Don’t Build on Flood Zone says Environment Agency

The Environment Agency being the British Government body required to control, monitor and advice on all matters affecting ‘Floods’ says : Get the location of new housing right: We need to avoid building homes in places where we will regret doing so, such as in areas at risk of flood.Sustainable communities: position statement by Environment Agency Key issues

To improve and protect the environment, we need to plan the development of new communities well. By taking environmental issues into account, we can make sure that we build homes in the right places and in the right way, for the benefit of both current and future generations.

The Housing Green Paper was published in July 2007. In it, the Government has set a target to increase the rate of house-building in England to 240,000 homes per year. This means two million homes by 2016 and three million homes by 2020. In Wales, the Welsh Assembly Government has committed itself to building 200,000 new homes by 2026.

The Government already has plans for 1.6 million homes, through regional plans and the current Growth Areas (including the Thames Gateway, Ashford and Milton Keynes-South Midlands). In October 2006, the Government announced 29 current New Growth Points (NGPs) that will result in 100,000 extra homes by 2016 . The Housing Green Paper commits to another round of New Growth Points (NGPs). This will result in 50,000 extra homes. For the first time, the NGP initiative will also cover the Northern regions. There will also be at least five Eco Towns by 2016 and 10 Eco Towns by 2020. In total the Eco Towns could provide up to 200,000 additional homes by 2020.

For this housing growth to be sustainable, the environmental pressures on flood risk, water supply and treatment, waste disposal facilities and greenhouse gas emissions need to be addressed. The Environment Agency can help. Our report Hidden Infrastructure: The pressures on environmental infrastructure and the supporting policy messages, recommend four ‘pillars’ for sustainable growth:

Get the location of new housing right: We need to avoid building homes in places where we will regret doing so, such as in areas at risk of flood or where water quality and water resources are already at or approaching environmental limits.

Joined-up and long-term approaches to planning: To ensure strategic and joined up planning frameworks exist for all types of environmental infrastructure.

Improve resource efficiency, reduce demand for drainage, and greater flood resilience: To promote more ways of managing and reducing the demand for new environmental infrastructure, managing demand for drainage and increasing flood resilience.

Secure funding for environmental infrastructure early: Get clear funding streams and allocate costs to polluters, developers, consumers and the taxpayer using clear and defensible principles.

The Environment Agency’s Role

The Environment Agency provides, regulates and advises on environmental infrastructure. We have a lot of experience on how to plan for, fund and regulate environmental infrastructure – and evidence on how it performs. We are, for example, the primary regulator for the water environment and competent authority for the implementation of the Water Framework Directive and Water Act. We regulate abstractions from, and discharges to, the water environment in England and Wales.

Our Water Resources Strategy sets out a 25-year framework for planning for water demand and new resources. We regulate the environmental aspects of water-company plans. We advise Waste Planning Authorities, and we report on the state of the environment. We also deliver flood risk management across England and Wales, and we are involved in the new system of Regional Spatial Strategies, Local Development Frameworks (Local Development Plans in Wales), and their associated Sustainability Appraisals.

The Summer 2007 floods highlighted issues relating to urban flooding. In urban areas, the risk of flood comes from a mix of factors that are difficult to assess and that may vary over time, combined with rapid building development. It is therefore far more difficult to characterise the risk of flooding from sources other than rivers or the sea. Many different organisations, including the Highways Agency, local authorities and utilities, play a role in managing urban flood risk. No organisation has been responsible for a comprehensive assessment of the risks of urban flooding.

The Environment Agency is the competent authority for the forthcoming EU Floods Directive. We believe that the Government should extend our role to include the strategic overview for inland flooding. It needs, though, to specify this role carefully, and clearly state the balance of responsibilities between the Environment Agency and other organisations.

We work closely with the Department of Communities and Local Government on housing growth. We give them initial, high-level assessments of the environmental implications of the possible New Growth Points and Eco Towns. We advise them on what further work may be required to show that a given proposal is environmentally acceptable.

Solutions – we call for:

1. Get the location of new housing right

Rigorous assessments of the environmental impacts and the viability of infrastructure dependent solutions before plans for housing growth are adopted.

Local Planning Authorities (LPAs) should rigorously apply the Government’s planning policy and guidance on development and flood risk (PPS 25 in England, PPW and TAN 15 in Wales), which steers development towards areas of lowest flood risk first. LPAs should refuse planning proposals that increase the risk of flooding to others.

