg n du ss CK Sta L al o uth oY Pa ta BA 23 El b Su 31 s gu Ev a ns Ho te l ET 1 29 Au RE ST arlb 6 ntre Ce 29 Ty J u s tin 8 2 G T M 20 10 EE TR 25 ED DS WAR 12 1 Probabilities of having Rate of Rise of 0.1 m\hr or more 43 3 LB W se O EH AR u Ho 5 on 4 1 40 15 TCB bi Al 6 E US 10 Ha v el o c k Co tta g e s 3b Dep o t 39 2 36 43 1 ST .J ST 25 2 1 TCB N OH 'S E AC PL Gara g e G AG AR E ST ET RE Ga ra g e 46 Po s t Th Ort e C h o Ch o do p ti c u rc x h TA Ce n tre Wo rk s 1 to 7 3 T EE TR O 1 S AR 29 t AD 16 OA D Cl i n i c El Su b Sta Pol i c e Stati o n f 24 lo a pe st Ch Re 3 8 AV R t en nm v er e s Go Off ic Y 37 IT IN E TH TR U EN LL GY RO eC D ile 8 OR XF Llandudno Station J ub JU EE BIL 2 32 14 OR P RE ST ET Te l ep h o n e Ex c h a n g e M a g i s trate s ' Co u rt Ox fo rd Ho u s e 28 1 17 8 5 Po s t 16 PA SS AG E / N Y RT ST OU MO C R YN GE ST RO M O T R ER CW O G R 1 Clu b O OR XF D Ysgol Tudno CR 8 EE BIL JU El Su b Sta RO AD 41 LLAND 10 25 N R NT LO CE Wo rk s E AY 20 19 DO 3 15 BIN N,S SO 5 15 RO 10 5 De p o t 5 1 1 SB M P3 S' VIE DA W H AY AR OW D RO AD 25 5 IL 33 BU SP Sta 27 an T EE E lG R ST Sub 29 7 na Sig R AG SS PA S' VIE DA 12 Wo rk s DE El 26 15 10 try AD 1 12 AN E 3 13 M OR 31 2 Ce n tra l Ho u s e N 11 N LA El Su b Sta 1 tra l Un Pal its ce W 33 HM Co a s tgu a rd Re s c u e Eq u i p m e n t 16 Ce n AN 13 1 H AC PL 47 M OR 19 C FA AL 45 Wa re h ou s e N 9 39 ED Bd y LB Su p e rs tore 20 El Sub Sta 19 14 3 Work s 1 15 5 CA E 1 UN S T EE TR 21 T ES W er a th He ra e B H AR OW D AC PL E Depot O FF M as t P R EN N HY 'S 14 M C R CE ON CW LA 7 Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De p o t 14 15 16 6 12 Fa c to ry 8 D RD 13 CO CIL 8 H Di a m o n d Ho u s e 6 C BA Wo rk s Bo a s e Ya rd DO NOT SCALE Goods Yard Llandudno 46 abcde N Environment ¿ 2 6 8 AD ifre 2 RO ce Pla Win 0 to 1/1000 1/1000 to 1/200 1/200 to 1/100 1/100 to 1/10 ds Offi c e 1 rt h an 3 18 ge PH 32 5 T EE 1 8a VA 5 9 4 1 8b UG N HA R ST T EE Th e M o s ty n Ga l le ry 5 R ST 7 34 L od 7 Va ug 19 1 Y u gh SI up to 4 hrs 11 Pos t ou E NU VE YA Hea d 13 A NW 4.8 m C 30 ET CO RE ST 32 ON oro LT AR to CH 4.5m N IO INIT TR 12 Ga ra g e yl l 4 .9 m B AL 41 e St re ag Arg nt Ce ss CK Sta th ou oY Pa s ta BA 23 El b Su L al n ud nd gu LB TCBs 1 29 Au Ev a ns Ho te l arlb 6 31 29 Ty J us ti n 8 2 G T M 20 10 EE TR 25 ED DS WAR 12 1 Probabilities for Speed of Inundation up to 4 hours 43 3 LB ou nH W 5 se O EH AR 4 io Alb 6 10 E US Ha v e lo c k Co ttag es 1 40 15 TCB 3b De po t 39 2 36 43 1 ST ST 25 2 1 TCB . HN JO 'S PL E AC Ga rag e G AG AR E ST ET RE Ga rag e 46 Po s t Th Ort e C h o Ch o do p ti c u rc x h TA Ce ntre Work s 1 to 7 3 T EE TR O 1 S AR 29 t AD 16 24 f lo a pe st Ch Re OA D Cl in i c El Su b Sta Po l ic e Sta tio n 3 8 AV R nt me rn es ve Go Offic Y 37 IT IN E TH TR U EN LL GY RO eC D ile 8 OR XF Llandudno Station J ub JU EE BIL 2 32 14 OR P RE ST ET Te le p ho ne Ex c h an ge M ag i s trates ' Co urt Ox ford Hou s e 28 1 17 Po s t 5 8 16 PA SS AG E / N Y RT ST OU MO C R YN GE ST RO M O T R ER CW O G R 1 Clu b OR XF D CR O Ysgol Tudno 8 EE BIL JU El Su b Sta RO AD 41 LLAND 10 25 N R NT LO CE Work s E 20 19 3 15 BIN N,S SO 5 15 10 5 5 5 33 1 1 SB SP M P3 VIE DA S' W H AY OW AR D RO AD 25 Dep ot 27 DE IL E BU AG SS try PA an T EE S' lG Sta 29 7 na Sig VIE DA 12 Wo rk s R ST Sub El 26 15 10 R AD 1 12 13 N RO E 3 11 AN 31 2 