Flood Risk Assessments and PPG25

Flood Risk Assessments: email sent to Environment Agency dated 22 March and their letter of reply dated 15 April 2004. This exchange of correspondence highlights inadequacies in the PPG25 planning guidance for controlling developments in flood plains especially in 'developed areas'.

Jo Clarke
Env Agency
Exminster.

Thank you for your letter of 19 March ref: DC/2004/001490 re: Hamilton Garage Sidford.

As a part of the Flood Risk Assessment I assume it is necessary to take into account local features that could have a bearing on the risk to specific properties. I highlighted several factors in my letter to you and would be pleased to discuss further on site with whoever from your Agency assesses whatever is submitted. I assume the FRA is undertaken commercially (with a bias towards what the developer wishes to hear?) and then assessed by the EA??

Anytime after 2 April would be convenient for me - please pass this email to whoever is the appropriate person.

I have looked briefly at parts of PPG25: in respect of Table 1 could you tell me if the EA presently classify this small area of Sidford (with its particular known problems) as 'High risk' and if so as a 'developed' or 'undeveloped and sparsely developed area'. I may have misunderstood the logic here: what matters is surely the risk to the proposed property and any neighbouring properties. Loss of storage capacity in this small part of the flood plain could be significant. Table 1 seems to suggest that further development in already developed areas is less severely restricted than in less developed areas, despite that the risk to existing properties may be greater. It might save some correspondence if I could speak to one of your officers on site.

Dr Stephen J Wozniak

In a subsequent telephone conversation Ms Clarke agreed that parts of PPG25 were poorly drafted and could lead Planning Authorities to grant permission for development in 'High Risk' areas even where the risk of flooding of existing properties might be increased as a result. Her formal letter of reply is reproduced below. There is clearly an issue here of poor quality guidance from central government: it needs addressing by Ministers.

Dear Dr Wozniak

ENV. AGENCY REF. NO: DC/2004/001490.
DEVELOPMENT PROPOSALS AT HAMILTON GARAGE, ENGLANDS CLOSE,
SIDFORD.

Thank you for your e-mail of 22nd March 2004. I apologise for the delay in response.

Under the terms of Planning Policy Guidance (PPG) 25 (paragraphs 20 and 60), it is the
responsibility of those promoting development to provide a flood risk assessment (FRA). In the normal course of events this Agency will consider the submission of any such assessment and provide advice on the matter to the Local Planning Authority. The quality of FRA's varies considerably. In this case, our engineer, Mr Stephen Moore, will consider any
submitted FRA. While he is happy to meet with you on site to discuss the proposed
development in relation to flood risk, pressure of work means he is currently unable to
consider attending a site meeting until after April. I apologise for this but we are currently
under some stress regarding the delivery of other key government advice.

Areas deemed to be at risk of flooding in the once in 100 year flood conditions are likely to be regarded as "High risk: developed areas" under the terms of Table 1 of PPG 25. This is
properly a matter to be determined by the Planning Authority however. It is the case that the
proper determination of the flood zones set out in Table 1 is open to a degree of interpretation and this can in turn, lead to confusion and disagreement on the proper application of the government's advice.

I trust this is of assistance.

Yours sincerely

Miss J L Clarke
Planning Liaison Officer

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