Written evidence submitted by The Royal Institute of British Architects (RIBA) (FLO0083)
Flooding causes an average of £1.4 billion in damage a year to businesses and households, but the impact of flooding goes far beyond the financial costs: it disrupts lives and livelihoods and inflicts profound and long-lasting that extend far beyond communities that were originally flooded. These include direct injuries and physical health problems, but also long-term anxiety and depression resulting from the impacts of damage to homes, having to move out until properties are habitable, and delayed recovery.
Extra funding, new flood defences and the launch of Flood Re have improved the protection offered to communities against increasingly extreme weather. Even with these and continued large-scale investments in flood defences, it will not be possible to keep pace with the growing scale of the problem. Flooding will become the new norm; the Committee on Climate Change warns that “severe flooding somewhere in England in any given year is almost to be expected”.
The implications are huge. In many parts of the country, we can no longer base our approach to managing flood risk on simply keeping the water out; we need to examine how we can design buildings and built environments which are more resilient to flooding.
Instead of focusing primarily on flood prevention, Government policy must start enabling communities and property owners to manage risks. This should be achieved through property level flood resilience and adaptation, better equipping people and businesses to live with water, stopping water entering properties and quick recovery if it does.
Good design can help future-proof new developments and deliver greater value for money when investments in new flood defences are made
Flood-resilient architectural design is already helping communities around the world to reduce the chances of their lives and livelihoods being disrupted in a flood, and some of this innovation is already being successfully implemented within the UK. However, Government action is required to speed up this process. There is also a need for an awareness-raising campaign to change public ideas about what resilient design means.
In the past local planning authorities did not have to refer to any flood authority when designating land for development, nor did they have to submit plans for consultation to such a flood authority. These weaknesses in the planning system mean that significant amounts of our economic infrastructure and housing have been ‘locked into’ areas at risk from flooding and are now reliant on flood defences for protection.
It is vital that money earmarked for flood defences is spent in a way which maximises the number of homes and businesses protected. At the same time, careful attention needs to be paid to the long-term financial burden on the taxpayer of high running and maintenance costs.
The UK would do well to learn from other countries’ innovative designs for flood defences that combine flood protection with a range of urban functions such as housing, ecology and transport in one multifunctional structure. Such schemes provide practical alternatives in cases where necessary improvement of flood defences compete for space with other functions. This would particularly benefit coastal communities in the UK.
The most significant advantage of good multifunctional design is the potential for financial, social and environmental benefits to accompany the primary objective of reducing flood risk. By adopting this approach, the Government could increase links between flood defence investment and urban regeneration and development. This in turn could also help to attract private investment to co-fund schemes, with a resulting reduction in the cost to the taxpayer.
The lack of design perspective in viability assessments for flood defences is a key missed opportunity to provide a compromise between competing functions, increase the benefits an infrastructure project can deliver to communities and to attract private finance to the schemes to ensure their maintenance is sustained.
To promote multi-functional and adaptable designs that deliver better value for money, central and local government should work with built environment experts to improve infrastructure investment decision-making processes. They should:
Good design can improve the resilience of housing on flood-prone sites
The National Planning Policy Framework (NPPF) helps to control the level of flood plain development. Councils are expected to avoid inappropriate development in areas at risk of flooding by directing development away from areas at highest risk, including floodplains. However, the NPPF does not explicitly rule out development in high flood risk areas. Around 10 per cent of England, including large parts of major cities such as Hull, Portsmouth and central London are located in areas with a high-level of flood risk.
There are many sites in urban areas where the costs of stopping or removing flood water would render conventional development financially unviable. Although these constraints often deter development, innovative design solutions pioneered within the UK and around the world have helped to unlock development on many difficult sites, bringing life back to abandoned sites and creating more homes. Projects like these have a key role to play in enabling new and existing development schemes to safely live with water cost-effectively.
Because innovative developments like these are a first of their kind, statutory guidance, building standards, and approved construction techniques for new flood resilient properties are lacking. This makes it impossible for innovators to secure loans from traditional funders, warrantors and mortgage providers, resulting in much less experimentation taking place than otherwise could. The Government needs to become more proactive in filling in these voids to enable more market-driven innovations that can reduce the vulnerability of new developments to flooding.
Building regulations that adequately address flood resilience will help to stimulate an effective market for flood resilient property. They would also address the existing ‘disconnect’ between planning requirements for building flood resilience measures and their implementation, which is not always followed through into construction.
