Flood Management Policy:
Different Planning Approaches in the United Kingdom and Germany
by : Febry Budianto and Diederik de Koning
This paper aims to give a picture of the differences and similarities of planning and policy approaches concerning flood problems in the United Kingdom (UK) and Germany. It is interesting to compare the approaches taken by different countries related to planning policy and practice to solve their problems. Both the UK and Germany have its own style of policy and planning regarding flood risks. Different backgrounds of flooding problems lead to different approaches. In this paper, a description will be made of the background of flood issues. Also, planning practices and policies related to the problem will be discussed, and a comparison will be made between the different approaches. This leads to a conclusion that there are some lessons that can be learned from the UK and Germany.
Flooding of rivers and coastal waters is a natural process that plays an important role in the shaping of the natural environment. However, flooding threatens lives and causes substantial damage to property. Not only the weather but also the decisions about the location, design and nature of settlement and land use can influence the risk of flooding. Although flooding cannot be wholly prevented, its impacts can be avoided or at least reduced through good planning and management.
Flooding in some European countries has emerged the problems and caused some disadvantages and lost. Both the United Kingdom (UK) and Germany, two big countries in Europe, have significant flooding problems. There are both differences and similarities in their approach related to spatial planning and its policy concerning these flooding risks. Flooding becomes one of the most important problems to be solved, because of its direct major impacts and the possible future environmental changes.
This first chapter will, shortly, give an explanation of the background of the paper: what is the purpose of this paper, what was the reason for this particular subject and why have these two countries been chosen to make a comparative study?
Outline of research
Part of the “International Planning Practice” course is an assignment to compare two different and non-native countries from a specific angle. The main focus is the cultural difference between the countries, which in return results in specific differences in planning practice in the two countries. The analysis of the similarities and differences between the two countries will result in the question whether these countries can learn from each others planning practice. Addressing this question will eventually be the main objective of this paper.
The research angle for this paper is the flood risk management: sea levels are supposed to rise due to environmental issues, there will be a higher risk of intense rain falls, and while all this is happening these water problems are transboundary. This means that countries will have to cooperate more and more concerning river flood issues, and this nicely follows the growing power of the European Union. It is therefore that this angle has been chosen as topic for this paper.
Two countries have been chosen for the comparative study: Germany and the United Kingdom (UK). The main reason for this choice is the following core difference concerning the river flood management in these countries: the United Kingdom does not have a transnational problem with river flood management, since it’s rivers start in its “mountains” and ends in the sea on own territory. Germany however, relies strongly on neighboring countries like the Czech Republic concerning the Elbe River. Precisely this unique difference is the basis for the chosen countries within the discussed angle of research.
Although the main focus is on the differences between the two countries, this paper will start by giving a short outline of the planning practice within the two different countries. This chapter will be followed by the general differences and similarities between the countries, after which the possible policy transfers will be discussed.
2. Flood management planning and policy: Germany and UK
In this chapter the planning practice and policy within the two countries will be explained shortly. After this brief outline, the similarities and differences will be discussed. The final chapter will address the underlying reasons for these differences.
The type of general spatial planning in Germany is based on the historical federal states of the country. This means that there is no strong hierarchical planning system in Germany. The “Laender”, which can be seen as provinces, have a strong say in what has to be done in their region. The federal government in return has less power in planning as can be seen in other countries.
There has been a paradigm change in German planning since roughly the year 2002, which can be seen as a turning point in German thinking. In this year there was a major Elbe flood, which triggered the process of water management. As can be seen in more European countries, the emphasis now lies on these three points:
- More space for water
- Decentralized planning
- Damage mitigation: concerning housing etc.
The water problem is being seen as a permanent problem, the emphasis now lies on reducing the risk of a potential flood. Part of the reason for this is the fact that Germany depends on the water input of neighboring countries like the Czech republic, concerning the Elbe river. This dependency results in two aspects:
- Communication with neighboring countries.
- Taking water for granted, reducing flood damage.
To reduce the flood damage, Germany tries to combine flood risk areas with local land uses that suffer less from a possible flood (one can think of parks, recreational areas, agriculture, etc.). German planners are trying to bar the creation of new housing projects that lie in danger areas. To achieve this, German planners added a specific tax to development in “gray” danger areas.
There are several tools for the German planners to use. They can be split up in three main parts. The ultimate tool, of course, is the land use plan.
