BIBA response to the Consultation on proposed amendments to Planning Policy Statement 25: Development and Flood Risk

4th November 2009

The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance organisation representing the interests of insurance brokers, intermediaries and their customers.

BIBA membership includes 1700 regulated firms. Insurance brokers and intermediaries distribute nearly two-thirds of all UK general insurance. In 2007, insurance brokers and intermediaries generated £1.5 billion of invisible earnings and they introduce £22 billion of premium income into London’s insurance market each year.


BIBA is the voice of the industry, advising members, the regulators, the Government, consumer bodies and other stakeholders on key insurance issues.  BIBA provides unique schemes and facilities, technical advice, guidance on regulation and business support and is helping to raise, and maintain, industry standards. BIBA works closely with the Chartered Insurance Institute to provide training to those working in the industry and actively participates in helping the industry and its customers deal with some of the major issues of the day.


BIBA members provide professional advice to businesses and consumers, playing a key role in identification, measurement, management, control and transfer of risk.  They negotiate appropriate insurance protection tailored to individual needs and operate to a very high standard of customer service with the aim of ensuring peace of mind, security, financial protection and the professional advice required.


Our responses to the 3 questions set out are as follows:



Q1 a) Do you agree with the proposal to clarify the definition of Flood Zone 3b, the

‘functional’ floodplain, in Table D.1 in PPS25, to make clear that the identification of this zone in strategic flood risk assessments should take account of local circumstances, and that a ‘1 in 20’ annual flooding probability parameter should be the starting point for consideration and discussion?

Yes, we agree.

b) If not, would you prefer the current definition of Flood Zone 3b in Table D.1 to remain unchanged, or do you wish to propose an alternative definition? What are your reasons for this alternative view?


We agree with proposal as per Q1 a)

Q2 Do you agree with the proposed amendments to Table D.2 in PPS25:

a) Removing water treatment and sewage treatment plants from the ‘less

vulnerable’ category and instead placing them in the ‘essential infrastructure’

category, making clear that measures to control pollution and manage sewage

during flooding events would need to be in place; and amending the description

of ‘essential infrastructure’ to make clear that it applies to ‘essential utility

infrastructure which has to be located in a flood risk area for critical operational



Yes, we agree.

b) Insertion of additional text providing for police, ambulance and fire stations

which are not required to be operational during flooding to be treated as ‘less

vulnerable’ (and therefore permissible in flood risk areas).


Yes, we agree.

c) Insertion of additional text to clarify that where there is a need to locate bulk

storage facilities requiring hazardous substances consent with port or other

waterside facilities, these installations should be classified as ‘essential

infrastructure’, rather than ‘highly vulnerable’. Also, clarification that installations

requiring hazardous substances consent that are associated with energy

infrastructure, including carbon capture and storage installations, should be

classified as ‘essential infrastructure’.


Yes, we agree.

d) Clarification that wind turbines for generating renewable energy should be

treated as ‘essential infrastructure’.


Yes, we agree but BIBA disagree that wind turbines are “similar” to other strategic utility infrastructures as mentioned in the text in point  3.34, although we do agree they should be classed as “essential.”  Unlike e.g. an electricity sub-station; wind turbines and associated cabling can be specifically designed to function perfectly well in deep water (e.g. offshore windfarms) and the blades would be sited sufficiently high on the masts to stay well clear of any flooding.  They are also unmanned (except for servicing) and operated/monitored remotely, so the comment about their having to be “safe for users in times of flood” is not appropriate.

Of all possible essential infrastructures which could be sited in flood plains, we would think a windfarm would cause by far the least impedance to flood water/reduction in floodplain storage.

If you disagree with any of these proposals, how would you wish to see the required clarifications set out above reflected in PPS25? What are your reasons for any alternative views and/or proposals?


We do not disagree.


Q3 Do you have any comments or views on the impact assessment, in particular, do you consider there may be additional costs that might arise if these proposed

amendments are implemented?


No comment on impact assessment. 


Thank you for taking the time to consider our response. If you have any further queries please contact Graeme Trudgill, BIBA’s Technical and Corporate Affairs Executive for further information on 02073970218 or on [email protected] or Steve Foulsham, BIBA’s Technical Services Manager on 02073970234 or [email protected] or Peter Staddon, Head of Technical Services on 0207 397 0204 or [email protected]


Yours sincerely



Eric Galbraith

Chief Executive


Direct Tel:  020 7397 0201

Direct Fax: 020 7626 9676

Email: [email protected]