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

Memorandum by the Environment Agency (FP 07)


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  Historically

  1.1.1  Flood events have traditionally been closely followed by increased awareness and action to reduce flood risk. However, awareness—of people, organisations and Government—rapidly 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 25—Development and Flood Risk. This is attached as Annex 1.[3]

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.


  2.1  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 innovative design;

    —  "future-proof" development 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 flood defences.

  2.2  In the light of recent floods (Todmorden, Uckfield and Yalding—three times—and 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 Plans; and

    —  encourage Local Authorities to set standards of flood defence at a higher level than the minimum prescribed in the PPG.


  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 risk area;

      —  where is creates additional flood risk.

  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 promoted—preference 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.


  5.1  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.


  6.1  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.


  7.1  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 be made.

  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 treatment facilities;

    —  telecommunications and other vital infrastructure;

    —  hospitals;

    —  location of fire, police and ambulance services;

    —  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 to flooding.

  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 made.

Director of Water Management

17 November 2000

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