CIWEM Soils PPS

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					                       Office of the Deputy Prime Minister

                       Consultation on Planning Policy Statement 25:
                       Development and Flood Risk

                       CIWEM Response, February 2006



The Chartered Institution of Water and Environmental Management (CIWEM) welcomes the
production of a new Planning Policy Statement on Development and Flood Risk. This is an
issue which is critical to the long-term sustainability of communities in the UK. With increasing
evidence of climate change becoming a reality, there is a need to address how
communities can be developed and managed in the face of increasing flood risk.

CIWEM recognizes that in modern day society, developments will take place in areas which
are at risk of flooding. However, this Institution hopes to see a step-change in attitude
towards flooding, with wider recognition of the threats posed by climate change, putting
flooding at the forefront of considerations regarding new development. We hope that this
PPS helps to deliver this change.

Layout of the PPS
CIWEM is concerned by the layout of the PPS. We understand that the intention is for the
document to focus on policy imperatives, and to be supported by the Annexes and the
Practice Guide. However, we believe that in setting the documentation out in this way,
many planners may simply read the 8 pages of the main statement and neglect to look at
the Annexes which contain some very fundamental advice.              PPG25 was less
compartmentalized and whilst we understand that ODPM wishes to make a clear statement,
we consider that for some this will be as far as they look.

A further observation is that it would be helpful for there to be clear guidance for planners on
the relationship and interactions between the different relevant plans including catchment
flood management plans and shoreline management plans. This could be in the form of flow
charts and be placed in Annex 1. We also suggest that the document would benefit from a
comprehensive glossary of terms.

Functional Floodplains
CIWEM considers that there is a need to recognize clearly that flood plains are functional
geographical features which have an important role in carrying and storing water in times of
flood. In response to the review of PPG25 we proposed the creation of a ‘Blue Belt’
designation as a means of clearly identifying flood plains. Whilst we are aware that the
ODPM has taken our comments on board but is not keen to implement such a designation,
we maintain that there remains a need for better definition of what is termed the ‘functional
floodplain’. The description in Annex D, “land where water has to flow or be stored in times of
flood’, is ambiguous and should be defined in more detail. Such areas have no defined flood
return period, unlike other zones, so it will be difficult for planning authorities and developers
to identify them from Environment Agency or other strategic flood maps.

Importance of regional and strategic flood risk assessments, timetabling, importance of maps
to planners
CIWEM is pleased to see the importance attached to flood risk assessments (FRAs) on the
regional, strategic, and site level. We are disappointed however, that the text of the PPS only
states that these should be carried out, and there appears no recourse if they are not. We
would like to see a requirement for all relevant authorities to be required to produce Regional
and Strategic FRAs to a clear timetable and with the aid of clear, detailed guidance. Such
assessments are vital tools for planners, who place great importance upon maps for a clear
       The Chartered Institution of Water and Environmental Management
                   ODPM PPS25 Consultation – February 2006

indication of flood risk. This is particularly so as in local authorities there is often a lack of
resources or skills to understand flooding issues in great detail.

We suggest that a deadline should be set so that completion of maps coincides well with the
review cycle for local authority plans. We suggest that the ODPM should require such maps
to be produced within the next 5 years. The existence of a set of clear strategic flood maps
would help to deliver greater effectiveness in flood risk management at a more local level. It
would be important for maps to be based on sound, verified science. These would provide a
higher quality alternative to the Environment Agency Flood Maps, which were produced
quickly over a period of only 18 months and occasionally suffer from inaccuracy (neither are
these maps consistently utilised across the Agency regions, and we are supportive of
proposals to roll out national EA guidance and training on this). There are also differences in
flood return banding used by different bodies e.g. the Environment Agency and the
insurance industry, which only adds to potential confusion.

Proper stakeholder engagement at the strategic level is also essential and will prevent
problems arising later in the planning process. A better resource of regional and strategic
flood risk assessments would also make it easier for developers to take flooding issues into
consideration at an earlier stage and reduce their exposure to losses arising as a result of
flooding issues highlighted at a later stage.

We consider that producing a resource-set of such nature would be a great step forward.
However, this would only work well if properly funded and delivered, therefore we urge the
Government to commit the appropriate funding.

