RTPI response to the draft National Flood and Coastal Erosion Risk Management Strategy for England

This is the RTPI's response to the 2019 Environment Agency consultation on the draft National Flood & Coastal Erosion Risk Management Strategy for England. The strategic objectives are in the main inarguable but also seem to be disconnected from the reality of (1) achieving sufficient resources to implement them and (2) securing buy in from other government departments, especially MHCLG, to mainstream this as a priority.

Our work on Map for England in 2012 showed how the different spatial plans of different government departments did not require any sign-off for consistence. In particular one continuing concern is that MHCLG policy on the location of development nationally is based almost entirely on past trends. This means that if a place has grown a great deal, the requirement on it is to continue growing. The Government seems to decline to exert any influence over the national location of development. This is not consistent with an approach to flood risk management and water stress management. Many of the places which have grown fastest in recent decades ought in the light of a proper FCERM strategy be replaced by places with greater environmental resilience.