- Spatial planning: assigning flood risk areas in general.
- Water management: determining flood areas (smaller areas than above).
- Risk management: forecasting and warning systems.
Floods that can occur once in a hundred years are, in general, tolerated in Germany as standard in risk management.
Concerning the Rhine, there is a commission that tries to create links between different countries to talk about water management of that river. This is the International Commission for the Protection of the Rhine (ICPR). In 1998 there has been a meeting between Luxemburg, the Netherlands, Belgium, France and Germany. Remarkably, Switzerland was not part of this meeting, although the Rhine does start in this country.
The weak hierarchical structure that can be seen in German planning, does mean a bigger NIMBY risk in Germany: a strong central government can force NIMBY-dangerous projects to be executed in a pre-assigned area.
Concerning the United Kingdom
Planning system in the United Kingdom (UK) historically rooted from the Town and Country Planning Act 1947, which regulated development through the land use system especially for public interest. That Act can be called as the basic planning system for the development in the UK. The role of Central government in spatial planning systems in the UK which focuses on land use regulation is very significant to arrange all of the development.
The significant change of planning system in the UK was marked by the concept of regionalization which was begun around 1990s. That concept more fluid modes, with many private sectors and pressure group actors involved and it were already established in most areas of the country, encouraged by the drive of government policy (Marshall, 2003). It means that policy or new system is not only focusing on government but also is influenced by other stakeholders.
Since 1998 there have been two severe floodings, the first at Eastern 1998 and the second in autumn 2000. According to the flood and water management problem, the role of planning system in England has been placed under media and political spotlight in recent years (White and Howe, 2002), as a result of a number of serious flooding. Pressure from rapid development especially housing development is one factor that encourages the problem to overcome flood. Land use planning system has significant role in this problem to arrange and as one part in flood’s solution. The significant role of planning system must play not only for current condition but also future.
Data from Environmental Agency which is responsible for flood risk management mentioned that nearly six million people live in floodplain and between 1997-2000 11% new dwelling units built in England were in areas which has higher risk from flooding (Crichton 2003 in Howe and White, 2005). Even, the recent data shows that net loss of underdeveloped land (Greenfield) to urban development is 5400 Ha per year and that trend increase both potential for damaging floods and the number of flood defenses needed (House of Commons Environment, Transport and Regional Affairs Committee, 2000). It is predicted by government that 3.8 millions new homes are needed in England and Wales till 2021 and it has potential to the land use changes and of course potential for increasing the flood risks. Those conditions show that reducing flooding risk and providing housing land highlights significant conflict in planning system. Planners are faced with conflicting government aims: the desire to encourage the development of housing and the need to protect society from flooding (Howe and White, 2004).
Planning policies and procedures across UK are the mechanism by which property development and land use are regulated in an attempt to promote sustainability (Howe and White, 2004). At the first, flood problem is not arranged specifically in the certain guidance and it referred to Planning and Policy Guidance (PPG) Note 3 or PPG3 Housing and PPG20 Planning. Because of the need of specific guidance for flood, it was released the Planning Policy Guidance Note 25 (PPG25) that represents specifically flooding-oriented planning guidance. PPG25: Development and Flood Risk was published in July 2001 and contained guidance on how flood risk should be taken into account as part of the planning and development process. Its introduction represented recognition of inadequacies of past guidance and PPG25 has intention to strengthen the coordination between land use and development planning and to improve the operational delivery of flood defense strategies.
Table 1: Summary of Planning and Policy Guidance 25 (PPG25)
|Summary of PPG25|
Source: White & Howe (2002).
There are a number of actors involved in the management of flood risk through the planning process are as follows (Howe and White, 2004):
- Developers—should consider flood risk issues, and guidance about flood risk. The most effective way for developers to consider these issues is to engage in discussion with the LPAs and the Environment Agency at the earliest possible stage.
- Local Planning Authorities (LPAs)—have a central role in operating the planning system, preparing development plans and determining planning applications.
- Environment Agency—as Flood Defence Agency, it should be consulted over all proposed developments in areas at risk from flooding.
- Sewerage undertakers and canal operators— water companies and the British Waterways Board should be consulted especially in relation to run-off issues.
