Memorandum by The Housebuilders' Federation
DEVELOPMENT ON, OR AFFECTING, THE FLOODPLAIN
A PLANNING SYSTEM
Ancient cities like York were founded in places
where flooding was a risk because of the strategic advantages
of the location. This was many years before national and local
planning policies could ensure that any future development would
not worsen the problem. Today, the planning system can work effectively
to meet housing need and at the same time overcome reasonable
risks associated with potential flooding.
Draft PPG25 says that development is permissible
where it is not at risk itself from flooding nor will it contribute
to the risk of flooding elsewhere in the river system. It is this
principlethat of "safe development"which
should underpin planning policy on flooding.
But there is at present great pressure to introduce
a variety of measures to prevent development. Such pressure often
frustrates the economic, social and environmental advantages of
planning positively for development that is safe, beneficial and
As presently drafted, PPG25 is ambiguous. It
can be interpreted as a presumption against development in many
locations, including many brownfield sites in our older towns
and cities. This will significantly harm the delivery of the Government's
wider sustainability objectives, and also the aims of its housing
and planning policiesto provide a decent home for all.
New development does not contribute significantly
to flood risk for the following reasons:
1. There has not been significant recent
development in flood plains around the country.
2. For many years now, surface water run-off
has been controlled on new housing developments using engineering
techniques such as storage tanks and detention basins which hold
back the storm run-off until the river is ready to receive it.
Only in much older development does rain water tend to go at unnatural
speed through drains and sewers into the rivers, thereby risking
flooding further downstream.
3. There are now highly sustainable new technological
solutions which can make water management in houses much easier
than in the existing stock. For example, Sustainable Urban Drainage
Systems (SUDS), contain the surface water at "source".
Properly installed, they replicate the river regime, with a completely
neutral effect on flood risk. SUDS use environmentally friendly
features such as reed-beds, ponds, swales soakaways and porous
pavements. Advantages of SUDS include:
creating new ponds and wetlands
to act as public open space with high biodiversity;
allowing development to take
place in areas with near-capacity (or over-stretched) sewerage
infrastructure, thereby making best use of brownfield land;
reducing the effects of accidental
pollution by containing any spillage at source;
and, in areas of water shortage,
they can help maintain (or recharge) aquifers and "at risk"
Not only are SUDS environmentally better, but
they are often less expensive to install than traditional sewer
systems. They may also be less expensive to repair and maintain
(although water companies and others can upset the calculations
by demanding punitive lump sum payments from developers to set
aside for future maintenance purposes).
So why are they not happening as much as we
would like? Our colleagues in Scotland are leading the way with
SUDS. In England, water companies and highways authorities are
very reluctant to abandon their preference for traditional systems.
This may be down to an ultra-cautious approach to innovation,
or a feeling that their shareholders' interests are best served
by the construction of network "assets" using known
At present, clear guidance is given by Circular
30/92 on how potential flood risk problems should be identified,
and how solutions should be found through planning agreements.
This principle should not alter in the new guidance.
The planning system currently requires that
developers should be made aware of the risks in specific areas,
the consequent constraints on development and means that developers
can be asked to provide appropriate flood defence works as necessary.
The cost of flood defences should be reflected in the value of
the land, like any other development infrastructure requirement.
Costs should not be passed to house buyers nor avoided and picked
up later by flood defence bodies when problems arise and flood
alleviation measures are called for at expense to the public purse.
However, for such arrangements to work satisfactorily
the Environment Agency must provide at an early stage in the planning
process flood risk surveys, identify constraints and indicate
how these may be overcome. This is so that both developers and
land-owners can make financial provision for appropriate flood
defences and surface water disposal from the outset.
The Environment Agency is in the best position
to offer impartial and independent advice to local planning authorities
and developers. To facilitate this, PPG 25 should indicate that
flood plain maps should be based on the best possible information
and should be prepared to a consistent standard with a high degree
The Environment Agency could do a lot more through
the planning system to create sustainable solutions, rather than
effectively saying "no".
It appears to be unwilling to take the lead
in directing water companies and highways authorities to overcome
the barriers to SUDS. The Agency could facilitate SUDS and thereby
encourage new and more environmentally friendly approaches to
We find around the country that the Agency could
be a lot more proactive in the discussions between the local authority
and developers which would enable many sites to be developed safely
with the right safeguards in place. With more help from the Agency,
we could, for example, make best use of brownfield sites in urban
areas near rivers, and help the Government reach its 60 per cent
target for development on recycled land.
Head of External Affairs
The House Builders' Federation