BIBA response to the Planning Act 2008 Consultation on list of statutory consultees for National Policy Statements

23rd April 2009


The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance intermediary organisation. We represent the interests of insurance brokers, intermediaries and their customers and have partner members from the leading companies in the insurance industry.


BIBA represents 2,300 insurance intermediaries including 98 of the UK’s top 100 insurance intermediaries. Our members handle around half the value of all UK home, contents, motor, travel, commercial and industrial insurance policies. Independent insurance intermediaries distribute nearly two-thirds of all UK general insurance, of which BIBA members account for more than 80%. They also introduce £22 billion of premium income into London’s insurance market each year.


BIBA were consultees on the Pitt report Learning Lessons from the 2007 floods.  


In answer to your question: Do you agree that the draft Regulations capture the organisations which the Secretary of State should be legally obliged to consult before designating a statement as a National Policy Statement? If not, what changes would you make to the list of organisations?


We believe BIBA should be a consultee for considering and deciding on major infrastructure applications as outlined in your consultation document where any NPS (national policy statements) are likely to affect the pricing and availability of insurance.



We believe it essential that developers consult the insurance industry before building on flood prone land to address any concerns about appropriate building methods.   Unless the industry is consulted it will be increasingly difficult to offer flood insurance for affected properties. When building on land that is prone to flooding, we believe that developers should make a contribution to the cost of building and maintaining any necessary defences.  


Thank you for taking the time to consider our response. If you have any comments or queries on the above, please contact BIBA’s Technical and Corporate Affairs Executive Graeme Trudgill at [email protected], tel 020 7397 0218.

Yours sincerely

Eric Galbraith

Chief Executive

0207 397 0201

[email protected]