Memorandum submitted by Prudential Property
Investment Managers Ltd (PRUPIM) (FL 161)
1. PRUPIM is a part of M & G, the investment
management arm of Prudential Plc in the UK. With over £19
billion invested in properties in the UK, PRUPIM is the leading
property investment management company in the UK. PRUPIM has interests
in a wide range of development projects and has involvement in
schemes where flood management schemes can make a positive contribution
to reducing flood risk as well as providing safe, new development
in sustainable locations. We welcome the opportunity to submit
a supplementary memorandum to the Committee's inquiry into flooding
on the particular issue of planning and development in relation
to flood risk.
2. Following recent events, climate change
and flooding are now recognised as major public concerns. This
is entirely appropriate, however PRUPIM are concerned that the
debate at present is failing to recognise the positive benefits
which can be achieved through appropriate flood management schemes.
We believe a more balanced approach is needed, specifically recognising
the real opportunities that are offered by flood management techniques
such as landraising and upstream storage. Such techniques can
not only reduce flood risk for existing communities, who might
otherwise be subjected to increasing risks as a consequence of
climate change, but also offer opportunities for sustainable new
development well-related to existing settlements.
3. PRUPIM has already made submissions to
Government in respect of Planning Policy Statement 25: Development
and Flood Risk, and its draft Companion Guide, in support of this
view. In these submissions, we raised concerns, that whilst flood
management techniques are recognised, the guidance fails adequately
to explore the potential that they have to enhance flood protection
for existing communities and thereby reduce risks to residents
and businesses alike. We believe that the failure to explore such
options and to include positive guidance as to their use represents
a lost opportunity on the part of Government, and hope that the
Committee might seek to further investigate the potential benefits
of developing a positive policy framework in this way.
4. We believe this is particularly given
Government targets on delivering a significant increase in the
supply of new housing and the widely acknowledged constraints
on land supply. Combined with the importance of delivering well-located
sustainable development as part of efforts to combat climate change—the
effects of which are thought to be one of the causes of the recent
floods—we strongly feel that opportunities involving flood
management schemes should not be rejected where they can make
a positive contribution to the development of sustainable communities.
5. One such example is the Taunton Riverside
Development in Somerset, where a business, retail and leisure
park development was brought forward in land partly within the
River Tone floodplain. By creating a reservoir within the floodplain
to provide replacement storage for that lost to landraising, the
developer was able to provide additional store and improved conveyance,
resulting in improved flood protection not only for the new development
but also the town of Taunton.
6. The development of the Northampton South
West Sector to bring forward commercial and residential development
partly within the floodplain of the River Nene is a further example.
In this instance, the developer created a strategic flood storage
reservoir on the River Nene to compensate for lost flood storage
from development in the floodplain, as well as capacity for additional
run off and improvements to the river. As a result, the development
planned for mitigation of effects within the development, and
provided spare capacity to reduce flood risk in the surrounding
area.
7. In this and other cases, flood management
schemes form an integral part of the development plans and are
funded by the developer. However, under current planning guidance,
such schemes are treated as exceptions despite the positive benefits
that accrue through reduced risk of flooding to existing properties.
Whilst these schemes accorded with the relevant guidance, we feel
that as examples they raise the question as to whether guidance
should not be more proactive in promoting and actively supporting
opportunities where developments bring flood defence benefits
to surrounding communities where they arise.
8. One of the Pitt Review's Interim Conclusions
(IC8) indicated that PPS25 should be rigorously applied by local
planning authorities, including giving consideration to all sources
of flood risk and ensuring that developers make a full contribution
to the costs both of building and maintaining any necessary defences.
PRUPIM is concerned that such an approach does not recognise the
potential benefits of flood management schemes associated with
new development and promotes an inflexible, rigid stance.
9. Opportunities do exist to address flood
risk without reliance upon public finance. We urge the Select
Committee to take into account these opportunities by encouraging
the development of a policy framework that offers positive support
to potential development schemes that deliver a reduction in flood
risk both to existing and new communities.
We welcome the Committee's work on this important
subject and are happy to offer further information to the inquiry.
PRUPIM
February 2008
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