It will take time to incorporate resistance and resilience requirements into Building Regulations for properties in flood risk areas. To fill in this void, RIBA is supporting the Construction Industry Research and Information Association (CIRIA) and Better Regulation Executive (BRE) in developing the Property Flood Resilience Code of Practice and consolidated guidance that provides a standardised approach for the delivery and management of flood resilience measures.
In the lead up to Building Regulations for flood resilience and resistance, market-driven innovations in flood resilient design should also be fostered via the planning system. One solution could be ‘Licences for Innovation’ which enable innovative designs to unlock flood-prone sites for suitable development. Based on strong overarching environmental design aspirations, the licenses would allow more flexibility in terms of compliance with current planning policy.
Each city region or local authority could be enabled to grant up to 5 licenses a year to encourage public and private companies to innovate and compete to find ways to deliver more housing, more quickly, and more sustainably.
The administrative bodies should distribute the licenses based on the innovation’s potential and achievability, and tax breaks should be made available to these demonstration schemes. The tax breaks should be conditional upon projects meeting key milestones during construction and should be maintained for a pre-determined period subject to an evidence base being presented post-occupancy to demonstrate the schemes met their original goals and objectives.
Should projects under the licence fail to meet original goals and objectives, they should be placed on ‘watching briefs’ – allowing up to two years to rectify and modify building schemes to meet their original targets. If, following this period, the schemes continue to fall short of original briefs, the buildings would have to be brought back in line with current and building codes to ensure their compliance with conventional regulations.
The licenses would incentivise public and private companies to innovate and compete, yielding schemes that both alleviate housing pressures and stimulate technological creativity which could be exported to the rest of the world, giving the UK a competitive advantage. Successful pilots would incrementally raise the bar for sustainability and filter into policy reform. Additionally, the ‘License for Innovation’ would provide funding organisations the confidence to invest in alternative approaches to property.
To encourage market-driven innovations that can reduce the vulnerability of new development to flooding, and ensure all new buildings incorporate appropriate measures, the Ministry of Housing, Communities & Local Government (MHCLG) should work with built environment experts, the Environment Agency and the Department for Environment, Food & Rural Affairs (DEFRA) to examine the feasibility of introducing Building Regulations, planning regulations and planning guidance for flood resilience and resistance that are linked to Flood Zone (FZ) Designations:
To enable innovative design that unlocks flood-prone sites for suitable development, MHCLG should explore the potential for trialling ‘Licenses for Innovation’. Local Enterprise Partnerships and Combined Authorities should be encouraged to work with local authorities to bring forward new project types.
Good design makes communities healthier and safer before, during, and after flooding events
Investing in preventing or limiting the impacts of extreme weather is much cheaper and has less social impact than recovering afterwards. Not all risks can be prevented, but pre-emptive action to reduce the impact of extreme weather and a swift, effective response to the event can reduce the health and financial impact of an event and speed up recovery.
Flood defences and the right insurance cover are vital in protecting homes and businesses against the worst effects of flooding. But increasingly, the use of resilient design is becoming a key tool in reducing the misery and disruption caused by flooding, particularly in areas which do not benefit from flood defence protection or experience fluvial or ground surface flooding.
The RIBA responded to the Environment Agency’s National Flood and Coastal Erosion Risk Management Strategy consultation and welcomes some of the changes. The Strategy recommends improving placemaking through encouraging flood resilient building standards and fitting property flood resilience measures to homes and properties. However, more detail on flood resilient design should be included in the Strategy.
Resilience can be designed into buildings either as a preparatory measure or during the repair of properties after they have been flooded. These measures can help to limit the number of residents that need to be rescued from their homes, are displaced for months, and those who endure lengthy periods of loss adjusting and reconstruction. They can also aid rapid recovery, enabling households and businesses to simply wash out and disinfect after flooding, rather than requiring wholesale replacement of the fabric of the property.
Despite the obvious advantages of this approach, the take up of flood resilient measures remains low. It is not yet normal practice for properties in areas at high flood risk to be made more resilient following a flood. Resilient solutions can be developed through research and innovation, but there is a need to address policy and practice for such solutions to be implemented early enough in planning and building new developments.
To ensure flood-resilient design is more proactively taken up by home and building owners exposed to flood risk:
Environment, Food and Rural Affairs – Flooding
 Learning lessons from the 2007 floods (Sir Michael Pitt Review, June 2008)
 The English National Study for Flooding and Health: First year report (Public Health England, January 2017)
 Committee on Climate Change Adaptation Sub-Committee (FFP 110)
 Housing: Floods Lords HL5515 answered on 4 February 2016
 Future Flood Resilient Built Environment (BRE, 2016)
 Code of Practice and guidance for property flood resilience – RP1055