The application site is located in Flood Zone 3, an area deemed by the Environment Agency as being at a high risk of flooding and the proposed dwellings would be a 'more vulnerable' use. However, as the proposal does not involve substantial re-building it is considered to be a change of use, for which the sequential test and exceptions test are not necessary (paragraph 164 NPPF, 33 NPPG) although the risks of flooding to the proposed residential use need to be considered. Notwithstanding the provision of a safe refuge area in one of the proposed barn conversions, the second dwelling would remain single storey in terms of its accommodation and would lack a means of escape. This results in a situation whereby any occupier would not have a safe place to go in times of a flood. As a consequence the building does not provide the necessary mitigation measures needed to ensure flood safety and increases the risk to life of any potential occupants. The application is therefore contrary to the National Planning Policy Framework and guidance within the Planning Practice Guidance relating to Flood Risk and Coastal Change.