Memorandum submitted by the Royal Town
Planning Institute (FL 156)
SUMMARY
— The RTPI considers the risk
of flooding to be a major civil contingency that requires to be
considered and responded to in planning policy and decision making.
— The RTPI is persuaded by work
carried out by the IPCC, Sir Nicholas Stern and the Foresight
Review of the view that:
— Climate change processes are a significant
likely source of additional flood risk over and above that experienced
by urban areas in the historical record.
— Additional costs over and above BAU
should prudently be devoted to addressing this likely risk-adaptation
costs.
— The effect of not incurring adaptation
costs, but responding to individual events as considered likely
to be necessary is likely to be manifold higher than of incurring
adaptation costs.
— Planning assumptions should respond
to the outputs from flood models that factor in climate change
drivers.
— The RTPI has considered the
interim report of Sir Michael Pitt into the 2007 flooding. The
following key questions emerge for planning:
— What should be the strategic relationship
between planning policy and decision-making and flood risk identification,
mitigation and management?
— What should be the relationship between
planning controls (development management) and other mechanisms
of control and regulation?
— What should be the `threshold' of
planning (or indeed other) control and regulation?
— It is important to ensure that
urbanisation and development processes stop contributing to an
ongoing exacerbation of flood risk due to overland flows and increased
or unmanaged discharges to drains, sewers and catchments generally.
Planning has a key role to play in delivering this objective in
partnership with other regimes of policy and control.
— The RTPI agrees that action
is necessary to reduce "urban creep": the ongoing and
uncontrolled reduction of the permeability of urban land. However,
measures other than the creation of new discretionary development
management processes within the planning system are urged for
small and incremental works.
— The RTPI agrees that action
is necessary to control access to sewer and drainage systems,
but again seeks measures other than discretionary development
management for small and incremental works.
— New "performance-based"
techniques for responding to "urban creep" should be
developed and conditioned through permitted development and/or
building control.
— There should be a principle
that urban development processes should, in aggregate and at the
scale of individual land ownerships, ensure that the permeability
of land is retained/restored at or near pre-urbanised values.
Strategically managing this is a valid operation of development
management.
— Planning policy and development
management more broadly should respond to the spatial patterns
of likely flood risks and to infrastructure development requirements
for mitigation, as set out in PPS25.
— However, local planning authorities
still urgently need:
— Detailed guidance on Flood Risk Appraisal.
Flood processes are enormously complex and the information needed
to support development needs is still inadequate.
— Guidance on minor applications that
will allow timely responses that do not involve undue bureaucracy
and unreasonable costs in providing flood risk information.
— Readily available and reliable flood
risk assessments at site and neighbourhood scales in particular.
— Better understanding of urban drainage
pressures.
— Urgent review of the implications
for both existing economic activity and brownfield regeneration
schemes in flood risk zones and integration of national policy
on flood risk with national policy on housing, regeneration and
brownfield redevelopment.
— Demonstration of how catchment flood
management plans prepared by the Environment Agency can be meaningfully
and successfully integrated into Local Development Frameworks.
— Better alignment of local development
policy and flood defence spending priorities.
— Detailed guidance on the relationship
between SEAs for Catchment Flood Management Plans (CFMPs) and
sustainability appraisal for spatial plans.
— Clarification of support for Sustainable
Urban Drainage schemes (SUDs).
Royal Town Planning Institute
January 2008
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