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

Memorandum by The Housebuilders' Federation (FP 02)



  Ancient cities like York were founded in places where flooding was a risk because of the strategic advantages of the location. This was many years before national and local planning policies could ensure that any future development would not worsen the problem. Today, the planning system can work effectively to meet housing need and at the same time overcome reasonable risks associated with potential flooding.

  Draft PPG25 says that development is permissible where it is not at risk itself from flooding nor will it contribute to the risk of flooding elsewhere in the river system. It is this principle—that of "safe development"—which should underpin planning policy on flooding.

  But there is at present great pressure to introduce a variety of measures to prevent development. Such pressure often frustrates the economic, social and environmental advantages of planning positively for development that is safe, beneficial and sustainable.

  As presently drafted, PPG25 is ambiguous. It can be interpreted as a presumption against development in many locations, including many brownfield sites in our older towns and cities. This will significantly harm the delivery of the Government's wider sustainability objectives, and also the aims of its housing and planning policies—to provide a decent home for all.


  New development does not contribute significantly to flood risk for the following reasons:

    1.  There has not been significant recent development in flood plains around the country.

    2.  For many years now, surface water run-off has been controlled on new housing developments using engineering techniques such as storage tanks and detention basins which hold back the storm run-off until the river is ready to receive it. Only in much older development does rain water tend to go at unnatural speed through drains and sewers into the rivers, thereby risking flooding further downstream.

    3.  There are now highly sustainable new technological solutions which can make water management in houses much easier than in the existing stock. For example, Sustainable Urban Drainage Systems (SUDS), contain the surface water at "source". Properly installed, they replicate the river regime, with a completely neutral effect on flood risk. SUDS use environmentally friendly features such as reed-beds, ponds, swales soakaways and porous pavements. Advantages of SUDS include:

      —  creating new ponds and wetlands to act as public open space with high biodiversity;

      —  allowing development to take place in areas with near-capacity (or over-stretched) sewerage infrastructure, thereby making best use of brownfield land;

      —  reducing the effects of accidental pollution by containing any spillage at source;

      —  and, in areas of water shortage, they can help maintain (or recharge) aquifers and "at risk" watercourses.

  Not only are SUDS environmentally better, but they are often less expensive to install than traditional sewer systems. They may also be less expensive to repair and maintain (although water companies and others can upset the calculations by demanding punitive lump sum payments from developers to set aside for future maintenance purposes).

  So why are they not happening as much as we would like? Our colleagues in Scotland are leading the way with SUDS. In England, water companies and highways authorities are very reluctant to abandon their preference for traditional systems. This may be down to an ultra-cautious approach to innovation, or a feeling that their shareholders' interests are best served by the construction of network "assets" using known technologies.


  At present, clear guidance is given by Circular 30/92 on how potential flood risk problems should be identified, and how solutions should be found through planning agreements. This principle should not alter in the new guidance.

  The planning system currently requires that developers should be made aware of the risks in specific areas, the consequent constraints on development and means that developers can be asked to provide appropriate flood defence works as necessary. The cost of flood defences should be reflected in the value of the land, like any other development infrastructure requirement. Costs should not be passed to house buyers nor avoided and picked up later by flood defence bodies when problems arise and flood alleviation measures are called for at expense to the public purse.

  However, for such arrangements to work satisfactorily the Environment Agency must provide at an early stage in the planning process flood risk surveys, identify constraints and indicate how these may be overcome. This is so that both developers and land-owners can make financial provision for appropriate flood defences and surface water disposal from the outset.


  The Environment Agency is in the best position to offer impartial and independent advice to local planning authorities and developers. To facilitate this, PPG 25 should indicate that flood plain maps should be based on the best possible information and should be prepared to a consistent standard with a high degree of confidence.

  The Environment Agency could do a lot more through the planning system to create sustainable solutions, rather than effectively saying "no".

  It appears to be unwilling to take the lead in directing water companies and highways authorities to overcome the barriers to SUDS. The Agency could facilitate SUDS and thereby encourage new and more environmentally friendly approaches to development.

  We find around the country that the Agency could be a lot more proactive in the discussions between the local authority and developers which would enable many sites to be developed safely with the right safeguards in place. With more help from the Agency, we could, for example, make best use of brownfield sites in urban areas near rivers, and help the Government reach its 60 per cent target for development on recycled land.

Julian Smith
Head of External Affairs

The House Builders' Federation

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