Memorandum by the Environment Agency (FP
DEVELOPMENT ON, OR AFFECTING, THE FLOODPLAIN
The amount of damage, loss and injury from
floods is the result of deliberate choices
The Environment Agency welcomes the Environment,
Transport and Regional Affairs Committee's inquiry into "development
in or affecting the floodplain". We welcomed the previous
recommendations of this Committee and the Sixth Report of the
Agriculture Committee on Flood and Coastal Defence (1998)
1.1.1 Flood events have traditionally been
closely followed by increased awareness and action to reduce flood
risk. However, awarenessof people, organisations and Governmentrapidly
dwindles in the absence of flooding.
1.1.2 Guidance on Development and Flood
Risk was first produced in 1947. Planning Policy Guidance 25 (PPG
25) will be the sixth revision. It needs to look more to the future
as well as to the past if we are to keep flood risk in focus.
1.1.3 The Agency has provided a formal submission
to DETR on the consultation draft of PPG 25Development
and Flood Risk. This is attached as Annex 1.
1.2 Existing Challenges
1.2.1 1.85 million houses, 185,000 commercial
properties and 5 million people are now at risk.
1.2.2 There is commitment to development
via specific land allocations in Local Authority Development Plans.
These allocations could be storing up a problem for the future.
1.2.3 The number of planning applications
for development in mapped flood risk areas has increased year
on year over the last five years.
1.3 Climate Change
1.3.1 Climate change will increase the frequency
of flooding. Today's rare events will become tomorrow's frequent
ones. There were 30 floods recorded in the 30 months from December
1997 to June 2000. It is predicted that the 1-in-100-year event
today will occur every 20 years by the 2050s.
1.3.2 An allowance for sea level rise has
been included in the design of sea defences since 1989. Increases
in flood risk from rivers should be addressed immediately.
2. MAIN MESSAGES
2.1 In summary, our response in June 2000
highlighted that the draft PPG 25 must be more specific, and should
go further to:
ensure the use of a more sustainable
approach to development and flood risk;
emphasise that flood defences reduce
the risk of flooding, they do not eliminate it;
clearly define the Government position
on flood safety and new development;
promote development in low flood
risk areas first, and use a sequential search sequence to promote
development away from areas of high flood risk;
prescribe minimum standards of flood
defence for new development;
emphasise more strongly that development
can and should be made more "flood-resistant" through
by using current climate predictions as the basis for design;
ensure that emergency services are
involved in the planning of new development; and
ensure that new development does
not add to the costs of maintaining, operating and replacing existing
2.2 In the light of recent floods (Todmorden,
Uckfield and Yaldingthree timesand across the country),
we wish to emphasise the importance of the following issues. In
particular, we suggest that PPG 25 must:
take a much firmer line to prevent
properties being flooded, making allowances for climate change;
adopt a precautionary approach to
prevent flooding problems in the future;
be reinforced by Building Regulations
and other relevant guidance to ensure that development is better
designed to be safe and to resist floods;
be reviewed against specific targets
for the amount of development permitted in flood risk areas at
National, Regional and Local levels;
instigate a review of the flood risk
to and from sites already identified in Local Authority Development
encourage Local Authorities to set
standards of flood defence at a higher level than the minimum
prescribed in the PPG.
3. CLARITY AND
3.1 In our consultation response we encouraged
DETR to promote development outside flood risk areas, and advocated
the principle that:
built Development is unsustainable:
when it is located in a flood
where is creates additional flood
3.2 This policy proposal does not put a
veto on development in areas of flood risk, but it does encourage
an understanding of the risks involved, together with the compromises,
trade-offs, options and choices that will need to be examined
and made. It supports the aim of avoiding unacceptable development
and promotes a move to sustainable development.
3.3 This approach is especially relevant
to climate change, where there are doubts about the scale of potential
impacts. It is better to take a precautionary approach now ie
"apply the brake", than to regret, in the future, that
a cautious approach had not been taken.
4.1 A more sustainable approach to the selection
of sites for allocation in Development Plans is required. In our
response to draft PPG 25 a sequential search sequence for sites
was promotedpreference going to sites with no flood risk,
then those with a low risk followed by those sites with high risk.
4.2 This approach will work alongside existing
sequential approaches for retail and residential developments,
and will complement the need for Local Authorities to undertake
environmental appraisal of emerging Development Plans. As such,
the sequential search sequence will not conflict with the Government's
policy for the development of brownfield sites.
4.3 Local Authorities must be encouraged
to consult with emergency services in instances where Development
Plans provide for development in flood risk areas, in order to
understand the ability and capacity of emergency services to respond
to flood events.