Practice Guide
CIWEM welcomes the production of a Practice Guide to accompany the PPS. There is also a
need for an official set of high quality and detailed guidance on how to properly assess flood
risk. We consider the CIRIA C624 guidance to be a good example of high quality guidance
(although it will need to be updated to reflect the new PPS25) and we urge the ODPM to
build on this.

We are concerned that the guidance appears to be being rushed out for Spring/Summer
without any kind of trialing, or use of professional expertise that could be provided by, say, a
consultant tasked to develop the guidelines over a timescale representative of the size of the
job in hand. CIWEM urges ODPM to produce only an outline set of guidelines at this stage,
which could be trialed with a review after a year taking into account the experiences of the
wide range of practitioners in the field. We fear that the current process may result in the
production of a guideline set which is less comprehensive than the existing CIRIA guidance.
This may result in significantly differing interpretation and implementation of a rushed set of
guidelines which would be wrongly perceived as a definitive document. Given the
importance of the issue we urge the ODPM to consider this approach.

Exception Test
CIWEM recognizes the need for an exception test, however we consider that there should be
guidance on who is required to undertake an exception test and how this should be done. If
the developer is to undertake the test then they will need a good understanding of the wider
aims of sustainable development. Ultimately, this test must not be used as a means of
avoiding proper sustainable building.

Building on Defended Land
CIWEM considers that it is preferable not to build large-scale developments on defended
land. However, we acknowledge that there are many areas where there is little obvious
alternative. We would emphasise the essential need for houses being constructed in such
areas to be designed and built to reflect the possibility of flooding, including full risk
assessments and breach analyses to determine the precise location of buildings. However,
                                                                                         2

              CIWEM, 15 John Street, London, WC1N 2EB. Tel: 020 7831 3110 Fax: 020 7405 4967
               Email: admin@ciwem.org Web Site: www.ciwem.org. Reg. Charity No. 1043409
       The Chartered Institution of Water and Environmental Management
                   ODPM PPS25 Consultation – February 2006

detailed consideration must be given to the question of how far it is sensible to fund and
protect development behind defences and it must be possible to clearly justify long-term
benefit of development in at-risk areas. In this context, it is not clear what the ‘lifetime of the
development’ is, and an example table of expected lifetime for different types of
development would be helpful.

It is important that in the context of climate change, planners look beyond 100 years to
determine the flooding risk for such areas, defences should meet the standards required for
the next 100 years, as well as mechanisms put in place for their maintenance over such a
timescale.

Safe Access
CIWEM considers that there needs to be better definition of safe access. There currently
appears to be debate over whether access should be wet or dry, and the situation should be
clarified. We would emphasise however, that there is always a risk to individuals with wet
routes, as even shallow turbid water, which would otherwise be safe in terms of velocity, can
mask hazards for example open manhole covers. For this reason we would suggest that dry
access would be preferable.

Consideration of Climate Change
CIWEM agrees that allowance must be made for climate change when taking into
consideration the risk of flooding, but it is also important that the reasoning behind the use of
given allowances is explained. Allowances should also be consistently applied. Too often it
seems that there is inconsistency from the Environment Agency across its regions in the
allowances it makes, and we would welcome a national programme of Environment Agency
guidance and staff training on this.

SUDS
CIWEM is supportive of the wider use of sustainable drainage systems (SUDS) as a means of
reducing runoff. The Environment Agency has for the past five years been an advocate of
their use but there is a significant obstacle in the form of the ongoing maintenance of the
system once a development has been constructed. This has meant that local authorities are
less likely to require SUDS as part of a development. There appears to be a reluctance all
round to take responsibility for SUDS schemes and until this situation is resolved their use will be
restricted.

There are examples of solutions to this problem, e.g. in Australia where any development with
SUDS (Water Sensitive Urban Design) has a commuted sum for the ongoing maintenance of
the system in place before the development is permitted. We would suggest that such an
approach should be better encouraged in this country.

Calling-in Process
We note that relevant Government Offices are to handle cases where planning authorities
are minded to approve planning applications for a major development against a sustained
Environment Agency objection. We are unconvinced that this approach will guarantee
impartiality, given the current desire in Government to increase the pace of development,
particularly in the south and east of England. We would suggest that there should be an
independent arbitrator employed to take such decisions.




                                                                                                  3

               CIWEM, 15 John Street, London, WC1N 2EB. Tel: 020 7831 3110 Fax: 020 7405 4967
                Email: admin@ciwem.org Web Site: www.ciwem.org. Reg. Charity No. 1043409

				
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