Cen tra l Hou s e M OR N LA El Sub Sta 1 rt a l Un Pal its ce AY W DO 16 Ce n AN 33 M OR 13 1 H AC PL 47 N 19 C FA AL 45 Wa reh ou s e HM Coa s tgu a rd Res c u e Equ i pm e n t 9 39 ED y Bd LB Su pe rs tore 20 El Su b Sta 19 14 3 Wo rk s 1 15 5 CA E 1 UN S T EE TR W 21 T ES er a th He ra e B H OW AR D AC PL E Depot O FF Mast P R EN N HY ON 'S C 14 R CE M CW LA 7 Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De po t 14 15 16 6 12 Fa c tory 8 D RD 13 CO CIL 8 H Di a m o nd Hou s e 6 C BA Wo rk s Boa s e Ya rd DO NOT SCALE Goods Yard Llandudno 47 abcde Environment N RO AD 6 ifre 2 Y ds 1 rt h an 3 19 18 ge PH 32 5 T EE 1 8a VA 5 9 4 1 8b UG N HA R ST T EE Th e M o s ty n Ga l le ry 5 R ST 7 34 L od 7 ug 8 2 8 A e Win 0 to 1/1000 (436) 1/1000 to 1/200 (323) 1/100 to 1/10 (168) Offic e ou 1 NW Any Flood Depth 11 Po s t C Va N IO 30 13 ac Pl He a d 4 .5 m B AL E NU VE YA CO 4 .8 m gh ON 32 LT AR u oro CH St Ga ra g e LB TCBs to e CK 4 .9 m INIT TR 12 ag yl l d ss Arg n du o Pa s ta BA 23 ta bS El Su L al Y no gu Ev a n s Ho te l ET 1 29 Au 31 41 RE ST 6 ntre Ce ut h ¿ 29 Ty J u s tin b arl 20 2 12 Ga T 10 EE TR M ED DS WAR 25 43 1 Probabilities of having any flood depth Adjusted for 50 years climate change 3 LB W 5 ou nH se O EH AR 4 io Alb 6 10 E US Ha v e lo c k Co tta g e s 1 40 15 TCB 3b De p o t 39 2 36 43 1 ST ST 25 2 1 TCB .J N OH 'S PL E AC Ga ra g e G AG AR E ST ET RE Ga ra g e 46 Po s t Th Ort e C h o Ch o do p ti c u rc x h TA Ce n tre Wo rk s 1 to 7 3 T EE TR O 1 S AR 29 t AD 16 24 l a pe st Ch Re 3 8 AV OA D Cl in i c El Su b Sta t en nm v er e s Go Off ic Y 37 IT IN E R Po li c e Sta ti o n of TH TR U EN LL GY RO eC D ile 8 OR XF Llandudno Station J ub JU EE BIL 2 32 14 OR P RE ST ET Te l e p h o n e Ex c h a n g e M a g i s tra te s ' Co u rt Ox fo rd Ho u s e 28 1 17 8 5 Po s t 16 PA SS / N Y RT OU AG E ST MO C R YN GE ST RO M O T R ER CW O G R 1 Clu b OR XF D CR O Ysgol Tudno 8 EE BIL JU El Su b Sta RO AD 41 LLAND 10 25 AY 20 19 3 15 BIN N,S SO 5 15 10 5 5 De p o t 5 1 1 SB SP M P3 VIE DA W S' H AY D AR OW RO AD 25 IL 33 BU Sta 27 try E an T EE AG SS PA lG Sub 29 7 na Sig R ST S' VIE DA 12 Wo rk s R El 26 15 10 DE AD 1 12 N RO E 3 13 11 AN 31 2 Ce n tra l Ho u s e M OR N LA El Su b Sta 1 tra l Un Pal its ce W DO HM Co a s tg u a rd Re s c u e Eq u ip m e n t 16 Ce n AN 33 M OR 13 1 H E 47 Wa re h o u s e N 19 C FA AC PL 45 AL N R NT LO CE Wo rk s 9 39 ED y Bd LB Su p e rs to re 20 El Su b Sta 19 14 3 Wo rk s 1 15 5 CA E 1 UN T EE TR W 21 T ES er a th He ra e B H AR OW D AC PL E Depot O FF M as t P R EN N HY ON 'S C 7 14 R CE M CW LA Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De p o t 14 15 16 6 12 Fa c to ry 8 D RD 13 CO S 8 H Di a m o n d Ho u s e CIL 6 C BA Wo rk s Bo a s e Ya rd DO NOT SCALE Goods Yard Llandudno 48 abcde Environment N 2 6 2 AD 8 1 h an L od 18 PH 5 T EE 1 8a VA 1 8b 5 9 4 UG N HA R ST T EE Th e M os ty n Gal l ery 5 R ST 34 ge 7 3 1 RO ds ug 19 30 Y ce Pla 0 to 1/1000 (647) 1/1000 to 1/200 (278) 1/200 to 1/100 (1) 1/100 to 1/10 (44) Offic e rt Va 7 3 43 se ST ST TCB 4 10 1 25 2 1 US E 6 46 5 ou nH AR EH O 1 40 15 LB io Alb W Hav el oc k Cottag es 3b TCB De po t 39 2 36 A u gh FD_600mm_or_more 11 Pos t ou E NU VE YA Hea d 13 NW 4.8m C 32 ET CO RE ST 32 ON oro LT AR 4.5 m N IO INIT TR 12 CH i fre 4.9m B AL 41 Garag e Win St ntre Ce e yl l h ag Arg ut Yo ss CK ta no Pa BA 23 bS El