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

Memorandum by North Yorkshire County Council (FP 09)


  Thank you for the recent telephone call regarding the Committee's forthcoming consideration of draft PPG 25, a timely call in view of the effects on North Yorkshire of the recent weather.

  Bearing in mind the timescale that you outlined, I have been able to prepare evidence on some of the issues that the document raises but would not claim that this is necessarily a final reaction to the current flooding here in North Yorkshire. I have, however, advised the City of York Council and Ryedale and Selby District Councils of your request for views in the light of the extensive recent flooding around York, Malton/Norton and Selby.

  Flood defence and planning is a matter upon which the Council has been undertaking a considerable amount of work in conjunction with the Environment Agency and other organisations. We sought to ensure that draft Regional Planning Guidance contained policies to steer major development away from floodplains and promoted the extension of managed washlands. The report of the Public Examination panel has largely supported this approach. We anticipate that the Structure plan Review, a draft of which is expected in 2001, will give a strong lead on this matter.

  The Council is also a member of the Project Board of the Sustainable Management of the River Ouse Project. This is one of three projects set up by the Environment Agency and Yorkshire Water Services to improve the sustainable management of water resources. The aim of the Ouse Project is to balance the need to provide a cost-effective and secure water supply, protect the environment and communities and reflect the needs of a wide range of interests. Inevitably flooding has emerged as a key issue. The Ouse and its tributaries have been very badly affected by the recent heavy rainfall to the detriment of householders, businesses and communications.

  The County Council has prepared a discussion paper for the Project Board on the "Control of Development within the Floodplain". Although not prepared with your Committee's specific deliberations in mind, it does address a number of the key issues. A copy of the paper is enclosed for the use of your Committee.[4]

  As noted at paragraph 6, the paper concentrates on the contribution that the planning system can make to the control or prevention of flooding by regulating those land uses under its control. It does not deal with wider factors such as agricultural and forestry practices or maintenance and capacity issues which also contribute to flooding problems.

  From paragraph 21 onwards the paper addresses such issues as:

    —  developer contributions;

    —  development behind existing defences;

    —  camping and caravan sites;

    —  sustainable urban drainage systems; and

    —  land drainage.

  There are several further points that your Committee may wish to consider.

  As we discussed during the Committee's recent visit to North Yorkshire, Government policy in PPG 3 rightly emphasises the need for urban regeneration and the redevelopment of urban brownfield sites. However, in North Yorkshire, as I suspect in many other areas, such sites are often found in those parts of existing towns which have historically developed on flood plains. This point is recognised in the draft guidance which refers to the inadvisability of using flood-prone redevelopment sites for housing. If the precautionary principle put forward in draft PPG 25 is to be pursued in the light of the recent experience of extreme flood levels, it may be more difficult for local authorities in some areas to achieve the brownfield targets currently being put forward in Regional Planning Guidance.

  Urban capacity studies which will confirm this are yet to be undertaken, but some local authorities may find themselves faced with having to prioritise between housing allocations that minimise flood risks and those that maximise the use of recycled land. It may become a question of what is least unacceptable in wider sustainability terms if local development needs are to be met.

  It should also be recognised that flood prevention measures may make it difficult to achieve other national policy objectives in PPG 3. Larger developer contributions to flood defence or alleviation works together with the use of part of a site for sustainable urban drainage systems will increase unit costs and may, for example, limit the scope for affordable housing to be accommodated within a wider development scheme. Similarly the use of part of a site for sustainable drainage systems could make it difficult to achieve the density levels advocated in PPG 3.

  The draft PPG properly promotes the precautionary principle in relation to flood risk but does not prescribe the appropriate level of risk to different types of development. Rather than leave the issue to individual authorities the final PPG should give guidance on national standards, such as those based on the Environment Agency's research on extreme floods. This would have significant advantages and give greater certainty to local planning authority decision making.

  A further issue that needs to be addressed is the role and use of floodplains. Rivers and watercourses can only cope with a certain maximum flow and when this is exceeded, as it has been this autumn, flooding occurs. When a watercourse floods, the excess water flows onto a floodplain. These areas are an integral part of the river system and provide extra capacity for the storage of floodwater prior to subsequent release. This capacity is reduced if significant areas of floodplain have been raised, embanked, or built on. This loss of storage capacity can lead to higher river levels elsewhere and for this reason it is not possible to alleviate flooding in all areas. Along the Ouse a number of areas are specifically recognised or managed as washlands which serve to reduce flood levels further downstream.

  In terms of the planning system there is now perhaps a need to recognise flood storage as a land use in its own right or one of several multi-uses, for washlands, together with appropriate policies, to be included in development plans and to ensure that relevant proposals in the Environment Agency's Local Environment Agency Plans are included in local plans.

  The scale and extent of the current floods suggests that Government must now consider whether the final PPG should include a presumption against certain types of residential and institutional development within areas liable to flooding. While this would represent a departure from the case by case risk-based approach a clearly stated presumption against development along lines similar to green belt policy may make it easier to implement. There would, of course, be dangers if this were to be adopted as a knee-jerk reaction to recent events because many settlements owe their location, history and urban form to a river access or crossing point. An unqualified policy U-turn towards over-protection could introduce a new form of property blight in low-lying areas and adversely affect investment and regeneration initiatives. It could also result in a distorted pattern of development at the local, strategic and regional levels with whole areas and towns effectively being unable to accommodate further development.

  Currently, draft PPG 25 gives only limited advice on the approach to be adopted to development behind river flood defences, referring solely to design and construction. Given the scale of the flooding in North Yorkshire, consideration should be given to a more comprehensive approach as a basis for future planning policies.

  In extreme circumstances it may be necessary to consider whether to assist relocation of some of the most vulnerable homes and businesses. While this could not be considered as a normal planning response, there may be circumstances where central and local government might wish to consider introducing relocation packages or other forms of pragmatic assistance where this would address high risk and ensure a more sustainable form of development. In planning terms this might require local authorities to adopt a more flexible response to local needs and the interpretation of policy.

M Spittle
Senior Planning Officer, Environmental Services

17 November 2000

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