Flooding: Cooperation across Government Contents

5Planning and strategy

Nationally significant infrastructure

62.The floods of winters 2013 and 2015 brought into focus the resilience of nationally significant infrastructure, such as airports, ports, and electricity networks. The CCC in its first statutory progress report to Parliament on the National Adaptation Programme in June 2015 said:

There is evidence that operators across most infrastructure sectors are taking steps to improve the performance of their networks and services during periods of extreme weather.73

The CCC highlighted positive examples of electricity, water and transport networks. Electricity transmission and distribution companies were taking a comprehensive approach to assessing risks, investing in resilience, and reporting on the progress being made. Water companies were investing in resilience improvements following the 2007 floods. Transport resilience was improving following the Government’s acceptance of all 63 recommendations in the independent Brown Review.

63.The CCC also pointed out “areas where evidence of progress is lacking”74. It noted how ports on the east coast of England were badly affected by the December 2013 tidal surge, the largest in the UK in 60 years. The Port of Immingham had to suspend its operations for a number days following flood damage to on-site IT servers and electricity substations:

Work to assess vulnerabilities by port operators is ongoing but this appears to be focused on raising awareness of climate change; it is not clear what improvements in flood protection have been made or are planned. Having participated in the first round of ARP [Adaptation Reporting Power] reporting, some ports have decided not to provide an update as part of round two.75

The CCC noted how passengers at Gatwick’s North Terminal suffered significant disruption on Christmas Eve 2013. Flood alerts were missed by duty staff, and flood water damaged basement IT and power facilities:

The similarity between the Immingham and Gatwick incidents led the Brown Review to conclude that poor siting of critical power and IT equipment may be a common vulnerability across many sectors that should be addressed as a matter of urgency.76

The CCC said that adaptation plans were at an early stage in the digital infrastructure sector.77 But it thought the services should be reasonably robust, given companies compete on service reliability. The CCC hoped the sector’s first ARP reports, due in 2015, would allow any specific vulnerabilities, and the actions being taken, to be better understood.78

64.Based on the CCC’s assessment, we invited a range of infrastructure providers to take part in a roundtable evidence session to assess their approach to, and progress on preparing for, flood resilience.

Tom Jeynes, Sustainable Development Manager (Humber), from Associated British Ports (ABP) said it had undertaken a thorough review of its ports’ physical resilience, and the Port of Immingham was working to the resilience benchmark set by the December 2013 tidal surge, which was a one in 450 year event. He said, “ideally along the front-line of the port, we would like to aim for a one in 1,000 years standard of protection.”79 But he added that the difficult part of improving the port’s flood protection was the lock pit, which affords access for deep sea shipping to the enclosed dock at Immingham, and required bespoke, expensive gates.80 Mr Jeynes said the port was working with the Environment Agency to model future floods and invest in flood defences.81
Chris Woodroofe, Head of Passenger Operations at Gatwick Airport, told us that prior to 2008 its South Terminal had been resilient to a one in 20-year flood event. Following investment with the Environment Agency and Crawley borough council in the Upper Mole flood alleviation scheme, to which Gatwick contributed £4 million to the £15 million programme, the terminal became resilient to a one in 50-year event. Mr Woodroofe added how, after the December 2013 floods, the airport commissioned a review which made 27 recommendations, to which Gatwick responded with a £30 million investment fund to improve resilience. Some £20 million had been spent so far. Mr Woodroofe also said that Gatwick was undertaking joint work with the Environment Agency, and that the airport had an aspiration to achieve one in 100-year resilience. This is still well below the CCC’s recommendation that all infrastructure assets should meet a one in 200-year standard.82
Ian Glover, Environment Sustainability Manager at National Grid said his company’s target was to achieve a one in 1,000 year standard for its large, high-voltage electricity substations and was working towards that through risk assessment and defence prioritisation projects.83 Mr Glover noted that none of the Grid’s substations had been affected by recent winter floods.84 Smaller, local substations, operated by distribution network operators had, however, been affected, including in Calderdale during winter 2015.85 Ivan Le Fevre, Head of Environment at Highways England said the road network had proved to be “reasonably resilient” and it had a longstanding programme of work to assess performance and identify flood-risk areas. It, too, was working with the Environment Agency to maintain resilience.86 Tim Kersley, Head of Asset Management Strategy at Network Rail told us that given the scale of the infrastructure it operates, it was trying to provide more resilient performance against adverse weather, which usually occurred annually, rather than against extreme events.87