Su L al d n du s ta LB TCBs to 29 gu Au Ev a ns Hotel 1 6 31 ¿ 29 Ty J us ti n 8 2 G T arlb 20 10 EE TR M ED DS W AR 25 43 12 1 Probabilities of having flood depth >= 600mm Adjusted for 50 years climate change N OH .J 'S PL E AC Ga rag e G AG AR E ST ET RE Ga rag e Pos t 32 TA Cen tre T EE TR Wo rk s 1 to 7 3 S O Llandudno S tation AR t AD 16 D Cli n ic El Sub Sta f Re st 24 lo OA Po l ic e Sta tio n 3 8 AV a pe Ch R nt me rn es ve Go Off ic Y 37 IT IN E TH TR U EN LL GY RO eC D ile 8 OR XF EE J ub BIL 1 JU 2 29 Th Ort e C h o Ch o do p ti c u rc x h 14 OR P RE ST ET Te le ph on e Ex c ha ng e M ag is tra tes ' Cou rt Ox fo rd Ho us e 28 1 17 Po s t 5 8 16 PA SS AG E / RT Clu b OR XF D CR O N Y ST OU MO C R YN GE ST RO M O T R ER CW O G R 1 Y sgol Tudno 8 EE BIL JU El Sub Sta RO AD LLAND 41 10 25 N R NT LO CE Wo rk s E DO 3 15 BIN N,S SO 5 15 12 10 33 1 1 SB SP M P3 VIE DA S' W H AY OW AR D RO AD 25 try 5 E Dep ot 27 5 G SA an S PA lG Sta S' 5 Sig na Sub 29 T EE IE 7 BU R ST V DA 12 Wo rk s R El 26 15 10 DE IL AD 1 RO E AN N 3 13 M OR 31 2 Cen tra l Hou s e N 11 LA El Su b Sta 1 tra l Un Pal its ce 20 19 33 HM Co as tgu ard Res c ue Equ ip m e nt 16 Ce n AN 13 1 H AC PL 47 M OR 19 C FA AL 45 Wa re ho us e N AY W 9 39 ED Bd y LB Sup ers to re 20 El Sub Sta 19 14 3 Work s 1 15 5 CA E 1 CIL S T EE TR W 21 T ES er a th He ra e B H AR OW D AC PL E Depot O FF M as t P R EN N HY 'S 14 M C R CE ON CW LA 7 Reproduced from Ordnance Survey Mapping with the permission of HMSO Crown Copyright. Conwy County Borough Council. 100023380 S CK JA De pot 14 15 16 6 12 Fa c tory 8 D RD 13 CO UN 8 H Dia m o nd Hou s e 6 C BA Wo rk s Boa s e Yard DO NOT SCALE Goods Yard Llandudno 49 Mixed Use Employment & Housing allocations In accordance with TAN 15, mixed use developments will be defined by the most vulnerable use. The following table consist of mixed use employment and residential development; this is classified as highly vulnerable development and will only be permitted within C flood risk zones where it can be justified. The following table of mixed use employment and residential developments satisfies the requirements of TAN15 therefore no further justification is required. 50 Urban Development strategy Area – Mixed use Employment & Housing Urban Settlement Site Allocation Abergele Abergele Business Park 5 Hectares of B1 Employment & 80 Dwellings 3.5 Hectares of B1 Employment & 150 Dwellings TAN 15 Flood Zone A Adjacent to Bodlondeb, Conwy 0.5 Hectares of B1 Employment & 30 Dwellings TAN 15 Flood Zone A Esgyryn, Llandudno Junction 6.2 Hectares of B1 Employment & 120 Dwellings TAN 15 Flood Zone A. Abergele Conwy Llandudno Junction Abergele South East Flood risk Mitigation No Objection Officer Comment Suitable. No EA flood zone 1 – low risk. TAN 15 Flood Zone A EA flood zone 1 – Low Risk (Except immediately next to river) TAN 15 Justification Test Required Flood risk from River Gele (Main River) but no know risk from ordinary watercourse at south of site) No objection but no residential development immediately next to main river. No known previous flooding. No constraints identified by Environment Agency Wales. No Environment objection from the Council’s Agency flood zone Environment and Technical 1 – low risk service No known flooding history on site. There are watercourses at the north west extent of the site near the roundabout and running