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

Memorandum by City of York Council (FP 19)


  The Council is generally supportive of the content of the draft guidance. The main thrust of the note towards adopting a precautionary approach to flood risk is one which the City of York Council would wholeheartedly support.

  The City Council are supportive of the guidance's presumption against inappropriate development in land liable to flood and to continue to liaise closely with the Environment Agency and other agencies early in the process to ensure that any perceived risks are investigated fully.

  This is effectively the Council's position in its current draft Local Plan (policy GP15; March 1999—copy enclosed) which it utilises for the assessment of all planning applications. This policy has been agreed with the Environment Agency as an acceptable basis for dealing with the flood risk as it applies to new development in the York context.

  Given the government's emphasis on urban renaissance and brownfield development targets it would seem clear that investigation should take place into whether engineering solutions are a possibility when assessing individual development proposals on brownfield land liable to flood.

  The Council maintains that given York's circumstances (where large tracts of the urban area are adjacent to rivers or watercourses) that this position should remain unchanged in the government's current guidance (draft PPG 25).

  The City Council strongly supports the draft guidance suggestion that discretion should be placed with local authorities (following detailed discussion with the Environment Agency) to ensure that they are satisfied they can deal with their own particular local circumstances as regards flooding risk.

  The recent flooding in North Yorkshire and York has demonstrated the potential for previously unknown river levels to overtop flood defences. This has emphasised the need for additional defences to protect areas identified by the Environment Agency on their flood maps, together with other areas not previously identified as being "at risk" from flooding. The City of York Council will be pressing for short and medium term action to address problems in the City of York area. The Council will be discussing with the Environment Agency how and when such measures can be introduced.

  In recent years the Council has successfully facilitated the development of a number of riverside sites in and around York City Centre (eg "General Accident" office building and "City Screen" leisure complex which face each other across the River Ouse in York City Centre). These have been designed to minimise any cumulative flooding impact as a result of the development by incorporating techniques such as basement flood storage. Whilst the Council would fully accept that such techniques may not offer the long-term solution to flooding in and around York City Centre, they do allow the authority to continue to meet its regeneration and social inclusion objectives through prioritising urban re-development.

  The City Council regularly corresponds with its neighbouring local authorities (and in fact is involved in preparing a Joint Structure Plan with North Yorkshire County Council and the two Yorkshire National Parks which will address the issue of the interaction between flooding and land use planning). One issue that may need to be discussed on a more formal basis is the potential "downstream" impact of development proposals higher up the river catchment. There are many other issues emerging in the discussions surrounding the flooding events of the River Ouse and River Derwent including dredging of rivers and preventative measures which require a regional perspective. This is something the City Council will be giving further consideration to and would appreciate further guidance from the government on how this can be achieved.

  The draft guidance goes into some detail on the potential of more sustainable drainage systems and this is something which the City of York will be giving some further consideration to together with the agencies involved in watercourse and piped drainage systems.

  I hope that these comments are of use to you in your deliberations on the final version of this very pertinent guidance note.

Roy Templeman
Director of Environment and Development Services
City of York Council

21 November 2000

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