The Welsh Government is consulting on a refreshed Technical Advice Note 15: Development, Flooding and Coastal Erosion (TAN15) until 17 January 2019.
The interpretation of TAN15 has evolved over time, as informed by case law and a progressively risk-based approach by Natural Resources Wales (following on from predecessor Environment Agency Wales), however the guidance has not been updated since its introduction in 2004.
The most obvious change is the proposed Wales Flood Map (WFM), with Zones 1, 2 and 3 set to replace Zones A, B, C1 and C2, and responsibility for the maps shifting to Natural Resources Wales (NRW). Most notably, the maps will now incorporate climate change, which means the extent of each zone will change.
While we can draw on experience of working with NRW and its advice on incorporating climate change into assessments, the implications for individual projects will not be known until the new Flood Map is published.
The consultation proposes a clearer steer than previously on regeneration sites, recognising that many of Wales’ key sites for regeneration are in locations prone to flood risk. This should not be interpreted as a green light for sites that may previously have been sterilised by flood risk, however it does provide the framework for careful consideration of possible solutions.
Overall, the proposed changes as they relate to development and flood risk largely reflect the evolution of practice over time, with more emphasis on strategic and risk-based approaches, as reflected in the new maps incorporating climate change, the streamlining of criteria for managing the consequences of flooding and introduction of a hazard matrix in line with best practice.
The consultation also proposes that TAN14 (Coastal Planning) is cancelled and coastal erosion considerations are integrated with TAN15.
Those with expectations of more emphasis on coastal planning to complement the introduction of the Welsh National Marine Plan in November 2019 – especially the champions of integrated coastal zone management – may be disappointed by this proposal. However the guidance on Coastal Planning (TAN14) has long been under-utilised – it was last updated in March 1998.
There is no doubt that we will experience coastal change over our lifetime, exacerbated by climate change, and that we should plan to adapt and be resilient to change. However the proposed focus for TAN15 is coastal erosion. This will guide a more strategic approach to avoiding development in areas at risk by encouraging planning authorities to address it through development plans.