The HBF supports, in principle, the policy to direct new development to low to medium risk areas. However, the HBF believe there are a number of fundamental issues, whiich must be addressed if the development industry is to have confidence in the operation of this approach.
Firstly, TAN 15 and its risk-based approach to land allocation must be compatible, as far as possible, with other Assembly objectives for sustainable development. Due to the nature of settlement patterns, our towns and cities have developed around river systems. Advice in PPW is to concentrate development within and adjoining urban areas promoting sustainable patterns of development, which are governed in the main by public transport accessibility criteria.
As such there are numerous circumstances where the approach advocated in TAN 15 will be diametrically opposed to the search sequence set out in paragraphs 2.5.2, 2.72, 9.2.8 and 10.2.10 of PPW. As currently drafted, this issue is conspicuous by its absence from the TAN. Unless this issue is addressed in the final version of the TAN the process and purpose of land allocations will be rendered inoperable and meaningless. Either the TAN addresses the weight to be given to flood risk or if the TAN over-rides all other considerations as it appears to, then PPW needs to be amended to reflect this position. The TAN should assist in the delivery of PPW objectives many of which are longstanding and well established. The Assembly needs to recognise that withdrawal from development in high-risk areas will significantly harm the delivery of its wider social and economic policy objectives.
Secondly, for both the public and private sector to have confidence in the risk-based approach to land allocation the methodology used to identify areas of risk must be fit for its purpose. At present there is grave concern regarding the validity and appropriateness of the maps in accurately defining areas at risk of flooding. Within the context of the risk based approach the maps have a high status therefore they need to be the best possible and fit for their purpose.
Finally, the HBF welcomes the risk based approach as this will generally be to the benefit of future development, which would be guided to areas of reduced hazard without the need for costly engineered defences and marketing problems. However, it must be recognised that in the short term the TAN will significantly restrict the amount of land currently available for development. This will result in many local authorities housing land supplies being severely depleted leaving them open to risk of appeals. The TAN will hold up UDP preparation at a time when the Assembly is encouraging speedy adoption. The HBF is also concerned with the likely adverse consequences for existing development in the areas identified as high risk both in terms of insurance costs and property values. As a result of the TAN these areas will be blighted. Most are already suffering from decline and are in need of regeneration.
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