2. Planning and Policy Framework

This section provides an overview of the flood risk policies and requirements on national, regional and sub-regional levels. A local level policies and requirements overview is provided for each of the six Boroughs. The source material is hyperlinked wherever possible, with only the key information stated within this SFRA. The policies referenced in this section may be superseded in time. To ensure that development proposals are in line with the most up to date policy, it is advised that developers, planning consultants and Local Planning Authority officers keep abreast of any changes.

The National Planning Policy Framework (NPPF) was published in March 2012 by the Department for Communities and Local Government. The document sets out the government’s planning policies for England and how these are expected to be applied. The NPPF provides guidance for Local Authorities to implement localised plans to meet the challenges presented by, amongst others, climate change, flooding and coastal change whilst achieving sustainable development. Paragraphs 94 and 99-104 specifically relate to development and flood risk, with Paragraph 100 outlining the importance of a SFRA:

The ‘Flood Risk and Coastal Change’ section of the Planning Practice Guidance (PPG) was initially published in March 2014 and operates in conjunction with the NPPF. As it is intended to serve as a living document, it is subject to periodic updates. This section of the PPG advises users on how to take account of and address the risks associated with flooding and coastal change in the planning process. The section, made up of 86 paragraphs, defines flood risk and how to address all sources of risk. It provides information on how flood risk should be taken into account in the preparation of local plans and what SFRAs should include. Where relevant, specific PPG paragraphs are referenced throughout this SFRA in the relevant sections. The current version of the PPG includes new and updated paragraphs from 2015 and 2016.

The Flood and Water Management Act (FWMA) 2010 provides a better, more sustainable and consistent management of flood risk in England and Wales. The FWMA was enacted following the Pitt Review of the 2007 flooding experienced across the country.

The FMWA defines the necessity of co-operation between relevant authorities at national, regional and local levels. It defines the roles of Risk Management Authorities (RMA), the bodies with flood risk-related responsibilities in England and Wales. RMAs includes the Environment Agency (EA), Internal Drainage Boards, Water and Sewerage Companies and Lead Local Flood Authorities (LLFAs). As LLFAs, the Boroughs have several responsibilities under the FWMA:

• Developing and implementing a Local Flood Risk Management Strategy (LFRMS) – see Section 2.2.4 for information about the six borough’s LFRMSs.
• Investigating and recording key local flood incidents
• Maintain a flood risk asset register
• Coordinate the management of flooding from local risk sources (surface water, groundwater and ordinary watercourses)
• Regulation of works on Ordinary Watercourses
• Sharing of information about flood risk

The Flood Risk Regulations (FRR) 2009 set out duties for LLFAs and the EA to produce Preliminary Flood Risk Assessments (PFRAs), flood risk maps which show flooding extents and hazards, and flood risk management plans. These FRR requirements are completed on a six-year cycle and achieve the country’s legal obligations of the European Union (EU) Floods Directive 2007. The Floods Directive’s objective is to provide a consistent approach to flood risk management across Europe. Further information about the Thames Flood Risk Management Plan is found within Section 2.2.2, links to the six borough’s PFRAs and flood risk maps are found within Section 2.2.4.

The London Plan, last updated in March 2016 (at the time of writing, March 2018), is the Greater London Authority’s (GLA) spatial development strategy plan for London. It sets the framework for development in London over the next 20-25 years, linking key economic, environmental, transport and social priorities. The London Plan was first published in 2004 and has undergone various alterations since.

The London Plan sets out several objectives put forward by the Mayor of London. One of the objectives is to ensure London is a city that becomes a world leader in improving the environment. This includes responding to climate change, which is covered in Chapter Five of the London Plan. Within this chapter are several policies that cover flood risk and water resource matters relevant to this SFRA:

• Policy 5.3: Sustainable Design and Construction
• Policy 5.11: Green Roofs and Development Site Environs
• Policy 5.12 Flood Risk Management
• Policy 5.13 Sustainable Drainage

Chapter Seven provides further policies that cover flood risk and water resources. The Blue Ribbon Network (BRN) sub-chapter covers London’s strategic network of natural and semi-natural water spaces, providing policies on the usage, protection and restoration of the BRN.

The GLA’s associated Sustainable Design & Construction Supplementary Planning Guidance (SPG) provides guidance that supports the London Plan policies. Chapter 3.4 of the SPG focuses on flooding and provides links to guidance about sustainable drainage systems (SuDS).

