Letter to the Chairman of the Committee
from the Chief Executive, Royal Sun Alliance, 27 July 2007 (FL
73a)
Thank you very much for your letter of 17 July,
and for the update you provided about the potential work programme
of the Environment, Food and Rural Affairs Select Committee. I
would also like to take this opportunity to respond to a couple
of the issues you raised in your last correspondence, regarding
flood risk modelling and the importance of factoring urban drainage
systems in to calculations of flood risk.
As you note in your letter, situations will
always occur in which it is impossible to eliminate flood risk
entirely. However, these recent floods illustrate two deficiencies
with the system of flood management in the UK—insufficient
investment in the flood defence infrastructure, and inadequate
consideration of the interaction between extreme weather events
and the capacity of the built environment to cope with these events.
At present, the insurance industry is unable to access what information
the Government and Environment Agency might have regarding the
capacity of the UK drainage system. Whilst recent events have
shown that we cannot predict where rainfall will occur, access
to a comprehensive and up-to-date record of the complete flood
management infrastructure, including the condition and nature
of the drainage network, would help us plan in the short-term
where best to locate our emergency response units to ensure our
customers are provided with quick and effective relief. As we
discussed during our dinner last year, we would also call on the
Government to provide insurers with complete access to the Environment
Agency's National Flood and Coastal Defence Database (NFCDD) as
part of its review into the recent floods.
Another issue which this latest round of flooding
has raised is that the development of the flood plain in the south
east is likely to exacerbate the problem of more frequent and
severe flooding, involving as it does around 200,000 properties
being placed in areas of high risk. We welcome the reassurances
in the recent Housing Green Paper that flood risk will be enshrined
as key factor in planning decisions, as well as the future inclusion
of climate change predictions in planning policy. However, as
we told the Efra Select Committee during its inquiry on the Environment
Agency in 2005, we would strongly advise that all possible planning
should be re-located to areas of lower risk in the first place.
We would also urge the Government to facilitate a frank and open
discussion between all stakeholders involved in development policy,
about how buildings in all areas in future can be designed to
cope with extreme weather events.
R&SA are committed to engaging actively
with the Government's flooding review over the upcoming months,
and hope that the Government moves quickly to clarify how and
where the additional money it has committed to flood defences
will be spent, and what the profile for this increased investment
will look like over the next four years. In the interim, should
you find any extra information from us useful, we would be more
than happy to meet with you to discuss this important issue further.
Bridget McIntyre
Chief Executive
Royal & SunAlliance
July 2007
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