Letter from Lewes Flood Action 13th May
2003
To: Mary Froud, Environmental Scientist
Black and Veitch,
Grosvenor House, 69 London Road,
Redhill, Surrey RH1 1LQ
Consultation on Flood Defences for Malling Brooks
Thank you for your letter to Maureen Messer of 30th April 2003.
Lewes Flood Action welcomes this long awaited demonstration of action
on essential flood defences and the opportunity to comment at an early
stage.
Consultation: I understand from a
helpful conversation with David Wilson that work is at an early stage
and that you have not been able to evaluate fully technical issues that
will have major or perhaps overwhelming impact on option choice..
We understand and welcome the urgency of your timetable but you will
appreciate that your present deadline means that some of our members will
not have had an opportunity to consider the material that you circulated.
It is essential that you follow this preliminary initiative with a consultation
that is wider scope and circulation. That said, we understand also that
there will be consultation on some aspects of the scheme eg choice of
wall finishes at the planning application stage, later in the summer
As a minimum I suggest that your consultation list should include:
- Lewes Chamber of Commerce, c/o Corn Exchange Buildings, High Street,
BN7 2DE, Lewes 01273 488212
- Federation of Small Businesses, 3 High Street, Polegate, BN26 5HA
01323 483352
- Friends of Lewes, c/o Corn Exchange Buildings, High Street, BN7 2DE
- Lewes Partnerships and residents groups in flood cells other than
the one to be defended. (Contact details to follow.)
There should be media releases and a public exhibition/meeting so that
stakeholders who may not have been identified can be informed and contribute.
Strategic issues: In the absence
of an agreed Ouse Valley Flood Management Strategy it is vital that you
consult on strategic issues or allay fears of "knock on" effects.
We welcome Environment Agency proposals to provide a 1:200 year standard
of protection in the Malling Brooks area provided that they are consistent
with our objective of a similar standard of protection for all flood cells.
We are disturbed that one option, Z1, could "potentially slightly
worsen flood conditions in upstream undefended cells at Landport, Malling
Deanery and North Malling".
Since the flood plain is wide between Phoenix Causeway and North Malling
our lay view is that flood levels will be similar in all contingent cells,
so that as well as Landport, Malling Deanery and North Malling there would
be increased risks in North Street and Talbot Terrace and Riverdale (5.9
mAOD and not presently a designated flood cell) until wall levels are
raised to 6.1 mAOD in all cells.
We note that the increased risks arising from option Z1 are due to removal
of the functional flood plain. Our lay view is that the undefended Malling
Brooks is a much larger part of the functional flood plain than the part
of the recreation ground included in option Z1. All other options for
the defence of Malling Brooks would therefore carry the potential to increase
flood risks in undefended cells upstream of the Phoenix Causeway. We should
like to know whether the current review of the Ouse Valley Flood Management
Strategy will lead to revision of flood risk assessments.
We do not believe that flood defence plans for Malling Brooks should
be finalised until risks of "knock on" effects in other parts
of the Ouse Valley have been fully assessed and either:
- you are able to confirm that "knock on" effects are minimal
in the eyes of at risk communities, or
- plans for their alleviation have been agreed.
This position is consistent with our support for the strategic approach
to flood defence advocated by DEFRA.
Downstream defences: We are perplexed
by the recommendation of wall raising to 5.4 mAOD between the Causeway
and Harvey's. Table 2.6 in the Ouse Valley Flood Management Strategy suggests
that a level of 5.7 mAOD + freeboard is necessary to provide a 1:200 level
of protection. We would appreciate clarification, but meanwhile we are
worried that homes and businesses downstream of the Causeway could be
at added risk.
Impact on priority scores for other areas:
We wish to be assured that successful completion of the Malling Brooks
scheme would not diminish DEFRA priority scores for other cells.
Riparian owner contributions: We
have recently registered our concerns about riparian owner contributions.
We should like to know whether progress of the scheme will depend on riparian
owner contributions and if so how when and where they will be sought?
Design principles and preferred options
- The work to defend Malling Brooks should have the minimum adverse
effect on the functional flood plain. This means allowing as much as
possible of the recreational area to flood. The entire community should
be consulted on the acceptability of the Environment Agency's interpretation
of the word minimum.
- We seek passive defences that do not rely on shutting flood gates
or fitting stoplogs, provided that access can be maintained. Effectiveness
of defences is paramount and the costs of maintaining access should
be accepted. This is especially important in Lewes where our small catchment
means that flood warning periods are short and false alarms frequent.
- Defences should be as unobtrusive as possible. This means that defences
should be built as close as possible to residential and business premises
unless there are overriding aesthetic or access reasons why this should
not be done.
- On the "fit and forget" principle, survey and maintenance
responsibilities, e.g. for mowing and litter control on earthbanks,
should be clearly allocated.
- Sufficient information should be provided to enable informed choice.
For example, finish has an important influence on the acceptability
of brick walls.
On the basis of these principles our preferred options are;
- A1 Wall between recreation ground car park and Spences Lane if this
can be done without gates or stoplogs.
- B2 Bridge abutment
- C1/C3, D1/D3 Embankments or walls with passive access arrangements
and subject to further consultation on wall finishes.
- E2 Wall on the boundary of Tesco's car park, subject to further consultation
on finishes and access arrangements.
- D/E Intersection - raised ramps at intersections.
Unacceptable: Z1 Embankment on former railway line alignment.
Since our comments go well beyond your consultation questions I am copying
these comments to Nigel Baker.
I hope these comments are helpful.
Tom Crossett
Copies of the plans referred to are held by Tom Crossett,
Peter Atkins and Duncan McPherson - see the Contacts
page.
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