Future Flood Risk in England: Committee on Climate Change Report

The recently published report ‘Climate change – is the UK preparing for flooding and water scarcity?’ an Adaptation Sub-Committee (ASC) Progress Report of the Committee on Climate Change, could not have asked for better timing really. The ongoing unseasonal rain (and by rain I mean torrential downpours rather than light summer showers) has brought the issue of flooding to the forefront of many people’s minds, not least those inundated with dirty brown flood waters. The headline grabbing pieces of the report are:


• floodplains have been developed faster than anywhere else in England over the past decade; one in five properties in floodplains were in areas of significant flood risk

• the current ‘build and protect’ policy will leave a legacy of rising protection costs; current levels of investment in flood defences will not keep pace with increasing risks with the number of properties at significant risk of flooding double by 2035

• increasing investment in flood defences and property protection measures could halve the number of properties at risk by 2035 (relative to current levels)

The recommendations of the report in relation to flooding (in the executive summary and helpfully laid out in a box on page 17) sound reasonable but they need to also be looked at in the light of the government’s recent modernization of planning policy (National Planning Policy Framework) which highlights the needs to undertake major and sustainable development in the UK in the near future. The ASC report advises that for flooding robust and transparent implementation of planning policy in flood risk areas is required and that local authorities should be consistent and explicitly takes into account long-term risk of flooding when deciding the location of new developments (page 17 of the report). In addition, there should be support for sustained and increased investment in flood defences by both private and public sources as current spending will not keep pace with the increasing risk. Failing increased expenditure, ways to manage the social and economic consequences of increased flood frequency should be identified. Lastly, there should be increased enabling of the uptake of property-level measures to protect against floods and encouragement of the increased use of sustainable drainage systems to manage surface water.

The National Planning Policy Framework highlights the importance of sustainable development particularly of housing and the importance of community involvement. The ASC report even recognises this on page 12 when it states that ‘Development in the floodplain may be rational decision in cases where the wider social and economic benefits outweigh the flood risk, even when accounting for climate change’ but then adds that in a review of 42 recent local development plans there was mixed evidence of transparency from local authorities in terms of locating development on areas other than floodplains and in including the long-term costs of flooding associated with climate change. So no cosnsitent approach to the issue yet.

So how do you decide (and who decides) if development on the floodplain is worth it or not? The decision seems to be located at the local authority level where contradictory messages are being delivered – develop sustainably (whatever that means) and don’t develop there unless you absolutely have to. There is also an assumption that the decision can be rationalised, presumably using cost-benefit analysis. This puts the valuation of property, the environment, business and infrastructure at the centre of any argument. How does this square with the ‘sustainability’ issues raised in the National Planning Policy Framework? Even worse it is not necessarily the current valuation that will be important by the future valuation of both the land and its use as well as the costs of clearing up flood damage. How do you work this out in a consistent and mutually agreed manner for the whole country for every land-use or potential land-use? Even if the local authorities made their valuations explicit would every stakeholder agree? What of localism as well? How much input will communities have into the decision-making process if valuation is the central pillar of decision-making for housing? Can they, the communities, compete in any discussion with the complicated economic modelling available to local authorities?

An interesting aspect of the report is the focus on ‘property-level protection measures’ by which they means things such as door guards and airbrick covers which the report points out require a take-up rate increase of 25-30 times by 2037 to reach all 200,000 to 330,000 properties that could benefit from their use. Although the report discusses these measures in combination with government investment as being a means of reducing flood risk I do wonder if this is more evidence of the ‘moral hazard’ argument coming into the discussion. In economic theory this refers to the tendency to take undue risks when the costs of those risks are not borne by the individual (or entity) taking those risks (a nice discussion of this idea can be found on Wikipedia – (I am not adverse to using this source if it is well done but wouldn’t advice it for any of my students reading this!) Property-level protection measures seem to throw responsible for tackling the risk (and increased risk of flooding) onto the property owner. Although not put into these words, does that mean it is their fault? They brought the house there, so the risks are theirs to bear? They have to implement property-level protection measures or else why should anyone else help them, such as insurers or local authorities? Odd when developers are allowed to develop on floodplains and then sell houses on – do home buyers have choice in where to buy if housing development is concentrated in floodplains or if those are the only locations they can find houses cheap enough (or in the right price range) for them to buy? Where exactly does responsibility for living in a floodplain lie?