Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

Memorandum by the Council for the Protection of Rural England (FP 03)


  1.  The impact of recent flooding has focused attention on the relationship between new development and water management. The issues go well beyond the role of land use planning in shaping the location of development and involve our collective response to climate change, soil protection, farming practices, urban renaissance and sustainable construction. CPRE encourages the Committee to adopt a broad perspective to its inquiry which addresses these issues.


  2.  The wide acceptance that anthropogenic greenhouse gas emissions are a significant contributing factor to increasingly extreme weather patterns, highlights the urgent need for action by the Government, and others to address both the causes of climate change, and the impacts. The scale of the task has been clearly demonstrated by the Royal Commission on Environmental Pollution's report, Energy: the changing climate, which requires a much more forward looking and radical response than we have currently seen. Action to tackle the symptoms of climate change without tackling the causes is bound to failure in the long run.


  3.  CPRE welcomes the new emphasis in draft PPG 25 Development and Flood Risk on prevention of risk through co-ordinated decision-making within river basins as well as on flood plains, and the employment of soft engineering techniques. It will be a priority to ensure the effective implementation of PPG 25 when it is published, and this will have resource implications for the Planning Directorate of DETR, Government Regional Offices and local authorities in terms of the staff and skills available. We urge the Committee to recognise these.

  4.  We are concerned that in a significant number of cases the Environment Agency's clear advice on flood risk appears to be overruled by local planning authorities, although the extent of this problem is difficult to gauge in the absence of readily available data. While many of these developments may be small, the cumulative effects of numerous decisions over decades can be grave. CPRE believes that the Environment Agency should be able to refer applications it objects to, but which the local planning authority intends to approve, to the Secretary of State for a clear decisions to be made (and justified) on whether a call-in is necessary or not. The Environment Agency also needs to play a more active role in strategic planning, especially Regional Planning Guidance and Structure Plans, and strategic planning authorities need to address development and flood risk issues more effectively. The Strategic Environmental Assessment of RPG and development plans should explicitly address the issue.


  5.  The sole characteristic of soil currently recognised by the planning system is its productive capacity for agriculture and only that classed as Best and Most Versatile (BMV) land (Grades 1, 2 and 3a) enjoys any degree of protection. Even this is not consistently applied. The numerous other benefits of soils—as a filter and reservoir for draining water, a carbon sink, a reservoir of historic resources, a contributor to local distinctiveness and a supporter for biodiversity—need to be fully recognised and protected.

  6.  We regret that the Government is failing at present to implement a stronger system for valuing land, and soil in particular, especially in the light of the clear and powerful recommendations of the Royal Commission on Environmental Pollution's 1995 report Sustainable Use of Soil. The Rural White Paper provides the opportunity to give a clear lead on this important issue. We believe that publication and implementation of a full national soil protection strategy should be an urgent priority for the Government which has an important role to play in minimising future flood risk.


  7.  Land management practices have a major impact on the hydrological cycle in river basins. Extensive ploughing of meadows, land drainage, field enlargement and other land management practices can all significantly increase flood risk. The ploughing of meadows in the Wye Valley in Herefordshire for potatoes, for example, has had a major impact. Since 1992 England has lost over 1,200 sq km of permanent grassland to more intensive land management or urban development.

  8.  The implications of changing farm practices for flood risk as well as other issues need to be properly assessed and integrated into other land use objectives. CPRE believes there is a need for closer integration between the land management objectives being established in Regional Rural Development Plans and Regional Planning Guidance and development plans. The wider impacts of shifting land management practices also need to be more fully addressed by the Regional Rural Development Plans and by MAFF. There is also a need to introduce effective requirements for Environmental Impact Assessment in relation to land use changes (as required by EU Directive 85/337/EEC); cross-compliance arrangements so that all farm support is used to achieve minimum environment standards; a further shift in farm support towards environmental and away from production objectives; and an extension of planning controls to major and irreversible land use changes, such as the ploughing of ancient meadows.


  9.  The Government's Sustainable Construction Strategy, Building a Better Quality of Life and the environmental dimension to the Movement for Innovation (M41) offer vehicles for promoting sustainable drainage techniques more widely in the industry. CPRE believes it should be priority for Government, working with the construction industry and local planning authorities, to ensure that good practice in sustainable urban drainage schemes (SUDS) becomes the norm as quickly as possible.


  10.  We believe the current flooding is further evidence of the wisdom of the Government's emphasis on urban renaissance, in combination with sustainable construction and drainage practices. This avoids further development of floodplains and the accelerated run off which results from urbanising rural land. Sustainable urban extensions are identified in PPG 3 as the next most acceptable option for accommodating development after re-use of urban land and buildings. They offer important opportunities to demonstrate leading-edge techniques in, for example, grey water re-use and drainage control through permeable surfaces which should be maximised with the objective of reducing flood risk in mind.


November 2000

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