A new London Plan is currently being drafted and expected to be finalised in 2019. Chapter 9 of the draft document covers sustainable infrastructure and includes several policies relating to flood risk and water management, including ‘Policy SI12 Flood risk management’, ‘Policy SI13 Sustainable drainage’ and ‘Policy SI17 Protecting London’s waterways’. Once the new London Plan has been finalised and adopted this SFRA may need to be updated to reflect any changes in key policies. Table 2-2 highlights the key flood risk policies in the both the current and draft London Plan documents. The table summarises the current differences between the two that may trigger future updates for the SFRA.

Table 2-2. Current and Draft London Plan Flood Risk Policy Comparison

The London Regional Flood Risk Appraisal (RFRA), last updated in August 2014, is an accompaniment to the London Plan. It provides a strategic overview of all sources of flooding in London and addresses its probability and consequences. The findings of the London SFRA supports information presented in the London Plan, and provides details which shape the Plan’s policies. The London RFRA was first published in October 2009.

The 2014 London RFRA provides several revised recommendations, which are meant to be used as a monitoring tool on a borough-wide or London-wide level. Progress against these fourteen recommendations is reported annually in the London Plan Annual Monitoring Report. All monitoring recommendations are categorised under one of the following:

• Fluvial Flood Risk (Recommendations 1 to 5)
• Surface Water Flood Risk (Recommendation 6)
• Foul Sewer Flood Risk (Recommendation 7)
• Groundwater Flood Risk (Recommendation 8)
• Reservoir Flood Risk (Recommendation 9)
• Specific Development Areas (Recommendation 10)
• Main Road Network and Airports (Recommendation 11)
• Emergency Services (Recommendation 12)
• Schools (Recommendations 13)
• Utilities (Recommendations 14)

The contents of the London RFRA are also designed for spatial planners, developers, emergency planners, and infrastructure and utility operators. One of the aims of the London RFRA is to provide spatial planners and emergency planners with a shared understanding and common baseline of information.

A new London RFRA  is currently being drafted and is expected to be finalised in 2019. It provides important evidence that underpins the new draft London Plan. Further revised monitoring recommendations are provided, intended to improve local risk policies and Drain London activities. It is suggested that these recommendations are incorporated into future Local Plan policies and documents once finalised.

The Thames Catchment Flood Management Plan (CFMP) was published in December 2009 by the EA. Its purpose is to provide an overview of current and future flooding within the River Thames’ catchment area. The Thames CFMP also sets out strategic policies to manage those flood risks over the next 50 to 100 years with climate change in mind.

All six boroughs fall under Sub-area 9, London catchments, in the Thames CFMP (See Figure 2-1). The boroughs fall into either the River Brent sub-area (Barnet, Brent, Ealing and Harrow) or the River Crane sub-area (Ealing, Harrow, Hillingdon and Hounslow). The Thames CFMP preferred policy for the London catchments is Policy Option 4, summarised as effectively managed flood risk areas where further actions are needed to keep pace with predicted climate change.

Three of the boroughs also fall under Sub-area 5: River Pinn sub-area (Hounslow and Hillingdon) and Lower Lee tributaries sub-area (Barnet). The Thames CFMP preferred policy for Sub-area 5 is Policy Option 6 where partnership actions are needed to store and manage runoff in locations with environmental or overall flood risk reduction benefits. The Policy Option states that the approach to flood risk management in these places uses the natural protection already provided by the river channel and the open spaces in the floodplain.

Three of the boroughs also fall under Sub-area 5: River Pinn sub-area (Hounslow and Hillingdon) and Lower Lee tributaries sub-area (Barnet). The Thames CFMP preferred policy for Sub-area 5 is Policy Option 6 where partnership actions are needed to store and manage runoff in locations with environmental or overall flood risk reduction benefits. The Policy Option states that the approach to flood risk management in these places uses the natural protection already provided by the river channel and the open spaces in the floodplain.

The Thames Estuary 2100 (TE2100) project was established in 2002 by the EA to manage and reduce tidal flood risk through the 21^st Century. The inclusion of other sources of flooding, including high river flows and surface water flooding implications on the estuary, resulted in the publishing of the TE2100 Plan in August 2011. A TE2100 5 Year Monitoring Review document was published in October 2016 which provides a five-year review of the TE2100 Plan. The TE2100 Plan, and associated documents, provide recommendations and actions for flood risk management for London and the Thames estuary through to the end of the century and beyond.