Availability guidance such as PPG25 is important and it is quite effective to face flood problem in local level. Study done by Wynn points out that most local planning authorities and developers support the philosophy of PPG25 and in its implementation both of them were generally willing to accept the role of Environmental Agency (Wynn, 2005).
The release of PPG25 was strengthened by issuing the Planning Policy Statement 25 (PPS25) that sets out Government policy on development and flood risk (http://www.communities.gov.uk). Its aims are to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas of highest risk.
From those explanations, it is clear that solution of flooding could be integrated and involved in many actors. As seen at previous explanation, threat of flood caused by conflict of needs of land for development and protection of floodplain, the role of planning is very significant. Local Planning Authorities have a central role in managing and arranging the spatial planning (land use) and have to cooperation with other actors. Howe and White (2004) pointed out that flood risk is one of a number of sometimes conflicting considerations that have to be taken into account by Local Planning Authorities (Wynn, 2005).
Previous policies on flood management, before PPG25 issued, tends to make physically defenses flood rather than prevent the flood problem (more reactive rather than preventive action) and less integrated decision making between planning professional and other actors. The shifting of policies and implementation from reactive action to preventive and from less integrated to more integrated planning is influenced by the existing conflict of land use development (housing development pressure and conserve the floodplain) and the attempt to promote sustainable development.
According to that, in England, to enhance sustainability of flood risk management, there are some potentially realizable long and short term changes to the land use planning system (Howe and White, 2004). Short term changes approach are aimed at strengthening the linkages between flooding and spatial planning and therefore enhance the contribution of land use planning to flood risk management. There are some steps should be taken to develop and consolidate existing procedures and new knowledge in short term changes, such as:
- Promoting flood management with planners
- Linking flood planning with land use planning so that flood management measures are included in land-use plan
- Improving the use of existing data within the planning system.
A number of short term changes can be implemented but to become sustainable, a longer term perspective is required. Long term perspective will consider broader perspective and as an integrated larger picture and not simply solution. Some steps in long term perspectives are:
- Strengthening linkages within spatial planning
- Fully integrating to water management in order to provide truly sustainable flood risk management
- Sustainable Urban infrastructure system included the investment in rehabilitation and creation of new major facilities.
3. Comparing Differences and Similarities
Approaches which are done by both UK and Germany to solve the flood problem have differences and similarities. The approaches to flood problem in UK and Germany cases show different purposes in undertaking planning systems. In this part we can compare both similarities and differences to face the flood problem in UK and Germany.
The UK’s background of flood issues is pushed by the rapid growth of housing development needs and many of developments take place in floodplain area. That condition shows that there are some mistakes in controlling the area because there is no clear specific guidance for flood in the past. Availability of clear guidance is important to prevent the problem. Not only to list what problems can occur but also the authority and responsibility of each actors/stakeholders.
The German interdependence regarding the flood risks due to transnational rivers shows a different focus on the issue. Although there is coordination between different countries concerning the same issue of a single river, Germany takes the incoming water for granted and tries to solve the problems that arise as soon as flooding does occur. New shifts in planning thought call for “more room for water” and efficient and safe use of space via Mixed-Use Developments (so called MUDs). The same conflicting issue occurs as with the UK: a growing need from the housing industry competing with the government that wishes to empty space where living is considered too risky.
Similarities and differences:
Firstly, as is discussed before, there is a clash between development on the one hand, and river flood safety on the other hand. This concerns especially the housing market, and its goal to build more. Dangerous areas may then be used as building sites. Germany tries to bar this, also by adding a tax to these danger areas.
There also is another similarity, as both countries tend to work out their planning on a rather decentralized way: in Germany this is mainly because of its old Feudal government system. In the United Kingdom this may be the result of the urge to have a more market orientated panning system. Yet, the latter does point out to a difference in planning in general, since the UK planning is done in a more market orientated fashion. This gives stakeholders, like the housing industry, to be involved. The clash between development and safety seems, therefore, to be stronger in the UK.
Thirdly, there is a shift going on from reactive planning (more dikes, how to solve the problem that leads from the underlying issues) to proactive planning (cooperation in Germany, tackling the underlying issues) in general planning practice. This is also triggered by the environmental issues that are stake at the moment: a cultural movement towards fixing underlying problems (relationship between water and the people, relationship between people and the global warming) seems to be occurring.
