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MEETING WITH TREASURY MINISTER

Letter from Tom Crossett, Lewes Flood Action, to Norman Baker MP, 13th June 2004

You asked for Lewes Flood Action comment in advance of your meeting on 29th June.

We think it is disgraceful that nearly four years after a disastrous flood there is still no comprehensive plan to reduce flood risk in the town and that practical action to improve the situation will not start until the 19th June.

We believe that the Treasury is directly responsible for;

1. levels of public investment in flood and coastal erosion management that are entirely inadequate in relation to previous understanding of the threat let alone the grim picture that has emerged from Foresight.
2. rules for allocation of these funds that do not give adequate weight to the people factor including the need to view communities as a whole. People in Lewes are suffering unacceptable levels of stress and our town will be blighted by schemes that offer protection to some but not others.

Treasury may argue that;

1. flood and coastal erosion management investment has increased spectacularly in recent spending reviews. This is true in relative terms but probably not in relation to absolute need.
2. there is not sufficient civil engineering capacity to build defences faster. This is not true in this part of the world. In January Peter Midgley told the Sussex Flood Defence Committee that he had a “needs based” programme worth £30 million ready to roll but he only had £20 million. The previous autumn growing understanding of the scale of the flood threat countrywide coupled with shortage of resources forced the Environment Agency to alter the whole balance of its strategy from emphasis on defence to support for emergency response all relevant issues are being addressed in the DEFRA strategy review.
3. All relevant issues will be addressed in Governments Review of flood and coastal erosion management strategy. LFA has been following the review in detail and is worried that the outcome will be to smother action with an avalanche of daughter reviews LFA welcomes recent relative growth in investment but notes that it is from a low base.

Following the public meeting that you spoke to in January about 125 of your constituents have written to Gordon Brown. As you know replies have not been encouraging. Angela McPherson has been looking after this initiative. She is away at present but I hope that she will be able to bring you up to date when she returns.

Finally although we are concerned first to get action in Lewes we hope that you will remind Treasury that Lewes is the shape of things to come. Like Lewes many places up and down the country bask complacently behind flood and coastal erosion management arrangements that are not to bad by the standards of yesteryear. Foresight has shown that however our economy grows and our society develops risks will grow faster. The good news is that we will be able to afford to deal with the problem. The treasury must not get in the way!

As I explained to you on the telephone I shall be away from 19th June but should be happy to give you or your colleagues further information. Meanwhile I attach some questions and answers to amplify the points that I have made.

Tom Crossett

What are current flood risks to Lewes?

Research published in the first draft Sussex Ouse Flood Management Strategy allows us to estimate how frequently the Ouse will overtop current flood defences in various parts of the town and to show how these would be affected by defence measures.

Frequency figures say nothing about when floods will take place. It could be tomorrow. They can be increased by poor maintenance, climate change (doubling risk in Lewes over next 80 years expected by EA) or changes in land management up or downstream. Flooding can also be caused in other ways eg from sewers, run off or rising groundwater.

The EA agreed LFA estimates of overtopping risk in August 2003 but now disputes the 125 year undefended figure for Malling Brooks.

Are these risks acceptable?

No, there should be timetable to deliver a consistent standard protection of at least 1:200 throughout the town. Meanwhile flood warning and support for response and flood resilience should be improved. Looking further ahead no one should live in fear of flooding. This will require regeneration of some central areas in Lewes. Government should fund action within the new planning system for immediate work. Policies should allow for development/amenity land swaps.

What did the 2000 flood cost?

The EA has used tables prepared by Middlesex University in 1992 to estimate the cost of the 2000 flood to the national economy.

Figures published by the EA suggest that the financial cost to the people and businesses of Lewes was greater by a factor of about 2.4 ie £82 million.

What did the 2000 flood cost apart from money?

Great damage to health and the vitality of the community. Groundbreaking research in Lewes has been published at last. It showed that the psychological damage caused by flooding is much greater than had been thought hitherto.

1. The research paper can be found at http://www.hpa.org.uk/cdph/issues/CDPHvol7/No1/7(1)p56-63.pdf
2. The Lewes Flood Recovery Group comprises:
   The Health Protection Agency Communicable Disease Surveillance Centre and Local and Regional Services,
   The Royal Free and University College Medical School,
   Lewes District Council,
   Brighton and Hove City Primary Care Trust,
   River Lodge Surgery Sussex,
   London School of Tropical Medicine and Hygiene

Health and other social factors must be given greater weight when determining public investment in flood and coastal erosion management.

Where has the Sussex Ouse Flood Management Strategy got to?

A first draft was published in September 2002. DEFRA and the EA then agreed that more work was needed to clarify technical and financial issues. This is still underway and appears to be causing problems. Issue 5 (May 2004) of the EA/Local Authority Strategy Newsletter says that the amended Ouse Valley Flood Management Strategy will be submitted to DEFRA in May and published in the autumn, when DEFRA’s view is known. (Newsletter issue 1 said submission at the end of 2003, issue 2 repeated the target, issue 3 said submission Spring 2004, issue 4 said submission February 2004 with agreement in May.

LFA is appalled by this delay and calls for the EA to give an early indication of what is being proposed. The stakeholder group should be convened immediately.

What has been going on meanwhile?

A lot of talking as the following chronology shows.

0use Valley Flood Management Strategy - chronology.