through the centre of the site for the western half. No objections raised but issues with watercourses and surface run off in the area need to be resolved. No additional surface flows should enter water courses. Suitable. Avoid developing immediately adjacent to the river. No Suitable. No Suitable. Sustainable Drainage will be recommended in the development brief No 51 Waste Management Facility – Gofer TAN 15 defines processing facilities (waste management facilities) as less vulnerable development, waste disposal such as landfill is classed as highly vulnerable development. The site is surrounded by C2 flood risk zone but is located entirely outside of the flood risk area; therefore development on this site can be justified in line with Tan15 requirements. Waste Management Facility - Gofer Location Flood Risk Officer Comment E24 – Gofer Ex Landfill Site The site is outside the extreme flood area. No objection from Environmental Services or the EAW. This site has been suggested by the landowner for waste management facilities. The site benefits from being within an accessible location, close to waste arisings and within close proximity to a bulking station, transfer station and civic amenity facility. Tan 15 Justification Test Required No Conclusion The majority of the sites allocated through the Conwy Revised Deposit LDP are not at risk of flooding and satisfy the requirements of TAN15. However, due to the constrained topography of the authority with regards to sources of flooding, and the fact that 85% of the population of Conwy lives within coastal areas, the Council recognises that it has a responsibility to maintain the vitality of its settlements through new development. Therefore the SFCA was undertaken to demonstrate that the consequences of flooding are sufficiently understood and can be managed in an acceptable and sustainable way to permit development within areas of low risk in order to satisfy identified local needs. Allocated sites within the LDP have been assessed against the requirements of TAN 15. The majority of these sites were found to be acceptable without any further assessments required. However, a small number of sites were found to be at risk from flooding and the relevant TAN15 justification test applied. Through further assessment it was considered that these sites could be successfully managed against flooding where relevant mitigation measures can be implemented. 52 The evidence base used to assess and justify the allocation of the flood risk sites is deemed to be sound. However, where additional information is required following the representation(s) received to the revised deposit plan, this will be the responsibility of either the LPA prior to formal submission and/or the developer prior to submitting a planning application. For instance, the EAW may deem the assessment and mitigation levels proposed for some sites in this SFCA as unsatisfactory and request that further assessment work or a FCA be undertaken prior to carrying the site forward. Should these sites be found to be unsuitable for development following further requested assessment, then contingency sites and/or sites considered as part of the Alternative Site Representations consultation will be considered to ensure an adequate provision of housing land within the county borough. 53
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