Memorandum submitted by Landmark Information
Group (FL 163)
1. Landmark Information Group is the market-leader
in the provision of environmental (including flood risk) reports
to home buyers and their legal advisers, supplying over 50,000
a month. We work closely with bodies like the Environment Agency
(EA), British Geological Survey, the Ordnance Survey, as well
as many private data holders, to ensure that consumers are able
to make an effective risk assessment prior to purchasing commercial
or residential properties.
2. Events of recent months have demonstrated
only too clearly how important it is that the public fully understands
the implications of environmental risks for their properties and
we welcome the opportunity to submit a supplementary memorandum
to the Committee on this particular issue of flood risk information
and consumer awareness.
3. The Environment Agency has recently stated
that the vital first step for consumers to achieve better flood
prevention is to find out if they are at risk. Landmark supports
this view, and believes that in seeking to inform consumers as
part of better preparation for floods, it is critical that consumers
understand what flood risk information they are getting, and how
reliable it is. One of the issues highlighted by the events of
the summer of 2007 is the discrepancies between different flood
data sources that consumers rely on. The incidents of flooding
in places where floods have not occurred in living memory, or
where the Environment Agency does not indicate a risk, have increased.
For example, pluvial flooding (sometimes known as "flash
flooding") in Kingston-upon-Hull caused major disruption,
and yet large parts of this area do not feature in the Environment
Agency floodplain records. However, some data available from the
private sector identifies the area as at high risk. (Please see
enclosed map at footer of document).[62]
4. This situation has been repeated numerous
times throughout the country and over the different periods of
flooding, with significant consequences for those members of the
public in affected areas. It highlights that, in part because
of the different causes of flood mentioned above in point 3, no
single source of data is, as yet, adequate.
5. In order therefore to provide consumers
with the most comprehensive information to inform their risk assessment,
it is necessary to combine numerous data sources, for example
Environment Agency official data, insurance claims data and information
from the British Geological Survey on groundwater flooding and
geological indicators of flooding. The private sector does this,
and it will be important that it continues to do so.
6. It can only do so, however, through a
competitive market driving innovation. For example, Norwich Union
has created a new flood map, and Landmark has collated the EA,
NU, BGS and other unique data sets to provide the most comprehensive
report available. In addition we have added an assessment of the
risk. We have also commissioned a unique new flood map of the
UK which will provide yet another more accurate analysis of flood
risk than any single data set that currently exists.
7. None of this innovation and development
would happen without a competitive market for flood information.
Other property risk searches provide an illustration of how competition
can drive up accuracy and quality whilst driving down the cost
to the homeowner. Environmental reports, for example. Conversely,
property searches operating without competition have not come
down in price.
8. Awareness on the part of consumers is
a critical first step. Both the public and private sectors should
work together to build awareness of the need for consumers to
ensure they are aware of the risks to their property. In doing
so however, the Government must not lure consumers into a false
sense of security about the information that they are relying
on. Only with the right information can consumers then take the
right measures—and make the significant investments they
might need. Making such big decisions based on Government-backed
data may have implications for Government where such data is less
accurate than information available elsewhere.
9. There are those who propose that flood
due diligence should become a part of the conveyancing due diligence
process as part of a Home Information Pack. We are agnostic on
this issue, and certainly would not want a requirement that consumers
pay in every case for inaccurate information. However, we do believe
that there is a due diligence issue here for solicitors acting
on behalf of the buyer, as there is with contaminated land.
10. It is unrealistic to expect Government
to foot the bill for solving the flood issues in the UK. Such
a task, with the changing climate, is simply unfeasible due to
cost. Expecting the insurance industry to pick up the pieces is
also unrealistic, and their models will become increasingly sophisticated
to weed out problem properties and areas. We believe consumers,
therefore, must act to protect themselves through understanding
any risk, to a significant level of accuracy, before they buy.
11. We make this argument without prejudice
to the importance of addressing other aspects of the flood defence
system, for example drainage infrastructure, planning requirements
and investment in physical flood defences.
12. Landmark firmly believes therefore that
the fundamental key to any solution is to ensure consumers have
the information and can make a decision based on their own attitude
to that risk. Only by succeeding in raising awareness among consumers
of the risks associated with flood, and giving them the tools
with which to make an appropriate assessment of the risks, will
we succeed in achieving better management of flood risks in the
UK.
We welcome the Committee's work on this important
subject and are happy to offer further information to the inquiry.
James Sherwood-Rogers
Managing Director
Landmark Information Group
February 2008
62 Not printed. Back
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