Memorandum by the Council for the Protection
of Rural England (FP 03)
DEVELOPMENT AND FLOOD RISK
1. The impact of recent flooding has focused
attention on the relationship between new development and water
management. The issues go well beyond the role of land use planning
in shaping the location of development and involve our collective
response to climate change, soil protection, farming practices,
urban renaissance and sustainable construction. CPRE encourages
the Committee to adopt a broad perspective to its inquiry which
addresses these issues.
2. The wide acceptance that anthropogenic
greenhouse gas emissions are a significant contributing factor
to increasingly extreme weather patterns, highlights the urgent
need for action by the Government, and others to address both
the causes of climate change, and the impacts. The scale of the
task has been clearly demonstrated by the Royal Commission on
Environmental Pollution's report, Energy: the changing climate,
which requires a much more forward looking and radical response
than we have currently seen. Action to tackle the symptoms of
climate change without tackling the causes is bound to failure
in the long run.
3. CPRE welcomes the new emphasis in draft
PPG 25 Development and Flood Risk on prevention of risk through
co-ordinated decision-making within river basins as well as on
flood plains, and the employment of soft engineering techniques.
It will be a priority to ensure the effective implementation of
PPG 25 when it is published, and this will have resource implications
for the Planning Directorate of DETR, Government Regional Offices
and local authorities in terms of the staff and skills available.
We urge the Committee to recognise these.
4. We are concerned that in a significant
number of cases the Environment Agency's clear advice on flood
risk appears to be overruled by local planning authorities, although
the extent of this problem is difficult to gauge in the absence
of readily available data. While many of these developments may
be small, the cumulative effects of numerous decisions over decades
can be grave. CPRE believes that the Environment Agency should
be able to refer applications it objects to, but which the local
planning authority intends to approve, to the Secretary of State
for a clear decisions to be made (and justified) on whether a
call-in is necessary or not. The Environment Agency also needs
to play a more active role in strategic planning, especially Regional
Planning Guidance and Structure Plans, and strategic planning
authorities need to address development and flood risk issues
more effectively. The Strategic Environmental Assessment of RPG
and development plans should explicitly address the issue.
5. The sole characteristic of soil currently
recognised by the planning system is its productive capacity for
agriculture and only that classed as Best and Most Versatile (BMV)
land (Grades 1, 2 and 3a) enjoys any degree of protection. Even
this is not consistently applied. The numerous other benefits
of soilsas a filter and reservoir for draining water, a
carbon sink, a reservoir of historic resources, a contributor
to local distinctiveness and a supporter for biodiversityneed
to be fully recognised and protected.
6. We regret that the Government is failing
at present to implement a stronger system for valuing land, and
soil in particular, especially in the light of the clear and powerful
recommendations of the Royal Commission on Environmental Pollution's
1995 report Sustainable Use of Soil. The Rural White Paper
provides the opportunity to give a clear lead on this important
issue. We believe that publication and implementation of a full
national soil protection strategy should be an urgent priority
for the Government which has an important role to play in minimising
future flood risk.
7. Land management practices have a major
impact on the hydrological cycle in river basins. Extensive ploughing
of meadows, land drainage, field enlargement and other land management
practices can all significantly increase flood risk. The ploughing
of meadows in the Wye Valley in Herefordshire for potatoes, for
example, has had a major impact. Since 1992 England has lost over
1,200 sq km of permanent grassland to more intensive land management
or urban development.
8. The implications of changing farm practices
for flood risk as well as other issues need to be properly assessed
and integrated into other land use objectives. CPRE believes there
is a need for closer integration between the land management objectives
being established in Regional Rural Development Plans and Regional
Planning Guidance and development plans. The wider impacts of
shifting land management practices also need to be more fully
addressed by the Regional Rural Development Plans and by MAFF.
There is also a need to introduce effective requirements for Environmental
Impact Assessment in relation to land use changes (as required
by EU Directive 85/337/EEC); cross-compliance arrangements so
that all farm support is used to achieve minimum environment standards;
a further shift in farm support towards environmental and away
from production objectives; and an extension of planning controls
to major and irreversible land use changes, such as the ploughing
of ancient meadows.
9. The Government's Sustainable Construction
Strategy, Building a Better Quality of Life and the environmental
dimension to the Movement for Innovation (M41) offer vehicles
for promoting sustainable drainage techniques more widely in the
industry. CPRE believes it should be priority for Government,
working with the construction industry and local planning authorities,
to ensure that good practice in sustainable urban drainage schemes
(SUDS) becomes the norm as quickly as possible.
10. We believe the current flooding is further
evidence of the wisdom of the Government's emphasis on urban renaissance,
in combination with sustainable construction and drainage practices.
This avoids further development of floodplains and the accelerated
run off which results from urbanising rural land. Sustainable
urban extensions are identified in PPG 3 as the next most acceptable
option for accommodating development after re-use of urban land
and buildings. They offer important opportunities to demonstrate
leading-edge techniques in, for example, grey water re-use and
drainage control through permeable surfaces which should be maximised
with the objective of reducing flood risk in mind.