65.The infrastructure companies we heard from referred to a range of resilience levels to which they aspired. Ian Glover from National Grid said he was seeking “a consistent picture of resilience levels that organisations are targeting, particularly among other critical national infrastructure.”88 Daniel Johns at the CCC wanted this information to be reported annually to help understand whether improvements to infrastructure were being made.89 He also wanted to understand, in cases where the resilience levels of infrastructure were known, whether those levels were appropriate:

Within the electricity industry, the distribution and transmission companies have a standard that says what level of resilience they want to aim for in substations. [ … ]. The concern is that every single flood event that occurs seems to involve a substation somewhere in the country flooding, [ … ]. The question again is: is the standard being implemented? Is the one in 100 flood event really the right benchmark to be protecting assets to, particularly in light of climate change?90

In its 2015 progress report the CCC said ‘the Cabinet Office should work with all infrastructure sectors [ … ] to develop consistent incident reporting, together with indicators of network resilience and performance, to allow improvements to be measured over time.’ Reporting of the results should be mandatory under the third round of the ARP. It also recommended that, ‘the Cabinet Office should confirm that the services provided by all critical national infrastructure (CNI) are now resilient to a 1-in-200 year flood event.’91

66.Oliver Letwin said the Government was reconsidering what constitutes critical infrastructure and now aiming for resilience to a one in 1000-year standard for local infrastructure, such as smaller substations and mobile communications assets, which if it were to go down would affect more than 5,000, 10,000 or 15,000 people. Oliver Letwin said:

The revealed preference [ … ] of the British public, when it was faced with a Vodafone server switch apparatus in Leeds becoming flooded, which prevented the airwave system from operating properly and prevented people from using their mobile phones during a flood [ … ] was that this was a pretty poor show, in much the same way as they might have said it was a pretty poor show if water had got into a nuclear power station,92

He added that, for the 40% of this infrastructure which will not have defences in place against extreme flooding in the next six years, the Government will put in temporary defences by Christmas. For the other 60%, where it says temporary defences do not make sense, it will wait to install permanent ones. He said, “we are very directly responding at a much higher level to what the Adaptation Committee has quite rightly drawn attention to”.93

67.The winter floods of 2013 and 2015 called into question the preparedness of some infrastructure companies to deal with flood events. The companies we heard from were all aiming to protect their assets to different standards. We are concerned that infrastructure operators continue to adopt varying degrees of preparedness and that there is an apparent lack of Government vigour to ensure a consistent and robust approach is taken to protecting services.

68.We therefore recommend that the Government implement the Committee on Climate Change’s proposals that infrastructure companies be mandated to report their target resilience level, why this target is appropriate and what progress they are making to achieve it. The Government should also adopt the CCC’s recommendation to ensure that critical assets meet a minimum of a one in 200-year event. The flooding of small-scale energy and communications assets can cause large-scale problems, as it did in Leeds in winter 2015. We therefore welcome the Government’s focus on protecting local infrastructure against extreme flooding, but recommend that Ministers publish which assets comprise the 40% being protected with temporary defences and which make up the remaining 60% that will have to wait for permanent safeguards. Notwithstanding this, Ministers must also ensure that the resilience of other, larger critical infrastructure assets are improved.

National Planning Policy Framework

69.The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these are expected to be applied. It “provides a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities.”94 In relation to flooding, the NPPF states:

Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards.95

There is a statutory requirement for local planning authorities to consult the Environment Agency for developments in certain flood zones and Lead Local Flood Authorities (LLFAs) for major developments before granting planning permission. The Environment Agency has standing advice on its website which gives guidance to local planning authorities and developers where flood risk is an issue, including on when the Environment Agency should be consulted on planning applications. The Government’s planning practice guidance
states that all local planning authorities should notify the Environment Agency of the
decision on any planning application to which it has objected on flood risk grounds. 96

70.Witnesses challenged whether local authorities did make clear what action they took in response to Environment Agency advice. Lord Krebs said:

It is not always clear what response the local authority makes to the Environment Agency’s recommendations. They do not always feed back to the Environment Agency what decision they have taken [ … ] in theory, yes it ought to provide a robust mechanism; in practice it probably does not.97