Fuller use of the provisions under PPS25 for the Environment Agency and local authorities to define critical or problem drainage areas in low flood risk zones where there are potential surface water and sewer flooding problems.

2. Joined -up and long term approaches to planning

In their plans, water companies need to forecast new housing development (that accounts for Growth Area, New Growth Point and Eco Town proposals) better, and in a way that is consistent with the Regional Spatial Strategies (RSS).

Water companies should produce 25-year plans for sewerage and wastewater infrastructure that look beyond the usual five-year business planning horizon. Ofwat has already asked the water companies to produce Strategic Direction Statements (SDSs) to inform the 2009 Water Price Review. The SDSs present an opportunity to make sure that water companies include long-term plans for the waste water infrastructure that new housing growth will need.

Local authorities produce Strategic Flood Risk Assessments (SFRAs). These assess all types of flood risk within a given district. Where an SFRA identifies concerns with surface water and sewer flooding affecting existing properties, a Surface Water Management Plan (SWMP) should be initiated involving the relevant local stakeholders.

Utilities, regulators and relevant agencies should be duty-bound to co-operate with local authorities in providing information for SFRAs and producing and implementing SWMPs.

In Growth Areas and New Growth Points, water cycle strategies should be encouraged where there are water management concerns. These studies assess the environmental and infrastructure implications for water resources, waste water and flood risk management to help shape the development of these new communities.

3. Improve resource efficiency, reduce demand for drainage, and greater flood resilience

In areas defined as seriously water-stressed, water companies should use their ability to meter on compulsory basis. Metering can save at least 10% of household water use. We want to see the majority of homes in seriously water-stressed areas such as the South-east metered by 2015. Because of the number of meters being installed, we recognise that some companies may not be able to achieve full compulsory metering until 2020.

Targets for water efficiency may help water resources to be used more efficiently and sustainably.

Significant new housing developments, such as Eco Towns, should be exemplars for sustainable water, energy and waste use. For example, we have worked with CLG and Defra to examine the feasibility of moving towards water neutrality in the Thames Gateway.

Ownership and responsibility for the maintenance of sustainable drainage systems (SUDS) should rest with a durable, accountable organisation that can be expected to be financially able to meet its responsibilities in the longer term. SUDS can help to improve water quality and reduce the impact of urban flooding caused by heavy rainfall. They do this by mimicking natural drainage systems and slowing the movement of surface water. Options include green roofs, permeable surfacing and ponds. Both water companies and local authorities should encourage the use of SUDS.

Government should strengthen the relevant parts of the Building Regulations so that these include measures for flood resistance (stopping water from getting in) and resilience (reducing the damage and helping recovery when water does get in).

4. Secure funding for environmental infrastructure early

Funding of environmental infrastructure to support innovation and long term planning, including maintenance and renewal.

A wide range of funding options to be considered through Section 106 planning agreements and the proposed Planning Gain Supplement.

Investment in flood risk management to continue to increase from £800 million in 2010-11 to £1 billion in the year 2013-14.

Water and waste water infrastructure is funded by the private sector, not by the Exchequer. The next 2009 Water Price Review will therefore be particularly important to make sure that new and expanded water and waste water infrastructure is provided for.

Reform the charges that developers pay for connecting domestic properties to water and sewerage services for the first time. The charges could help promote more water-efficient housing in accordance with the Government’s Code for Sustainable Homes.

Taxation and incentives should support sustainable waste management options.

Background – Top facts

In the South-east, there are seven places where the capacity of sewage treatment works will limit development. In addition, 45 other works will need to operate to a higher standard in order to avoid harm to the local environment.

Providing sewage treatment for the new housing proposed in the South-east Plan will cost £7.5 billion over the next 20 years.

The average cost per proposed house in the South-east Plan for flood risk management, water quality, water resources and waste is £20,000.

During 2005-06, sewers flooded nearly 5,000 properties, and more than 3,500 million litres of water a day were lost through leaks .

About 335 million tonnes of waste (and rising) are produced in the UK each year.

The value of property and assets in England and Wales in the floodplain is currently about £230 billion. The Association of British Insurers estimates that the additional flood risk in growth areas could increase by up to 12 times, to £830 million per year by the 2080s . We must adapt to the unavoidable impacts of climate change.