I have made my views on the folly of building more homes in floodplains very clear for many years now. These areas are where the rivers naturally go when they are full. Too many householders are already living at risk of the devastation flooding can bring, so why on earth would we want to put even more people in the same position? Sadly, I believe this is exactly what could happen, if the proposed reforms to the planning system do not take into consideration the huge importance of floodplains and the very reason they are there.
For historical reasons, many of our towns and cities have grown up on and around rivers and estuaries – places such as Hull exist because we built on floodplain areas. Our communities need to grow and thrive, but this should only be done as a last resort, and in the safest and most sustainable way possible. Building yet more homes that are likely to flood should be avoided,
Of course, we don’t live in an ideal world and I realise that a lot more housing is needed in this country. But my worry is that too much building has already happened on land that is known to be at the highest risk of flooding (known as Zone 3*). According to an analysis of government data** earlier this year, this is 10% of all new homes built in England since 2013.
Even where some form of flood ‘defence’ has been built, a residual risk remains – because any defence can still be overtopped. That means that around 84,000 families and individuals currently risk going through the same appalling disruption that my family did on several occasions – and I wouldn’t wish that experience on anyone.
The current system is that all new developments have to gain planning permission from the local authority. These decisions are guided by the National Planning Policy Framework (NPPF), and this makes it clear that building in areas at risk of flooding is to be avoided unless no ‘reasonably available sites exist’. In those cases, measures to reduce the risk are recommended, so that the development will be safe for its occupants, e.g. by raising the floor levels above the likely water level (resistance) or by making the buildings themselves flood resilient/ repairable. Usually, planning permission will only be granted once the local authority is satisfied that all this will be done.
However, this approach is not backed up by the Building Regulations, effectively making this approach voluntary, rather than a statutory requirement. Similarly, there is an ‘expectation’ that sustainable drainage measures will be included in new developments, to reduce the risks from surface water flooding – but this too is non-statutory in nature, meaning the onus falls upon the developer to follow this through, but under no binding or legal requirement.
How would the new proposals change all this? Surely more ‘teeth’ are being given to the planners to improve the situation? Shockingly, the reverse appears to be the case. According to the government’s own website, builders will no longer need a normal planning application to: “demolish and rebuild vacant and redundant residential and commercial buildings if they are rebuilt as homes”.***
We don’t yet know what a ‘non-normal’ planning application means. But if it translates to buildings that already stand in the floodplain being replaced by, or converted into, homes that are going to flood, then I am horrified. I can imagine that an unscrupulous developer would be rubbing their hands in anticipation, if this reduces the need to spend money on building defences, or including any form of flood resilience The checks and balances included in the NPPF, which are usually applied via the planning process, need to be strengthened, not side-stepped!
In my view, the government needs to think very carefully about the possible consequences of these changes where flood risk is concerned. Yes, we do need more housing, but people need safe places to live. I sincerely hope the detail of the proposals, when released, will show that my fears are unfounded or encourage those with an interest to review and respond to the Government’s consultation, which closes at the end of October.
Mary Dhonau OBE
* Definition: 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 (including the functional floodplain). https://www.gov.uk/guidance/flood-risk-and-coastal-change#flood-zone-and-flood-risk-tables
**Guardian 2020: https://www.theguardian.com/environment/2020/feb/19/one-in-ten-new-homes-in-england-built-on-land-with-high-flood-risk
*** https://www.gov.uk/government/news/pm-build-build-build
For historical reasons, many of our towns and cities have grown up on and around rivers and estuaries – places such as Hull exist because we built on floodplain areas. Our communities need to grow and thrive, but this should only be done as a last resort, and in the safest and most sustainable way possible. Building yet more homes that are likely to flood should be avoided,
Of course, we don’t live in an ideal world and I realise that a lot more housing is needed in this country. But my worry is that too much building has already happened on land that is known to be at the highest risk of flooding (known as Zone 3*). According to an analysis of government data** earlier this year, this is 10% of all new homes built in England since 2013.
Even where some form of flood ‘defence’ has been built, a residual risk remains – because any defence can still be overtopped. That means that around 84,000 families and individuals currently risk going through the same appalling disruption that my family did on several occasions – and I wouldn’t wish that experience on anyone.
The current system is that all new developments have to gain planning permission from the local authority. These decisions are guided by the National Planning Policy Framework (NPPF), and this makes it clear that building in areas at risk of flooding is to be avoided unless no ‘reasonably available sites exist’. In those cases, measures to reduce the risk are recommended, so that the development will be safe for its occupants, e.g. by raising the floor levels above the likely water level (resistance) or by making the buildings themselves flood resilient/ repairable. Usually, planning permission will only be granted once the local authority is satisfied that all this will be done.
However, this approach is not backed up by the Building Regulations, effectively making this approach voluntary, rather than a statutory requirement. Similarly, there is an ‘expectation’ that sustainable drainage measures will be included in new developments, to reduce the risks from surface water flooding – but this too is non-statutory in nature, meaning the onus falls upon the developer to follow this through, but under no binding or legal requirement.
How would the new proposals change all this? Surely more ‘teeth’ are being given to the planners to improve the situation? Shockingly, the reverse appears to be the case. According to the government’s own website, builders will no longer need a normal planning application to: “demolish and rebuild vacant and redundant residential and commercial buildings if they are rebuilt as homes”.***
We don’t yet know what a ‘non-normal’ planning application means. But if it translates to buildings that already stand in the floodplain being replaced by, or converted into, homes that are going to flood, then I am horrified. I can imagine that an unscrupulous developer would be rubbing their hands in anticipation, if this reduces the need to spend money on building defences, or including any form of flood resilience The checks and balances included in the NPPF, which are usually applied via the planning process, need to be strengthened, not side-stepped!
In my view, the government needs to think very carefully about the possible consequences of these changes where flood risk is concerned. Yes, we do need more housing, but people need safe places to live. I sincerely hope the detail of the proposals, when released, will show that my fears are unfounded or encourage those with an interest to review and respond to the Government’s consultation, which closes at the end of October.
Mary Dhonau OBE
* Definition: 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 (including the functional floodplain). https://www.gov.uk/guidance/flood-risk-and-coastal-change#flood-zone-and-flood-risk-tables
**Guardian 2020: https://www.theguardian.com/environment/2020/feb/19/one-in-ten-new-homes-in-england-built-on-land-with-high-flood-risk