Memorandum by the City of Worcester (FP
DRAFT PPG 25 DEVELOPMENT
Thank you for the invitation to submit additional
comments on the draft PPG in the light of our experience of the
last few weeks. I have forwarded the City Council's original comments
and I have now had the opportunity to consult my engineering colleagues
who were involved in the recent flood emergency. We would like
to take the opportunity to add a few points.
Worcester experiences flooding from the River
Severn on a regular basis. The Council has cleared some development
from high risk areas, and since 1992 has had a comprehensive set
of planning policies controlling development within the flood
plain (based on 1 in 100 year event). The effectiveness of this
strategy was proven in the events of recent weeks, and the flood
plain mapping was also accurate. On the basis of this proven track
record, we now propose to define flood plains for the other "main
rivers" in the city as part of the Local Plan Review.
My principal concern about the draft PPG is
that there is too much emphasis on the resolution of problems
by means of defences. Flood defences were modelled in Worcester's
hydrological study in 1990 and were found to exacerbate flooding
when major flood events occurred. The potential effects were clearly
evident from the way the recent flood water flowed across the
flood plain, as water levels rose and fell. Defences can give
a false sense of security as major events will overtop them.
In our view the PPG should give greater emphasis
to directing development away from areas of flood risk. I do recognise
that policies must be tailored to local circumstances and what
is appropriate to Worcester may not be appropriate elsewhere,
but the PPG must lead by establishing the guiding principles.
I am aware of the likely debate about pressure for the development
of brownfield sites and balancing this against flood plain issues.
Although Worcester has a tight urban boundary and development
pressures are acute, I still believe that the flood plains are
not viable planning options for future development.
You will appreciate that these are officer comments
and have not been the subject of any committee debate
Head of Planning and Economic Development
16 November 2000
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