Memorandum by North Yorkshire County Council
DRAFT PPG 25 "DEVELOPMENT AND FLOOD
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
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
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:
development behind existing defences;
camping and caravan sites;
sustainable urban drainage systems;
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
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
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
Senior Planning Officer, Environmental
17 November 2000
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