5. EXISTING LAND
5.1 Through the statutory Town and Country
Planning process, land has been allocated for development via
Development Plans. Many development plans and land allocations
pre-date the current flood risk mapping programme, and decisions
have been made without the benefit of our existing understanding
of flood risk.
5.2 In order to ensure that a future problem
is not in store we recommend that reviews be undertaken by Local
Authorities of the flood risk to and from sites already identified
in Development Plans. This recommendation is consistent with the
provisions of the recently issued PPG 12 (paragraph 2.22)Development
Plans. These reviews, and future consideration of flood risk in
Development Plans, must be undertaken on a river catchment basis
(a strategic flood risk assessment) to provide a broad understanding
of the issues and the impact of development.
6. PLANNING APPLICATIONS
6.1 There has been a steady increase over
the last five years in the number of planning applications for
development in floodplains. Already this year 526,000 planning
applications have been submitted. These include 223,000 houses
of which 19,725 (9 per cent of total) are in floodplains. If this
trend were extrapolated to the 3.8 million houses proposed by
2021, 342,000 additional houses would be built in flood risk areas.
6.2 The Agency has carried out an assessment
of its effectiveness in influencing the determination of Planning
Applications by Local Planning Authorities. For development proposals
where flood risk could not be overcome by mitigation, 21 per cent
were given planning permission.
6.3 To reduce our dependency on flood mitigation
works greater emphasis must be given to ensuring the availability
of good quality information, expertise and innovative solutions
early in the development process, especially during Development
Plan preparation. In this way better development decisions and
choices can be made.
7. DETAILED FLOOD
7.1 Development proposals must be the subject
of a detailed flood risk assessment. Developers must be able to
demonstrate that, in flood risk terms, the proposal is "safe
enough to approve". Developers must be required to pay for
this assessment. The assessment will be available to potential
occupiers of these developments and allow informed choices to
7.2 Existing flood risk areas have been
published as maps by the Agency. This information is being improved
by annual updates, and is the best information available.
8.1 Piped systems have traditionally been
used to manage and dispose of surface water from developments.
These systems can increase the risk of flooding downstream of
the new development.
8.2 More sustainable drainage methods are
now available. They mimic nature and provide water quality, flood
defence and recreational benefits. A good practice design manual
was published earlier this year.
8.3 PPG 25 should promote the use, adoption
and maintenance of sustainable drainage systems. Building Regulations
must be amended to ensure that where piped systems are used they
are capable of accommodating all the surface water from a development
without exacerbating flood risk downstream.
9.1 Historically the primary emphasis in
considering potential flood damage has been the danger to life
followed by damage to property. The time is ripe for a more rounded
consideration of flood damage to be made, including impacts to:
power supplies for water supply and
telecommunications and other vital
location of fire, police and ambulance
vulnerable groups, especially young
children, elderly or disabled people.
9.2 Recent flood events have pointed to
shortcomings in the ability of some vital services to operate
under flood conditions. Consideration of their operation needs
to be made more explicit in PPG 25. Lessons must always be learned
from floods, and there must be a policy of continuous improvements
in addressing flood risk for future developments.
9.3 The importance of good, sustainable
design is being recognised in many areas, as is the contribution
that the construction industry can make. We want to see this extend
9.4 There are many relatively simple techniques
that can be used to make development less vulnerable to the impact
of floods. Examples of such measures include the use of solid
(not plasterboard) walls, and electrical installations supplied
from ceiling level.
9.5 A further issue is the existence of
a number of old industrial premises on the floodplain which pose
a potentially significant pollution hazard during flooding.
9.6 Sustainable construction can help reduce
the direct economic damage, and associated disruption costs, of
flood events. Social costs can be similarly reduced.
10.1 The recent floods have seen a number
of settlements benefit from large volumes of flood water being
stored on upstream floodplains, for instance at York and Gloucester.
It is important to recognise the role of floodplains in helping
to reduce the risk of floods downstream. Retaining existing floodplain
and restoring floodplain, where appropriate, are important alternatives
to relying on flood defences.
11.1 There is substantial pressure to develop
land. It is crucial to recognise that this must be done in a more
sustainable way, to provide for and to protect existing and future
generations. We must all seek to achieve more in the future than
we have achieved in the past.
11.2 Households are projected to increase
by 20 per cent by 2021. Our improved understanding of the consequences
and impact of development must be used to develop positive, aspirational
guidance as to how this scale of development is to be achieved
whilst ensuring environmental improvements.
11.3 To help achieve the goal of a better
quality of life for everyone, PPG 25 must ensure that flood risk
is given full and transparent consideration at a very early stage
in planning and development processes. It must promote seamless
and integrated partnerships across river catchments and on the
coast to facilitate development. This will enable development
options to be better understood and more informed choices to be
Director of Water Management
17 November 2000
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