To point out a difference, the United Kingdom is more focused on indirect planning principles: they focus on integrating river flood policy into the spatial planning system. Germany is not so focused on the “tools” on how to do this, but is more interested in the “goal”: making more room for the river to flow in, and therefore works more directly. Maybe an underlying motive for this is that Germany has more serious flood issues, and depends on its neighboring countries. It wants to do its solutions on its own, since Germany cannot fully rely on the other countries. Also, the United Kingdom has a more market orientated planning fashion, which is based on a more indirect way of planning. Another underlying difference is the danger of coastal flooding, which is more prominent in the United Kingdom (since it is an island after all).
Also, the United Kingdom takes flood issues as a “part of spatial planning”, whereas Germany focuses on river flood planning as a thing in it’s own (although obviously Germany works this out through the spatial plans).
As mentioned earlier, in the UK planning is done in a more indicative way, to make more room for market driven forces. The role of the government in that sense is less than is the case in Germany.
Table 2: Similarity of Flood Policy in Germany and UK
Explanation of Similarity
Causal Factor of Flood Problem
Rapid development especially Housing development
Authority to Solve Flood Problem
Tendency towards decentralized planning (strengthening the local authority in practice)
Characteristic of Policy
From Reactive to Preventive Policy
Table 3: Differences of Planning and Policy Approach in Flood Problem Germany vs. United Kingdom (UK)
|Germany||United Kingdom (UK)|
|1||Planning Principles related to Flood Problem||
|2||Involvement Stakeholders to Solve Flood Problem||
4. Lesson Learned
Comparing the differences and similarities of flood management policy and planning in the UK and Germany give the broader view that every country has some unique or special characteristic in solving flood problems. There are some aspects that have similarities and differences that can be learned such as the concepts, structure, instruments, and institution.
The differences and similarities of planning policy in UK and Germany show that planning policy in both countries as part of planning system is dynamic. From this, we can learn that each country tries to fit their planning policy with the planning problem. Before PPG25 and PPS25, the UK did not have specific guidance or regulations for flood problem. The UK in case of flood problem realizes that to overcome the flood problem, they need clear and specific regulations or guidance and a specific institution that has responsibility for the issues. According to that, the strengthening of local planning authorities and involvement of the private sector (developer), written in guidance, without ignoring the central institution, has to be underlined as a significant change in overcoming the flood problem. Refer to study by Wynn (2005) most local planning authority support the philosophy of PPG25 and feel it effective. From that study also describes that local planning authority and developer willing to accept and to cooperate with the representation of Environmental Agency. It shows that in the UK, central government still has an important role although the local institution has become a bigger authority.
From the Germany side, some elements of policy in flood problem are different from the UK perspective. The national or central government in flood problem has a central and significant role but tends to shift to more decentralized work. An other important thing that can be learned from Germany is seeing the flood problem in relation to coordination with other neighbouring countries such as Switzerland, the Czech Republic, and others. Unlike the UK, Germany has to cope with the problems without ignore the other countries. It shows that the role of National/Central Government in Germany, especially in planning policy and management, is and should be stronger than in the UK because Germany has to coordinate with other countries. This urge to look outside the national borders of the country could however be as important for the UK as it is for Germany. Although less obvious, the UK can learn from the progression in other European countries like Germany. Making room for water is not as big an issue in the UK, although there is a similar discussion going on concerning the dehydrated soil in summer (recent news reports). For Germany, the involvement of private parties is less obvious, but could be very useful to combine flooding issues with innovative housing ideas for instance: innovative solutions are more obvious in a planning system which is as market orientated as is the case in the UK.
So there are some interesting things that we can learn from Germany and the UK related to flood problems. Differences and similarities between them can be influenced by the root of the problem, resulting in: different styles of planning systems and different policy instruments. Of course, their differences result in the use of different planning systems, although one cannot normatively be seen as a “better system”.
Flooding becomes important problem that has to be solved to minimize the destruction of property and potential loss of lives. Planning policies have a significant role to overcome the flood problem. It is not enough only to implement the reactive ways to overcome it and needs preventive actions such as through policy and guidance. Both the UK and Germany have its own policy related to flood problem. They have some differences and similarities policy to overcome the problem, which is caused by some factors such as background of causal factor, level of authority, characteristic of policy, and stakeholder involvement. From the differences and similarities of them, it can be a lesson in planning practice in flood management and policies not only for each country itself but also for others.
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