Local resilience forums and flood emergency planning

Flood emergency planning in England sits with local resilience forums, which are multi-agency partnerships set up under the Civil Contingencies Act 2004 and organised on police force areas. They are not planning bodies, they do not approve development, and their plans deal with responding to a flood rather than deciding where building should happen. Understanding that division explains a lot of the confusion that arises when a neighbour asks why the council approved houses in a flood zone and then published an evacuation plan for them.

The short version is that the planning system decides whether development is acceptable, and the resilience structures plan for what happens if the water arrives anyway.

Who plans for a flood emergency, and at what level

The Civil Contingencies Act 2004 creates two categories of responder. Category 1 includes the emergency services, local authorities, NHS bodies and the Environment Agency, and carries the full set of duties: assessing risk, maintaining emergency plans, maintaining business continuity, warning and informing the public, sharing information and co-operating with others. Category 2 includes utilities, transport operators and highways bodies, which have co-operation and information-sharing duties but do not write the plans.

Those responders meet as a local resilience forum. The forum maintains a community risk register, which scores the local likelihood and impact of hazards including fluvial, coastal, surface water and groundwater flooding, and it holds the plans that flow from that register.

Below the forum sit two further layers that matter locally. The lead local flood authority, created by the Flood and Water Management Act 2010, is the county or unitary authority responsible for local flood risk management strategy, ordinary watercourses and surface water. And the district or borough council usually holds the on-the-ground emergency response role: rest centres, sandbag policy where one exists, and welfare.

What a multi-agency flood plan covers

A multi-agency flood plan is a response document. It assumes the flood is happening and sets out who does what.

Expect it to contain the identified flood risk areas in the forum area, the trigger levels and warning thresholds at which action begins, the agencies responsible for each action, the location of rest centres and the arrangements for opening them, routes and access constraints during a flood, arrangements for vulnerable people and care settings, and the command structure that runs the response.

What it does not contain is a judgement about whether a particular site should be built on. It also tends not to contain site-specific detail for individual developments, which is why a developer cannot simply point at the forum's plan and treat it as the evacuation strategy for a new scheme.

Plans are reviewed and exercised periodically. Where you want to know the position for a particular area, the forum's published plan or the council's emergency planning team is the right place to ask, not the planning department.

How emergency planners see a planning application

Emergency planning officers are consulted on applications where flood risk is at issue, and their comments follow a predictable pattern.

They look at safe access and egress during the design flood event, including whether the route out stays dry or passable at a defined depth and velocity, and whether it leads somewhere that is itself out of the flood zone. They look at the depth and speed of water expected on the site, because shallow, slow water is a different problem from fast water over a metre deep. They look at whether occupants will be asleep, since sleeping accommodation at or below flood level changes the response entirely, a point explored in basements, flood risk and sleeping accommodation. They look at who will occupy the building, because a care home, a school or supported housing needs assisted evacuation. And they look at whether the site would become an island, cut off while remaining dry, which creates a sheltering problem rather than an evacuation one.

What they rarely do is approve a flood warning and evacuation plan. The Planning Practice Guidance on flood risk and coastal change is clear that the Environment Agency does not approve such plans, and that the local authority's emergency planning function should be consulted on their adequacy. The plan remains the applicant's document and the council's judgement.

Community flood groups and what they actually do

Community flood groups form in places that have flooded. They are voluntary, they vary enormously in capability, and the good ones do things no agency can.

They hold local knowledge about where water arrives first, which gully blocks and which lane becomes impassable at what level. They maintain door-knocking lists for neighbours who will not receive or act on an automated warning. They store and distribute property-level equipment. They act as a single point of contact for the agencies during an event, which saves hours in a response. And over time they become the body that holds authorities to maintenance promises about screens, culverts and watercourse clearance.

For a reader whose area has flooded, joining or starting a group is the single most useful step available. For a developer, an existing group is an asset rather than an obstacle: it is a consultee that knows the site better than any desk study and whose support is worth having before the application goes in.

Warning and informing

The Environment Agency operates the flood warning service for flooding from rivers and the sea, with flood alerts, flood warnings and severe flood warnings, delivered by phone, text and email to people who have registered or been automatically enrolled for an area. Surface water flooding is far harder to warn for, because it develops in minutes from rainfall rather than hours from a river level, and no equivalent property-level service exists.

That distinction matters for planning. A scheme whose residual risk management depends on a warning should be checked against the type of flooding it faces. A fluvial site in a warned area can plan around a few hours of lead time. A site at risk from surface water or from a rapidly responding urban catchment cannot, and the design has to rely on levels, resistance and resilience instead. The limits of the surface water mapping are covered in reading the surface water flood risk map without overstating it.

Registering for warnings is free and takes a few minutes. Local authorities and forums also use social media, loudhailers and door-knocking during an event, which is where the community group list earns its keep.

Where emergency planning stops being mitigation

Here is the point that most often gets lost. An evacuation plan is not a reason to permit development that is otherwise unacceptable on flood risk grounds.

National policy and the accompanying guidance put the sequential approach first: steer development to areas at the lowest risk of flooding, and only then consider whether risk can be managed. A sequential test for flood risk that has not been properly carried out cannot be cured by a well-written evacuation procedure. The guidance is also explicit that the ability to evacuate does not make a site safe for its lifetime, and that safety for the development's lifetime, including climate change allowances, is the test the exception test applies.

So when an objector argues that a scheme is unacceptable because people would have to be evacuated, the planning answer is about the sequential and exception tests and the design flood levels, not about the quality of the plan. And when a developer argues that an evacuation plan solves a safety concern, the same reasoning cuts the other way.

What a developer can usefully offer

A scheme in a flood risk area can make itself much easier for emergency planners to support.

• Finished floor levels set above the design flood level including the relevant climate change allowance, evidenced in the flood risk assessment rather than asserted.
• A dry or safely passable pedestrian route to land outside the flood extent, drawn on a plan with levels along it, rather than described in words.
• A refuge at a level above the design event where egress cannot be guaranteed, with the depth and duration assumptions stated.
• Resistance and resilience measures in the building fabric, which reduce the recovery burden on the authority as much as the loss to the occupier, as set out in residual flood risk and property flood resilience measures.
• A flood response plan written for the actual occupier, with named roles, trigger levels taken from the warning service, and a copy lodged with the managing agent rather than filed with the application and forgotten.
• An offer to register the development for flood warnings at occupation and to pass the information to each new occupier.

The last point costs nothing and is the one emergency planners mention most often, because the single biggest failure in a real event is that the people at risk were not signed up.

This is general guidance, not legal advice. Check the position with your local planning authority, the lead local flood authority and the council's emergency planning team before relying on it.

To see which flood and drainage documents a site is likely to need, enter your postcode on PlanScope and work through the guided questions. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.