The draft National Planning Framework (NPF) 4 demonstrates the Scottish Government’s commitment to directing development away from areas of potential flood risk. What does this mean for developers?
The draft NPF4, published November 10th 2021, sets out the government’s vision to achieve a net zero, sustainable Scotland by 2045. Once signed into law following a 4-month consultation period, the framework will be used by the Scottish Government and Local Authorities to inform future development plans and directly influence planning decisions.
A key change in the framework is to integrate the flood risk posed by climate change into planning policy. The draft proposals outline that no new development is to be supported in the “Future Functional Floodplain”. Some exceptions apply for essential infrastructure, water compatible development and areas benefiting from flood defences.
The Future Functional Floodplain, developed and published by Scottish Environment Protection Agency, shows areas with a medium likelihood of flooding by the 2080’s. The flood outlines use peak river flow uplifts of between 24-56% and peak sea level increases of between approximately 0.4 m and 0.7 m to represent the potential effect of climate change.
Current planning policy requires that developers consider the impacts of climate change however it stops short of placing planning restrictions on areas beyond the present-day floodplain. Once this policy is adopted many locations will be subject to more stringent planning restrictions on the grounds of flood risk.
The Scottish Government is not alone in using planning policy to promote climate change resilient development. In December the Welsh Government will become the first in the UK to incorporate climate change predictions into the flood maps that inform planning decisions. Natural Resources Wales (NRW) recently published the Flood Map for Planning, with climate change uplifts included. These maps will be used alongside the new Welsh Government Technical Advice Note (TAN) 15 to inform decisions on planning applications in areas at risk of flooding and coastal erosion in Wales.
Going forward, developers will need to be even more aware of potential climate change impacts on flood risk, appropriate siting and consenting of developments, and considerations for suitable design and mitigation. ITPEnergised flood risk specialists and wider environmental planning and civil engineering experts can provide valuable support and advice. Please email info@itpenergised.com if you would like more information or support.
UPDATE
Since this article was authored, the Welsh Government has announced a significant delay to the new policy regarding climate change and flood risk. The planning rules, which were due to be adopted December 2021 have now been delayed until June 2023.
Julie James, Minister for Climate Change states the decision to postpone came following concerns raised by Local Authorities about the new policy advice and map. The delay is intended to give planning authorities to time fully consider the impact of the climate change projections on their authority areas and incorporate this into their own local plans and consequence assessments.
The consultation phase for the Scottish Governments draft NPF4 publication is open until 31 March 2022, after which the responses will be considered, and a final draft will be presented to the Scottish Parliament. There remains scope for this process to influence the proposed planning policy regarding flood risk, and ITPEnergised will continue to keep abreast of the latest developments and offer up to date, expert advice.
