BIBA’s response to DEFRA’s consultation

30th March 2021

This consultation asks how we can strengthen our assessment of local circumstances in the government’s future flood and coastal defence investment programme.  It also looks for evidence to help identify actions to accelerate the uptake in property flood resilience and address barriers to progress.  Resilience to flooding is part of our manifesto where we aim to increase access suitable flood protection products and encourage all stakeholders to build back better.

These are the key summary points of our response:

  • Flood scheme proposals would best benefit communities that repeatedly flood, but where this considers the additional exposure to surface water flooding and the availability of the grant scheme.
  • Should the PFR grant scheme reconsider funding to previously or repeatedly flooded properties?
  • Government could accelerate the uptake of PFR for both households and businesses by utilising the Flood Re surplus and existing IPT allocation.
  • The culmination of the PFR Roundtable Code of Practice and new training and accreditation projects allows for this investment to be targeted and effective.
  • BIBA supports the Government’s intention to accelerate the uptake of PFR. The more of these measures that are deployed, “flood resilience becomes a routine part of ‘business as usual’.
  • Clarification is required how build back better and reduced premiums for PFR would operate.
  • There are opportunities for the PFR grant scheme to work better.
  • Signposting recommendations from the Doncaster Review are being developed with a new BIBA/ ABI flood insurance signposting service being launched later this year which will help households access flood insurance.
  • Perhaps the simplest incentive to improve resilience would be a digital template for households and businesses to draw up their own flood continuity plan. These exist from various sources, but one backed by the local council may be more readily adopted.
  • Building regulations and controls should incentivise PFR and require developers and senior managers to make good any failures.
  • We would not want to see the effect on householders/leaseholders that poor fire safety and building control has had, repeated for homes built on flood plains.
  • Consideration should be given to making SUDS in England mandatory.
  • Should EA take responsibility for surface water management?
  • Further data could help target investment efficiently:
    • Expected PFR take-up rate
    • Variance depending on the incentive(s) offered
    • Overlaid to at risk flood areas

Please click here to read our response in full.