In response, Sir James Bevan, from the Environment Agency, said that between April 2011 and March 2015, “99.1% of new homes had planning decisions that were in line with our advice.”98 On the surface this figure appeared to be inconsistent with the finding that 7% of homes—almost 10,000—were built in high flood-risk areas in 2013–14.99 But Sir James said, “they [the two figures] could certainly be consistent [ … ]. The fact that 99.1% of new homes have planning decisions along in line with our advice does not necessarily mean that 99.1% of new homes were not built in flood risk areas. It means that if they were built in flood risk areas they were in line with the advice that we had given about how to mitigate that risk.”100

71.The 99.1% figure is not, however, based on records of every local authority decision. Lord Krebs told us, local planning authorities do not in fact always inform the Environment Agency of the outcome of their objection. The CCC has stated it is “highly likely” that the Environment Agency’s advice is followed “in the majority of cases where the local authority does not inform them of the outcome.”101 Nevertheless, the Association of British Insurers (ABI) recently called for “evidence of clearer engagement between the Environment Agency and Local Planning Authorities, with a responsibility to report publicly on planning decisions in a clear and transparent way,” as it said this would help empower consumers when deciding whether to purchase a particular property.102

72.Even in those cases where the Environment Agency’s advice was followed, as evidenced in the terms of any subsequent planning permission, there were concerns about the implementation of those terms. Daniel Johns, from the CCC, explained:

The local authorities are in general applying the recommendations to individual developments, but there is no check at the end of that process that the properties being built are being built in sensible places in sensible ways.103

Elsewhere the CCC has reported that no data are available on whether developers are building in compliance with conditions set by planning authorities: “Planning authorities are responsible for enforcing planning conditions, but there is no systematic approach to recording checks and enforcement where it takes place.”104

73.Available statistics indicate that Environment Agency advice on whether, or how, to build in high flood-risk areas is almost always followed by local authorities. In the interests of clarity, transparency and consistency, however, this information—the decisions on, and terms of, planning permission in such areas—should be published in full by local authorities. We recommend that DCLG publish, by the end of 2016, a proposed framework for the reporting of such information. There are no comprehensive statistics detailing whether developers subsequently build according to planning permission, however. Given that almost 10,000 homes were built in high flood-risk areas in 2013–14, we recommend that Defra work with DCLG to establish a systematic approach to ensuring that these properties are built in accordance with planning permission.

Local planning

74.Alongside calls for clarity about whether local authorities follow Environment Agency advice, and properties are built accordingly, the CCC was also concerned to ensure the cumulative impact of individual decisions, taken in isolation, to grant planning permission for construction in high-flood risk areas throughout the country was assessed. Daniel Johns from the CCC suggested that “a simple misunderstanding of statistics” was part of the problem:

The chance of a flood event in one place might be one in 100 but there are lots of places in England that could get wet, so the chance of some part of the country flooding each year is much greater than one in 100 and, if you are building new properties in the flood plain, it is just really a question of when and where rather than whether it will flood next.105

The CCC referred to this issue in its 2015 progress report, when it said: “The lack of a regional tier of planning means that local authorities are effectively planning in isolation and not considering the cumulative build-up of risk.”106 The Town and Country Planning Association (TCPA) built on this point in evidence to us, noting that local plans did not look widely enough across the landscape—or far enough into the future. Hugh Ellis, Head of Policy at the TCPA, said:

The average local plan, which is the only foundation for statutory planning that we have, realistically is planning for three to five years, with maybe a 15-year time horizon. It is absolutely imperative we plan for 50 to 100 years and perfectly sensible to do so; certainly they do that in the Netherlands [ … ]. Does local planning reflect catchment area planning at the right spatial scale? No, it does not [ … ] we are planning for the wrong geography with the wrong system over the wrong timescales and, I am increasingly seriously worried, with the wrong science [ … ]

On coastal flooding, Mr Ellis added that he knew of “virtually no local plans” that were including the Environment Agency’s allowances for 1.24m of sea-level rise on the East Anglian coast by the end of the century.107 He concluded that, “we need a new comprehensive form of planning to deal with climate change [ … and … ] cross-catchment area planning.”108 Legislation does allow, however, two or more local planning authorities to agree to prepare a joint Local Plan to address cross-boundary issues. Similarly, the duty to cooperate requires local authorities and other public bodies to collaborate on a plan when there are matters that would have a significant impact on the areas of two or more authorities.109

