Memorandum by the Royal Society for the
Protection of Birds (FP 15)
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
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".
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
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,
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
WIDER PPG COVERING
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.
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 iteg
through environmental appraisal and strategic environmental assessment.