Of the six boroughs, only Hounslow lies within the TE2100 policy area, falling under Action Zone 1 (‘West London’). The Plan introduces two policies that are applicable to Hounslow to strategically manage flood risk from tidal and high river flow sources in the TE2100 Plan area:

• P3: Continue with existing or alternative actions to manage flood risk. We will continue to maintain flood defences at their current level accepting that the likelihood and/or consequences of a flood will increase because of climate change.
• P5: Take further action to reduce the risk of flooding (now or in the future).

There are also six recommendations for implementation by the Borough. Further details can be found under the Hounslow section in Section 2.2.4 of this document.

The Thames River Basin Management Plan (RBMP) is part of a series of river basin district (RBD) documents that aim to provide a framework for the protection and enhancement of the benefits provided by the water environment. Prepared by the EA, RBMPs fulfil the requirements of the EU’s Water Framework Directive (WFD) and are updated on a six-yearly cyclical basis.

The current Thames RBMP was produced in 2015 and is the second of a series of six-yearly cyclical planning documents. It covers the entire Thames river system, and includes contributory and interconnected rivers, lakes, groundwater and coastal waters. The document provides a set of measures as part of the main programmes, and local measures for catchments within the Thames RBD. As highlighted under the Thames CFMP, the six boroughs fall under either the London Brent catchment or the London Crane catchment. Hillingdon also falls within the Colne catchment and Barnet has a small overlap with the River Lee catchment (via the Pymme’s Brook tributary of the River Lee). As part of the local measures sections, priority WFD issues, contributions to environmental outcomes for 2021, and future aims are all highlighted. Further information about local priorities can be obtained from the Brent Catchment Partnership, the Crane Valley Partnership and the Colne Catchment Action Network.

The Thames River Basin Flood Risk Management Plan (FRMP) are a set of documents published by the EA in March 2016. They are produced in line with Flood Risk Regulations (2009) and the EU Floods Directive (2007). These documents are updated on a six-yearly basis, with the current cycle running from 2015 to 2021. They set out how RMAs will work with communities to manage flood and coastal risk over the next 6 years within the RBD.

The objectives of the Thames River Basin FRMP are grouped into environmental, social, and economic. They build on the aims and objectives of The National Flood and Coastal Erosion Risk Management Strategy for England, published in 2011 by the EA, and align to the Councils’ LFRMSs (see Section 2.2.4 for further information). A set of measures have been produced to work towards achieving specific objectives. These measures fall under one of four different categories:

• Preventing risk
• Preparing for risk
• Protecting from risk
• Recovery and review

Full details regarding these objectives and measure categories can be viewed in Sections 4 and 8 of Part A of the Thames River Basin FRMP.

The Thames Strategy, Kew to Chelsea, was commissioned in 1999 to help provide the basis for a more holistic approach to planning, management and use in Thames riverside areas between Kew and Chelsea. The document provides policy recommendations that fall under several categories, including ‘The River Channel’, ‘Shaping Development’, and ‘Biodiversity’. These policy recommendations have been devised with the requirements and objectives set out in line with the 1997 Strategic Planning Guidance for the River Thames (RPG3B/9B) and is intended to provide the basis for managing long term change.

The Thames Landscape Strategy, Hampton to Kew, was established in June 1994 and further updated in 2012. The document provides objectives to work towards the overarching aim of understanding the river landscape and to respecting its character – both natural and man-made aspects. A 2017-2020 Action Plan has recently been published.

Of the six boroughs, only Hounslow falls within the catchment area of both Thames Strategies. Any Thames-side developments should ensure they align with both Strategies’ strategic aims and projects.

The London Sustainable Drainage Action Plan (LSDAP) was published in 2016. Its overarching objective is to address how the capital’s increasing population, land use changes and climate change projections, will impact upon flood risk. The existing drainage systems across London is typically over utilised through increased surface water runoff and greater foul water discharges. To reduce the increasing risk of flooding, the GLA produced the LSDAP to better use the existing and planned drainage infrastructure. The LSDAP promotes the benefits of retrofitting traditional piped drainage features with SuDS and demonstrates how rainwater can be used as resource instead of a waste product.

Focusing over a 20 year period, 40 actions have been included within the LSDAP for the GLA to work in partnership with RMAs including the EA, Thames Water, Transport for London and London Boroughs. The actions range from wider policy improvements and delivery of SuDS projects to the identification of opportunities to better implement SuDS in schools, housing and transport schemes. The Boroughs strongly support the LSDAP and this SFRA’s push for greater inclusion of SuDS within developments directly align to many of the actions.