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


Memorandum by the Royal Society for the Protection of Birds (FP 15)

1.  PROTECTING FLOODPLAINS FROM DAMAGING DEVELOPMENT

  Many floods occur or are exacerbated because of inappropriate development on the floodplain. It is thus vital that floodplains are protected from damaging development. The protection of floodplains is paramount and PPG 25 must acknowledge and clearly articulate this. However, the RSPB is concerned that the guidance:

    —  lacks a clear presumption against development in the flood plain, unless there are demonstrable interests of over-riding importance, and does not fully reflect the Government policy to discourage inappropriate development in areas at risk from flooding; and

    —  fails to provide criteria for when development may be allowed in the flood plain.

  It is not clear where, or indeed if any, flood plains should not be developed. At present there are too many poorly defined exceptions to the general rule which means that the PPG fails to give a clear steer to local planning authorities. In fact, the draft PPG fails to make the necessary links with MAFF's Strategy for Flood and Coastal Defence in England and Wales. This Strategy aims to reduce risks to people and the environment (developed and natural) from flooding and coastal erosion by encouraging technically, environmentally and economically sound and sustainable defence measures. One of the three key objectives to achieve the policy is to "to discourage inappropriate development in areas at risk from flooding and coastal erosion".

2.  REPORTING ON DECISIONS THAT RUN COUNTER TO ENVIRONMENT AGENCY ADVICE

  Within the high level targets set by MAFF for flood and coastal defence, there is one on development in areas at risk from flooding. As a result of this target, the Environment Agency, since June 2000, should have been reporting to MAFF and the DETR the final decisions made by local authorities on planning applications the Agency have objected to on the grounds of flood risk. This reporting should include information on whether these decisions were in line with or contrary to Agency advice "to discourage inappropriate development in areas at risk from flooding and coastal erosion."

3.  THE ROLE OF FLOODPLAINS IN REDUCING URBAN FLOOD RISK

  Recent extensive flooding illustrates the disastrous consequences of flooding. However building existing defences higher only exacerbates flooding in those areas with lower flood banks. There are alternatives such as the creation of washlands in the floodplain which hold back flood waters to reduce flooding in downstream urban areas and then release this water slowly when the flood risk has passed. Such washlands can also provide wider environmental benefits to wildlife and society. The draft PPG offers an opportunity to promote these more natural systems approaches by allocating land for such washlands within a development plan.

4.  A STRATEGIC, CATCHMENT BASED APPROACH TO DEVELOPMENT

  All new development increases the amount of water running into rivers after rainfall and so increases flood risk in towns downstream. Development in the floodplain exacerbates this further by reducing the natural ability of the floodplain to contain floods. While each development on its own makes only a limited contribution to increasing flood risk downstream, if all recent developments in a river basin are added together the impacts can be substantial. Yet, at present each developer responds separately to remedying the problem.

  Co-ordinating the developers' contribution to reducing flood risk would achieve greater environmental and social gain. DETR need to investigate how the developers' contribution to reducing flood risk can be implemented in a strategic way to achieve better management of flood risk, enhance biodiversity (such as the creation of wetlands to store flood waters) and enhance water resource security.

5.  THE NEED FOR A WIDER PPG COVERING ALL WATER RELATED ISSUES

  While the RSPB welcomes the draft PPG 25, we still regard this as a missed opportunity. A combined PPG on Water dealing with issues of water conservation, supply, demand and environmental capacity, as well as pollution and flooding, would have helped give water issues a higher profile in the planning system and amongst planners and developers. The PPG structure at present fragments water issues which inhibits the integrated and sustainable management of water. It is the RSPB's view that water management is inadequately addressed with emphasis still on technical fixes rather than restraining development in areas of water stress. Greater attention must be paid to demand management.

  A PPG on water could refer to water conservation technology in building and require development plans to identify areas of water stress as well as covering the issues currently in the draft PPG 25. We appreciate that such a PPG is unlikely to emerge following this consultation. Nevertheless PPG 25 should cross reference to other water issues (ie relevant circulars and PPGs). Serious consideration should be given to updating, and potentially consolidating other planning advice on water.

6.  ASSESSING THE CUMULATIVE IMPACT OF DEVELOPMENT ON THE FLOODPLAIN

  PPG 25 should refer to Strategic Environmental Assessment (SEA) or environmental appraisals of development plans as a means of dealing with cumulative impacts. Cumulative flood risk is raised as an issue but the PPG does not provide Local Planning Authorities with answers as to how to deal with it—eg through environmental appraisal and strategic environmental assessment.

The RSPB

November 2000


 
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