There have been several attempts over the last 20 years to better integrate water resources planning into development planning and decision making in the UK. Recently, the context for planning decisions and how they are made has been significantly modified by enactment of the National Planning Policy Framework (NPPF) in 2012, which replaced hundreds of pages of detailed technical guidance with just 65 pages of guidance. Although the key ‘water for planning’ guidance under the old planning system, Planning Policy Statement 25: Development and Flood Risk (PPS 25), was partially reinstated in a March 2014 interim technical guidance note, much more needs to be done to support water sensitive urban planning. For example, the current system says nothing at all about resilience in the face of non-flood related water hazards, such as drought or water quality challenges. Nor does it address other water related ‘ecosystems services’ (a term scientists use to describe the different functions performed by natural environments, specifically: provisioning, supporting, regulating and cultural functions) which could usefully be part of an innovative way of integrating water into development planning. As an example, more proactively managed urban water flows could provide benefits such as better biodiversity, recreational amenities and mitigation of the tendency of built up areas to be hotter than surrounding natural environments (the urban heat island effect).
NPPF mentions water only briefly:
Paragraph 94. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk, coastal change and water supply and demand considerations.
Paragraph 165 of NPPF mentions River Basin Management Plans as part of the evidence base that should inform Local development Plans.
Paragraph 178 of NPPF requires joint working between local authorities to be done diligently.
Take away the Interim Technical Guidance discussed above and it is doubtful whether these brief statements can adequately get the job done.
Other recent legislation such as the EC Water Framework Directive (2000), the Flood and Water Management Act 2010 and the Water Act 2014, have had an effect on planning for water in our towns and cities. To understand the effect of these multiple changes we must make realistic evaluations of the pressures planners are under. A blind belief that the market will somehow solve the problem of how to integrate water into planning decisions just won’t deliver the right outcomes.
The harsh reality is that the combined result of the water legislation mentioned above and the NPPF, are unlikely to be sufficient to deal with water in all its aspects effectively in the development and planning process.
Flooding and drought have been national issues on several occasions in recent years. It is always worth remembering that we are simultaneously at risk of both; before the floods of winter 2014, came the “environmental drought” of 2013, and before the floods of July 2007 we were also planning drought measures such as hosepipe bans and other limitations on water use. A lot has been said about the need to consider water effectively in urban planning and the development process, but the basic issues of non-integration remain.
We need to ask some vital questions. By 2020, will we have made our built environment significantly more resilient, contributing less to and suffering less from flooding? Will there be adequate water resources for our household, agricultural and industrial needs across the country? Will we have sufficiently reduced the energy intensity of our water supply and use as an important part of de-carbonising the economy? So far it is looking as though we are only making very limited progress at the very edges of these questions.
There are real problems with the way in which water is conceptualised as an issue and then dealt with in environmental management in the UK. Water is by its very nature not something that can be just another planning consideration a long way down a list of many other such considerations, there are circumstances where it must take precedence over other concerns such as housing need. It cannot be addressed properly if it is an add-on after other considerations have precluded important water security and sustainability options. Water issues cannot be dealt with effectively if they are left to the point of individual planning decision; the strategic framework has to set the right context. That strategic context must set out a robust framework that is supported by statutory advice and technical guidance documents that is strong enough that they will represent planning considerations of sufficient weight to have the right impact on planning decision making and critically be able to stand up at planning appeals.
Some simple changes could potentially have a significant beneficial effect, such as making water companies statutory consultees on planning applications – they would then be able to identify development proposals that are not water sustainable.
On the one hand it is worth envisaging a radically improved integration of water in the planning system, on the other, it is vital to explore how the present regime is failing and what practical steps can be taken to improve it at different levels. Questions of implementation include for example, how well are River Basin Management Plans integrating with land use planning and how could this be improved? Are local authorities sufficiently skilled to perform as SUDS Approval Bodies, or are capacity building measures required? How is water being considered in actual planning decision making and how is the NPPF impacting planning officer’s thinking?