75.Notwithstanding the content of local plans, the CCC last year also drew attention to concerns about the number of plans actually in place, noting that, “A high proportion of local authorities do not have legally enforceable Local Plans, which is undermining strategic planning.”110 According to the Planning Inspectorate’s (PINS) most recent figures, 29% (98 out of 338) of local authorities did not have an adopted local plan as of 30 April 2016; while more 51% of those local authorities that did have a plan (122 out of 240) adopted it prior to the publication of the NPPF in March 2012. 111 Government guidance states that most local plans are likely to require updating in whole or in part at least every five years.112 Some 35% of authorities (85 out of 240) adopted theirs prior to May 2011.113 On this issue, the CCC has said:

Where an up-to-date adopted Local Plan is not in place, developers may be more likely to apply for planning permission in unallocated areas knowing that they will have a chance of their application being approved if they appeal against the refusal of permission.114

76.Government should devise a means of establishing and communicating to people the cumulative impact of individual local authorities granting planning permission across the country for developments in one in 100-year areas. The chances of one of those developments flooding significantly is greater than one in 100 years and will increase as more such developments are approved. Ministers must also consider whether local plans are fit for purpose, given that the areas they cover by and large do not correspond to catchment areas and that their short timescales do not correspond to the longer-term environmental changes that local areas need to be planning for now. Given the number of local authorities that do not either have an adopted local plan or one that reflects NPPF guidance, Government should, in the short term, provide more support to local authorities to enable them to adopt a plan and, in the medium term, support and encourage local authorities to develop joint local plans that are more ambitious in time and scale.

Lead Local Flood Authorities

77.A lack of completed plans was also an issue in relation to Lead Local Flood Authorities (LLFAs): county councils and unitary authorities, which, under the Flood and Water Management Act 2010, are required to prepare and maintain a local flood risk management strategy, coordinating views and activity with other local bodies and communities through public consultation and scrutiny, and delivery planning.115

78.The Environment Agency told us that as of 31 March 2015, 59 (39%) of the existing 152 LLFAs reported that they had published a strategy, and 43 (29%) reported they had completed consultation or had a strategy out for consultation—102 (68%) in total. The remaining 50 (32%) reported they had yet to consult on their strategy. The Environment Agency added that Rory Stewart recently wrote to LLFAs underlining the importance of completing their local strategies and giving 31 March 2016 as a target date.116 When the Minister appeared before us, he quoted the same figures but told us:

Currently 102 strategies are either completed or drafts in consultation in the public domain. That means that we have 80% published or complete and we have 20% still in progress [ … ] we are in absolutely no doubt that this is a legal responsibility of the local authorities and we are pushing them hard to complete [ … ] If there are individual authorities [ … ] that require extra assistance, we can provide that from the Environment Agency.117

79.We were unsure where the Minister’s figures of 80% completed, or consulted on, and 20% in progress came from, given the Environment Agency’s figures of 68% and 32% respectively. The Minister’s response also suggested no plans had moved from in progress to complete since March 2015. Matthew Bell, Chief Executive of the CCC, said the number of incomplete plans raised the question of whether the system was delivering what it was supposed to in each area of the country, and asked, “are the institutional structures and the incentives in place at that local level so that the right decision emerges? It is not clear that is the case.”118

80.The lack of completed plans was a cause for concern, but another issue was whether finalised plans were fit-for-purpose. When we visited Leeds, we heard from Calderdale Council that following the floods in its area during winter 2015 it had had to completely revise its plan.

81.Rory Stewart said the Environment Agency could provide LLFAs with extra assistance with their plans. Sir James Bevan told us his organisation has a “dialogue” with them,119 and the EA added that it had built close working relationships locally with them, and worked through those channels to reach common understanding or resolve issues relating to any aspect to flood and coastal erosion risk management, including strategies, plans or actions.120

82.Notwithstanding the work that the Environment Agency said it had done to assist local authorities, the Agency suggested that the problem was lead local flood authority capacity to produce strategies. Sir James said:

I have been much struck, going around the country and talking to local authorities, that there are very big discrepancies in terms of size, and capacity, and funding. I do not get the impression that any of those local authorities does not want to do this; it is just a matter of capacity and their ability to prioritise [ … ] I regard it as our job to help them, particularly those local authorities who might need a bit more capacity to help them develop a plan that will work.121

