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15/04/2014

The floods call for a planning revolution

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Kingston upon Thames floods

The recent floods have provoked a torrent of analysis and blame and, as ever, planning is in the frame – including calls for a “planning revolution”.

After the 2007 floods Sir Mike Pitt undertook an exhaustive study into the causes. Government and all the key players accepted his 92 recommendations. In planning terms these reiterated the need for strong planning controls, the need for flood risk assessments at both plan and site level, and the importance of the sequential test for both building and planning control. For exceptional development permitted in a flood plain developers should meet the cost of defences. The non-planning recommendations were just as important, and required action from all from householders to central government.
 
Planning policy reflects these risks and has not changed. Flood avoidance and mitigation remains a priority for planners. In England the NPPF contains all the important elements of PPS25, the previous policy on development and flood risk. Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but if development takes place in the flood plain it may only happen if it is made safe and does not increase flood risk elsewhere. The draft new planning guidance reflects this. Little new development is now approved in areas at high risk of flooding.
 
The Environment Agency, which must be consulted, calculates that in 2012/13 in cases where they objected, 95 per cent of applications were decided by planning authorities in line with their advice. That’s a lot of would-be potential development in the flood plain that hasn’t happened. Modern design should mean that if there is building in flood-prone areas the effects are effectively mitigated. We have the know-how to adapt, mitigate and protect against the impacts of climatic change.
 
I hope the government’s response will not be to commission further studies but, like all of us, take a long, hard look at what previous reports have advised and what we have and have not done.
 
The Public Accounts Committee looked at flood risk management in 2012 and its report, like Sir Michael’s, should be re-read when the waters subside. Calls for a reform of the planning system and just blaming new development in the flood plain are wide of the mark.
 
We need a national debate on the amount of effort, resources and brainpower we are going to apply to the task.
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I think the carrying out of site sequential searches in relation to site specific proposals is questionable especially if there has already been a strategic assessment as part of the local planning process. What it can lead to, as for example in the case of Selby in North Yorkshire, is a strategic flood risk assessment resulting in a major allocation for 800+ houses in flood zone 3a whereas small sites falling in zone 2 are rejected because the Council insists on a district wide site sequential assessment. The small zone 2 site sits a good quarter of a mile from the River Ouse whilst the major allocation is within 50 metres and will be subject to myriad mitigation measures to direct flood waters should defences fail (which they did in 2000). To the man in the street this dichotomy must look absurd. A strategic take on flood risk makes sense especially if it addresses the obvious tension between spatial strategy and flood risk. Once a settled view is established (between settlements accepting growth and those perhaps deemed too much at risk) then windfall sites can be assessed against that backdrop. I believe site specific sequential searches just bring the process into disrepute - especially when viewed from the prospect of the site's owner - how could he/she possibly engineer the sale of his own and the purchase of a safe site if a site sequential assessment has just condemned his land? It is plain nonesense! We should be encouraging a strategic approach to inform decision making and limit site specifics to flood mitigation measures (for those sites we believe to be acceptable).

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