Updated Practice Guide presents additional challenges

The Practice Guide which accompanies the Planing Policy Statement, PPS25, was re-issued in December, 2009. Whilst much of it remains the same or clarifies previous guidance, there are two distinct areas of change which will provide a greater challenge to development in flood risk areas.

Although PPS25 has always recognised the need to consider all sources of flooding and to adopt a sequential approach to avoid it, the general application of the guidance has been to restrict the sequential test to tidal and fluvial flood risk. This was primarily due to the lack of any maps identifying the spatial distribution of flood risk for other sources of flooding.

With the production of the Surface Water Flood Map by the Environment Agency, the Practice Guide now advocates that the sequential test also be applied to surface water flood risk. Since this map is only available to the Environment Agency and Local Planning Authorities and will not be distributed to anyone else an early assessment of risk becomes more difficult as one would not know the risk until these bodies had been consulted.

It is important that this information is made public in the same way that flood zone maps are available online to ensure that these risks can be adequately assessed by developers and their consultants.

Another important change relates to safe access and egress. The previous version of the guide correctly recognised that there would always be exceptional cases where, in existing developed areas, a safe access could not be provided and where it would be necessary to redevelop and manage risk in another way. This explicit recognition has now been removed and thus arguably any development which cannot provide some latitude but it is likely that the Environment Agency will adopt a fairly rigid interpretation of being either safe or unsafe.

We believe that if correctly applied this guidance still provides scope for appropriate floodplain development to be promoted. However, this guidance is still untested and over the next few months we will continue to provide updates regarding the implementation.

Tags: flood risk, PPS25, Practice Guide