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The Draft National Planning Policy


Framework What people have to say.....


The draft National Planning Policy Framework is a 52 page document that is set to replace a 1000 page plus document on planning policy and guidance.


It can often be seen as a postiive move when guidance documents are reduced, paving the way for quicker and more straight forward solutions. However when it comes to assessing flood risk and looking at the the potential effects of not considering all factors then there is the potential for disaster.


Does the new framework recognise the risk surrounding flooding? Local Authorities have been given an increased role in managing flood risk, and now that the guidance document PPS25 is being removed, will the LA’s have have the required specialst knowledge to assess the flood risk of potential developments.


The new Framework replaces all existing national policies and guidance, including PPS25, the Planning Policy that governs how Flood Risk is assessed.


News


This gives councils clear guidance on how to avoid development in areas of flood risk and it gives developers clear guidance on what information they need to provide. Without this Policy, each council will have to make up its own mind on how to assess and take account of flood risk The new framework states that Local Plans should only take account of advice from the Environment Agency on flooding and makes no mention of other flood risk management authorities such as Internal Drainage Boards (IDBs).


Greater risk of flooding


The proposed National Planning Policy Framework will put communities at greater risk of flooding, says the National Flood Forum.


Charles Tucker, Chairman of the National Flood Forum says “different councils have very different understanding of flooding issues. Letting them each take their own view on flooding will lead to more houses being built on flood plains and more houses with inadequate levels of protection against flooding. “


“Every one of the 150 Community Flood Groups we support and represent is put at greater flood risk by the withdrawal of PPS25. The new Framework keeps some key words from the PPS, but has removed the definitions, context and technical guidance that gives them meaning. Without definitions, the words have little value.”


“We foresee endless argument, where planners and developers tussle over the levels of protection required and barristers have a field day re-opening legal arguments closed by PPS25.”


“Will anyone know whether the houses built are adequately protected against flooding – or other communities put at greater risk? Will the uncertainty make the new houses uninsurable?”


“Does government really want to throw away a key part of the structure that helps protects its citizens from flooding?”


For further information, email: Charles.tucker@floodforum.o rg.uk


or visit their website: www.floodforum.org.uk


Doubts over Habitat protection


October 3rd marks World Habitats Day, yet there is no cause for celebration. CIWEM has serious doubts over the UK Government’s ability to protect and reintegrate vital habitats which provide a number of valuable ecosystem services in light of the new National Planning Policy Framework. A much more integrated policy approach is needed in order to halt increased habitat fragmentation, vital to increasing our resilience to the impacts of climate and demographic change.


The fragmentation of habitats can considerably undermine the integrity of whole ecosystems - reducing genetic diversity, limiting migration and reducing predators’ range. In the UK the degree of habitat fragmentation has long been recognised and the 2011 National Ecosystem Assessment found that of the 8 habitat types assessed, 30% are in decline.


The importance and value of ecosystems and the services they provide to the economy, to society and to individuals are now widely recognised, with the international TEEB study (The Economics of Ecosystems and Biodiversity) placing a value of trillions on the potential loss of ecosystem services. The recent Natural Environment White Paper offered a welcome recognition of this value and a shift in approach with the promotion of ecological networks at a landscape scale to deliver increased resilience to ecosystem pressures.


However, any optimism over the White Paper is quickly called into question in light of the draft National Planning Policy Framework (NPPF) which outwardly compromises many of the outlined objectives. The loss of regional tier planning, the removal of any protection for local wildlife sites (placing some 40,000 at risk across England) and the absence of any reference to the Nature Improvement Areas introduced by the White Paper misses the opportunity to integrate this new thinking into practical delivery via planning.


CIWEM’s Executive Director, Nick Reeves OBE, says:


“Fragmented approaches across government departments raise serious doubts over this Government’s green credentials.


A lack of


compatibility between the NPPF and Natural Environment White Paper leaves huge questions over how planning delivered at a local level will incorporate wider strategic aims. The NPPF reduces the environment to a series of discrete protected areas rather than a dynamic set of ecosystems interacting with our built environment. At the current speed of the planning reforms, England looks set on a trajectory of increasing biodiversity loss and fragmentation, further reducing the ability of this nation’s ecosystems to undertake the valuable services they provide threatening our natural heritage.”


ABI warns that Flood cover could be pulled


The ABI is concerned that reforms to the planning process will encourage building in flood risk areas. This is very likely to make flood insurance more expensive if available at all. The concern is, that with one in six properties in England are already at risk of flooding, the proposals to give local planning authorities more powers in the planning process will lead to a rise in developments in flood risk areas.


In order to reduce this risk the ABI has called on the government to ensure its reforms include requirements for:


• The regular publication by local planning authorities of any planning applications given against the advice of the Environment Agency (EA). Despite the current requirement that the EA reports on all planning applications made against their advice on the grounds of flooding, local planning authorities do not advise the EA of many of their planning decisions.


• Water companies to be statutory consultees on all development applications in flood risk areas in order to confirm the capacity of their systems to adequately drain the proposed development.


Nick Starling, the ABI's director of general insurance and health, said: "We understand the government's desire for sustainable developments, and that the Government recognises that flooding is an important consideration in the planning process. The continued availability of flood insurance is vital if the government's vision of more sustainable communities is to become reality.


"However, we are not convinced that the current proposals for planning reform are robust enough to prevent developments in flood risk areas. The drive towards giving local communities more say about what is built and where must include safeguards to ensure that developments are not built in flood risk areas, so we can avoid a nightmare scenario of unsaleable uninsurable, and uninhabitable properties."


New Code of Practice for Assessing an Managing Flood Risk in Development


The BSI has published a new code of practice (BS 8533) which gives recommendations and guidance on the appropriate assessment and management of flood risk where development is proposed in the UK.


It is intended to provide developers, and decision makers (local authorities and regulators), with practical assistance for dealing with flood risk in and around their development.


BS 8533 has been created to help the user to analyse flood risk and to guide the selection of appropriate risk management solutions. The stage at which this guide is intended for use is after initial planning considerations pertaining to the development of the site have been applied, including the Sequential Test within England and the


4


Justification Test within Wales, and after the need to carry out a flood risk assessment (referred to as a flood consequence assessment within Wales) has been established.


BS 8533 has been developed to bring together flood risk management guidance issued by the government and devolved administrations within the UK and to provide the user with recommendations that can help them to amass information for a planning application. Where applicable, this standard makes reference to the appropriate planning policies and guidance as correct at the time of publication.


This standard is intended to complement the following national planning policies and guidance for development and flood risk management in the UK.


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