83.Almost one third of lead local flood authorities (LLFAs) still do not have a local flood risk management strategy in place, according to the most recent figures available. These figures are, however, more than one year old. This suggests that Government may not know whether progress has been made to reduce this worryingly high figure. It also suggests Government lacks a comprehensive, up-to-date overview of local authority preparedness for flood risk. Furthermore, those LLFAs that do have a plan in place may not have one that is fit-for-purpose. There is an urgent need to put the right plans in place as soon as possible, but some LLFAs may not have the capacity to do so. For strategic oversight of flood risk management throughout the country, the Government needs to have an up-to-date overview of the number of LLFAs with plans in place. But it also needs to support the Environment Agency to ensure it can support those LLFAs that lack the capacity to produce these plans, and to review existing plans to guarantee they are preparing for the appropriate risk level.

Sustainable Urban Drainage Systems

84.After the 2007 summer floods that inundated 55,000 homes, the then Government commissioned Sir Michael Pitt to undertake a review of the lessons to be learned. In his report Sir Michael recommended that the right to connect new developments to the public sewerage system, for the purpose of surface water drainage, be repealed.122 Successive Governments have not accepted this recommendation in full. The CCC in its 2015 report reiterated Sir Michael’s call, and also suggested making water companies statutory consultees on planning applications with drainage implications, and monitoring uptake. The Government responded:

We are confident that the changes to planning policy put in place by the previous coalition Government to promote sustainable drainage systems (SUDS) as the first option for surface water drainage for new major developments will achieve this (reduction in call on the public sewer).123

That planning policy was implemented on 6 April 2015 and, according to the Environment Agency, is still in the early phases of implementation. Under national planning policy, new development must give priority to the use of sustainable drainage systems (SUDS). This means that developers must prove that SUDS will not be a viable solution before other surface water management measures are considered. This reflects the commitment by Government towards their delivery and implementation.124

85.We heard, however, that uptake was “disappointingly low”,125 with witnesses citing the costs to developers as a barrier to SUDs installation. Lord Krebs said the Government’s new approach was “still not sufficient” to achieve the level of uptake that the CCC wanted, and “the resistance to it is probably that it is extra work for developers: they would have to create soft surfaces or drainage areas that use up space, and it costs them money.”126

Hugh Ellis, from the TCPA, thought the difficulty with the new process was “the economics, because the benefits of sustainable urban drainage are long term to end users but the costs, of course, fall on developers.” As a solution, he cited the example of the Clean Air Act 1956:

When we see an environmental benefit that has a long-term benefit to people in the economy, one of the ways of doing it is simply to regulate. Within two years, the Clean Air Act solved an enormous public policy problem in the early 1950s [ … ] There are some cases where that [SUDS] is not appropriate, but in most cases they are. Then, of course, the market will adjust, so long as it is an even floor [ … ] Do your customers want to pay money to pay your insurance bills, or do they want to pay money for a better built environment?127

86.There were, however, potential downsides to compulsion, according to the Environment Agency, which said that the conditions for controlling when a Water and Sewerage Company (WaSC) could refuse connection must be carefully developed, to avoid consequential risks:

There may be benefit in WaSCs being able to refuse connections where there is no capacity, for example to protect against increased risk to sewer flooding, combined sewer overflow spills or overloading of sewage treatment works. However, this may discourage proactive engagement, planning and investment by the WaSC. There is also potential for inconsistency by making the WaSC the decision maker in controlling where surface or foul sewage is treated. This could present significant risks to the environment, public water supply, viability of development, regulatory burden, resourcing and compliance.128

The WaSC is not the only body on which SUDS-related powers might be conferred, however. Schedule 3 of the Flood and Water Management Act 2010, which is yet to be fully commenced, provides for the establishment of a SUDS Approving Body (SAB) within LLFAs, which would have to approve any proposed new drainage system before construction could commence.129 When we suggested that it was easier to force developers to create sponges on housing estates, rather than connect to Victorian sewers, Rory Stewart referred to “the question of modelling [ … ] and the way in which you try to attach cross-benefit calculations to absorbing water in a particular patch of ground and what the consequences are downstream, effectively, for flow and river level in terms of water getting into people’s houses.” He added:

