Plain Dealing Revisited
Planning for Flood Resilience
Author: Sandy Forsyth |
In autumn 2021, Localis published ‘Plain Dealing – building for flood resilience’. The study took for its context the sense that development on flood risk areas sits at the intersection of the housing and climate crises. In the three years since publication 22 named storms have made impact on the UK and Ireland – In 2023 alone, weather-related home insurance claims reached a staggering £573m in the UK, with flood damage following storms accounting for £286m.
Labour’s 2024 general election win was delivered on pledges to greatly increase housebuilding, requiring a careful balancing of climate resilience measures with robust planning policies and transparent decision-making. Plain Dealing Revisited reviews the policy landscape for flood resilience in new and existing developments, takes stock of the capacity for strategic management across levels of government and provides practical policy recommendations to ensure climate resilience can be built into the national effort to address the housing crisis.
Download the executive summary and recommendations
Download the report data appendix
Key points
The existing policy framework and future changes
Many areas of the UK are naturally flood prone, and in the context of repeated calls for continued urban development programmes to meet pressing housing and supporting infrastructure needs, new developments are influencing risk levels. Despite a rigorous and multi-stage approach to flood-aware development and the mitigation of flood impacts by risk management authorities, a combination of crumbling flood defences and the consent of development on functional floodplains, even at times against the Environment Agency’s advice, means that millions of properties in England remain at risk.
The new government have pledged an extensive review of capital spending, which observers have criticised as lagging behind the pace of investment needed for urgent resilience measures due to issues such as inflation and poor public sector capacity. The new approach also includes a ‘COBRA-style’ flood resilience taskforce to meet before every winter’s peak flooding season to coordinate and target cross-sectoral response.
The local role in ensuring resilience
Local resilience measures are especially important given the housebuilding target of 370,000 homes a year. The government are taking a hardline approach to housing supply under proposed reforms, with local authorities seeking a lower housing requirement having to demonstrate that they have spared no effort to find alternative land supply, including local green belt boundary review. From the planning perspective, the National Planning Policy Framework, although not a legally binding document, is averse to floodplain development. Referring to ‘inappropriate development’, the NPPF suggests that planners should direct development away from areas at highest risk and that all plans apply a sequential test followed by, if necessary, an exception test, in order to prioritise the least-worst location for development.
Appropriateness, however, is a subjective quality. Despite reasonable precautions, it remains that there is no existing law against the granting of planning permission for and construction of homes in areas at high risk of flooding, and the Environment Agency compiled 267 instances of homes granted planning permission against their advice on flood risk in the year 2022-23 alone. While the presumption against development may seem clear from this perspective, opinions in favour of floodplain development are also held by many experts.
Development in flood-risk areas
In Plain Dealing, Localis observed where new, floodplain development was occurring in the twelve local planning authorities with more than ten percent of properties already at a greater than 1 percent risk of flooding, as recorded in 2020. For the purposes of this report, we have revisited these authorities to assess the ongoing pattern of development in areas at an existing high risk of flooding. In the first half of 2024, 1,006 dwellings were given planning approval in the 12 local authorities with the highest percentage of properties already at risk. Adding in developments which were approved in previous years and continued to move through the planning system in the first half of 2024 reveals a further 6,110 dwellings with planning approval, amounting to a total of 7,116 dwellings in the planning pipeline for these authorities. Additionally, 2,389 new dwellings were granted planning permission on previously developed land or as a result of change-of-use applications, and 280 of those were new applications this year.
Insurance in a flood-risk area
The year 2023 saw a near 10 percent increase on 2022 home insurance totals – an increase, notably, driven by weather-related damage. In recent months, home insurance providers across the board have flagged the impacts on insurance pricing due to storms, particularly following the storm-intense 2023/24 winter season, with the Association of British Insurers calling for more to be done to support resilience in communities as the value of the average home insurance claim rose by 64 percent in only one year.
The future of home insurance for at-risk properties therefore remains an issue. Furthermore, public awareness of flood risk and of the necessity of property-level flood resilience and insuring properties proactively, ahead of flooding, needs widespread improvement across the country. Insurers themselves can implement better awareness programmes, but resourcing needs also to be extended to Lead Local Flood Authorities and other public sector stakeholders to allow this kind of proactive engagement and shore up individual and community-level resilience across the country.
Recommendations
- The Flood Resilience Taskforce should be given an expanded remit to examine the current state of existing flood defences, improve public information and review how effectively resilience measures are implemented in the planning system.
- The Minister for Water and Flooding, currently located within Defra, should be given a joint brief covering Defra and MHCLG, with the responsibility of overseeing the taskforce and implementing its recommendations.
- The Environment Agency must have its capacity greatly improved: to ensure the maintenance of flood defence assets, both public and privately held, and to enforce regulations in planning. The Taskforce should be given a remit to examine how this can be achieved.
- The Taskforce must work to improve the availability and accessibility of data on floodplain development – current transparency measures around planning decisions are not sufficient for understanding aggregate flood-risk across development.
- To help combat poor awareness of flood risk, the Taskforce should work to develop a live system providing responsive flood-risk category certification for new buildings to increase risk awareness among homeowners and occupiers.
- The Planning and Infrastructure Bill as well as the revised National Planning Policy Framework present an opportunity to consolidate and reinforce planning resilience measures.
- While it currently exists as a guideline in the NPPF, the sequential test for floodplain development must be made law, to ensure that new development takes place in the most strategically appropriate places for national flood resilience.
- To ensure that an area’s aggregate flood risk is being considered, lead local authorities should be consulted by law on all developments of more than two dwellings on floodplain land, and total permissions of all sizes should be periodically reviewed.
- In the context of greater green belt urbanization, surface water drainage requires specific consideration in the National Planning Policy Framework.
- The Flood Risk Assessment process should be reviewed, ensuring that assessments are fully inclusive of not only dwellings and businesses, but also the surrounding environment and infrastructure, as well as emergency response.
Research kindly sponsored by:
