The results of a Twitter poll hosted by Modus and reported in the April 2020 issue revealed some interesting responses from the profession.
In answer to the question ‘Should we still be building on floodplains?’ it seems that the profession is evenly split, with 44% saying not in any circumstances and 48.3% responding only if well designed. Of the remainder, only 1.1% said yes because the need outweighs the concerns, and 5.7% felt that such development should be used for non-residential purposes.
This dichotomy is reflected in the UK housing market at large. Yet there is no equivocation in the minds of the planners who are driven by the National Planning Policy Framework (NPPF). Development on floodplains is heavily resisted by the environmental agencies in England, Wales, Scotland and Northern Ireland. The NPPF is in favour of the regulators and seeks to drive inappropriate development away from areas of highest risk – see paragraph 155 of the framework.
If a sequential, risk-based approach to the location of development – taking into account the current and future impacts of climate change – is undertaken, the project has to ‘be made safe for its lifetime’. That’s an awfully long time with no clear end date, which necessitates a conservative approach.
As a result, development is by default encouraged on areas with the lowest risk of flooding. Given that many cities, towns and villages were built on floodplains by their forebears, where can this take place? There are difficult questions that local authorities have to answer if they are to meet the challenge of building the number of new homes that are needed each year. This is driven in part by the annual New Homes Bonus, which is a grant paid by central government to local councils designed to incentivise housing growth in their areas.
With the conflict over greenfield versus brownfield it may be tempting to consider a one-size-fits-all solution and build on brownfield sites. But there are major issues with this strategy. Firstly, many of the strategic brownfield sites have already been built on. Secondly, because they were the locations of older industries, they tended to occupy floodplains since much of their produce was transported by ship, canal or train. Trains commonly follow the course of rivers into the urban areas too.
“Insurance is a major problem even when new homes can be built safely on floodplains”
A flood ghetto is where values fall because of flooding events, resulting in the inability to raise a mortgage or afford insurance at an economic cost. Only those who have the cash can afford to buy such properties if there is no mortgage company prepared to support a full market value. Such properties may appeal to those seeking to exploit vulnerable people unable to get on the housing ladder. These properties start to fall down the social economic ladder and become a major barrier to social mobility.
Insurance is a major problem even when new homes can be built safely on floodplains. This is because the insurance industry is under no obligation to insure new homes for flood risk and has not done so since 1 January 2009. This is due to the collapse of the statement of principles between the insurance industry and UK government after the disastrous 2007 floods. This collapse occured because of the failure of successive governments to keep pace with the level of investment needed to maintain, build and improve flood defences. All of this was then exacerbated by the decision to cut capital expenditure in the years after the 2007-2008 financial crash.
In 2014, Flood Re was set up as a joint initiative between the government and insurers with the aim to make the flood cover part of household insurance policies more affordable, and in recent years the government has also increased capital expenditure for flood defences.
However, Flood Re only supports 350,000 homes in the most severely affected areas, and new homes are excluded. In addition, despite the increased expenditure, the UK is still massively behind the capital expenditure curve needed to bring its defences up to date, and this is without considering the impact COVID-19 is likely to have on capital budgets.
Many will point to the Netherlands as an example of best practice, and rightly so. Dutch engineers have been continually developing engineering techniques to protect their land, which enabled the country to become one of the most successful economies in Western Europe. This process began in the 9th century and continues to this day. The Delta Works, for example, consists of 13 sections, which together form the largest flood protection system in the world at a cost of 5bn euros between 1953-1997, with the Dutch government raising 250m euros per annum in flood taxes to fund ongoing works.
Fishlake is a small Yorkshire village to the east of Doncaster, in an area of historically peaty land that regularly flooded. In 1625 a Dutch drainage engineer Cornelius Vermuyden was commissioned by King Charles I to drain the fenland. Sadly, the lack of investment in drainage infrastructure over the subsequent 375 years meant that the village became vulnerable to inundation which is precisely what happened in November 2019.
In the last couple of years, government has been working with many stakeholders to develop flood resilience techniques in the built environment once flooding has occurred or where it may occur. Yet on a recent walk in Fishlake, there was no evidence of this having been applied and only soggy sandbags remain.
Government policy is to make homeowners aware of their flood risk and to use the techniques of flood resilience to make their properties adapt to the risk of flooding. The issue is that this may be necessary not only to obtain flood insurance in the future but also for properties that cannot get insurance. This is because the pool of global insurance for markets to draw on is getting smaller and smaller as increased demands are placed on it. In the big scheme of things insurance is likely to be thin on the ground anywhere on the globe.