In many cases that [SUDS] is a smart thing to do, but there are other cases where that is not the most cost beneficial intervention.130

87.The House of Lords sought to include a new clause in the recent Housing and Planning Act to remove an automatic right to connect to the public sewer for surface water, unless a sustainable drainage system formed part of a development and was constructed in accordance with non-statutory technical standards and with the terms of the planning permission. The Government was against the amendment, stating that it was “unnecessary and unworkable” due largely to the technicalities of including planning permission in the new clause.131 The Commons subsequently disagreed to the new clause but the Government tabled in lieu the following amendment to which the Lords agreed:

The Secretary of State must carry out a review of planning legislation, government planning policy and local planning policies concerning sustainable drainage in relation to the development of land in England.

In the debate DCLG Minister Baroness Williams of Trafford said the review would be thorough, robust and look at evidence on the ground. Lord Krebs asked that it be completed in spring 2017 so that the CCC Adaptation Sub-Committee could use the findings in its progress report to Parliament in summer 2017. Baroness Williams said she would work with the Lords towards a “suitable timescale.”132

88.Sustainable urban drainage systems, such as rainwater capture and storage, are widely acknowledged to be an efficient way of dealing with surface water. But successive Governments have been reluctant to commence the legal powers that would make such systems the default option in new developments. The often cited reason is cost to developers. While these should not be underestimated, if the refusal is introduced to all developments, except in very particular circumstances, a level playing field should be maintained. Developers may pass those costs on to house buyers, a concern that again should not be ignored. But the longer-term costs, directly or from increased insurance premiums, of paying to repair houses and clean up local areas can be expected to outweigh short-term expense. We question, nine years after the Pitt review recommendation that SUDS be the default option in new developments, why a further review is required. Given this has now been legislated for, however, we recommend that it be completed at the latest in time for the CCC to use the findings in its 2017 progress report to Parliament.

73 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 78

74 As above

75 As above

76 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 79

77 Fixed line, mobile telephony, internet and data service providers.

78 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 79

79 Q177

80 As above

81 Q170

82 Q174

83 Q179

84 Q180

85 Q191 [Cllr Steve Sweeney]

86 Q183

87 Q185

88 Q208

89 Q40

90 Q41

91 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 79

92 Q234

93 Q260

94 HM Government, National Planning Policy Framework, March 2012, para 1

95 HM Government, National Planning Policy Framework, March 2012, para 100. One or more local planning authorities produce a strategic flood risk assessment to assess the risk to an area from flooding from all sources. Local authorities are required to produce a Local Plan, setting out the strategic priorities for development of an area and covering housing, commercial, public and private development, transport infrastructure and protection for the environment.

96 HM Government, Planning Practice Guidance, para 043, accessed 9 May 2016. The EA must be consulted on developments of 10 dwellings or more, or new floorspace of 1,000 square metres or more, or a site of 1 hectare or more, in flood zone 2 (land having between a 1 in 100 and 1 in 1,000 annual probability of river flooding; or land having between a 1 in 200 and 1 in 1,000 annual probability of sea flooding); flood zone 3 (land having a 1 in 100 or greater annual probability of river flooding; or land having a 1 in 200 or greater annual probability of sea flooding; or land where water has to flow or be stored in times of flood); and in any flood zone 1 (land having a less than 1 in 1,000 annual probability of river or sea flooding) that has critical drainage problems.

97 Q14

98 Q153

99 “UK building 10,000 homes a year on floodplains”, Financial Times, 28 December 2015

100 Q157

101 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 63. The CCC says the Environment Agency’s advice was accurately transposed by planning authorities into conditions set out in the final decision notices in almost all of the 111 applications assessed by the CCC Adaptation Sub-Committee in more detail.

102 Evidence to the Environment, Food and Rural Affairs Committee (FFP0011), para 6.6

103 Q15

104 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 63

105 Q16

106 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 74

107 Q198

108 Q199

109 HM Government, Planning Practice Guidance: Local Plans, para 007

110 Committee on Climate Change, Progress in preparing for climate change: 2015 report to Parliament, June 2015, p 74

111 Planning Inspectorate, Core Strategy Progress, 30 April 2016, accessed 9 May 2016

112 HM Government, Preparing a local plan, para 008, accessed 9 May 2016

113 Planning Inspectorate, Core Strategy Progress, 30 April 2016, accessed 9 May 2016