2002

1. July 24th Presentation to SFDC
2. Sept 11th Exhibition and public meeting in Lewes
3. Disappointment at the time elapsed since October 2000, but recognition of the essential research completed.
4. Qualified welcome because of inequalities in standards of protection within the community. Total capital cost £6.4 million
5. LFA campaign for equality of treatment within a 1:200 standard of protection
6. Sept 27th LFA writes to EA (Doc 1)
7. Nov 11th LFA meets EA to resolve outstanding issues. (Doc 2)
8. Dec 14th LFA writes to EA re unresolved issues (Doc 3) Reply overtaken by events.

2003

9. 11th January East Sussex CC announces that it will support and fund the EA proposed programme of necessary flood defence work
10. Widely reported and welcomed.
11. 3rd February Letter to RFDC Chairmen and associated table indicates that Ouse Valley Flood Management Strategy not approved and that Sussex does not qualify for the higher rate of flood defence grant.
12. 14th February Elliott Morley announces more money for priority flood defences in places like Lewes... if they can meet set criteria.
13. 17th March Agency press release summarises progress, indicates that work should start soon on Malling Brooks cell notes that DEFRA and EA agree that the Ouse Valley Flood Management Strategy requires more work.
14. 27th March LFA writes to EA to express dismay.
15. 24th April DEFRA statement “In the case of Lewes it is not possible to identify fully its priority until the flood mitigation strategy is complete though first indications are that not all parts of Lewes fall into the highest category.”
16. 29th April LFA meets EA and LDC to discuss outstanding issues
17. 30th April Black & Veitch consult an odd assortment of people on options for Malling Brooks. (Later disowned by EA who said that the main opportunity for consultation would be at the time of planning application.)
18. 6th May LFA writes to EA on unresolved issues requesting formal confirmation of LFA interpretation of Ouse Valley Flood Management Strategy flood risk estimates.
19. 26th June EA writes to LDC indicating that flood defences for cells 4-5 improbable.
20. 27th June LFA writes to EA expressing concern. Reply awaited
21. 1st July LDC rejects outline planning permission for redevelopment of the North Street area linked to provision of flood defences on grounds that excessive emphasis on high quality residential property was inconsistent with local plan.
22. Early July First edition of news letter published. Describes strategy review and announces work on Malling Brooks in early 2004
23. 29th July LFA meets DEFRA, the EA and LDC in London. Site investigations have shown that flood walls in Lewes are in a worse condition that had been hoped and that the cost of the strategy was in the region £8 - 25million. Bigger local contributions would be needed. In the longer term flood defence policy would require a risk based rather than reactive approach.
24. 4th August Peter Migley replies to LFA letters of 6 May and 27 June indicating the need for external contributions to the costs of defences in cells other than Malling Brooks and confirming current flood risks for all cells.
25. August DEFRA announces a review of strategy for flood management and coastal protection for completion by October 2004
26. 10th September Elliot Morley “Lewes is not the easiest place in the world to install flood defences but I can assure him [Norman Baker] that they will be installed. We have approved the first cell and I am confident that the second cell will be approved.”( Hansard link LFA\corresp\2003\GK -TC 17 Oct.)
27. September. Second issue of Newsletter circulating, Revised strategy to go to DEFRA by the end of the year; Malling Brooks planning application in November and if approved work in February, opened discussion of developer contributions - the EA and LDC are producing guidelines.
28. 7th October EA reconvenes Ouse Valley Strategy stakeholder forum. LFA raises concerns about impact of Malling Brooks defences on flood risk elsewhere (LFA/SHG/Atkins - Jolley 13 10 03)
29. 14th October EA launches “Beyond flood defence; a new approach to flood risk management.” More emphasis on self help
30. Autumn 2003 rumours of financial crisis circulate -
    a. following the review of flood defence funding DEFRA transfer responsibility for critical ordinary watercourses and administration to the EA without the necessary funding;
    b. EA believes that a needs based programme for Sussex would require a 20% increase in Council contribution.
    c. Alleged that the EA told the Sussex FDC on 10th September that if the full 20% increase was not granted schemes in Lewes and Pevensey would be held back.
31. 17th November. 3rd issue of Newsletter published.
    d. Revised strategy to be published when approved by DEFRA - hopefully Spring 2004,
    e. Malling Brooks scheme
         i. submitted to DEFRA for approval,
         ii. environmental impact assessment in progress,
         iii. planning application soon,
         iv. work in Spring 2004 if permissions are in place.
    (e-mail copies from Tom Crossett ref LFA/media relns/nlnovo3.)
32. 21st November Peter Midgley tells the Sussex Express that work on defences in the Western bank of the Ouse north of the Causeway will start after the Malling Brooks scheme has been completed.
33. 28th November DEFRA tells NSCA conference the “points” threshold for 2004/5 is likely to be in the region 20 rather than 16 as foreshadowed in their February letter to FDC Chairmen

2004

34. 7th January. Sussex area flood defence committee told that DEFRA has approved the Malling Brooks scheme but that financial difficulties mean delay of completion until mid 2005. Financial provision in the forward look for work on 6 other flood cells to be completed by 2007/8, but no detail available until DEFRA has approved strategy hopefully in May 2005. (see MD\LFA\Action plans\fdc report jan 04) Total cost of strategy £11.5 m
35. 15th January Town meeting expresses outrage and incomprehension at further delays. (See LFA\MD\public mtgs\Jan04 pub mtg follow up and \corresp\2004\MM-Peter Midgley 21 1 04)
36. 15th January 4th issue of joint Newsletter announce exhibition on Malling Brooks planning application will take place on Feb 10 - 14. also that there will be compensation for damage caused by “knock on” flooding.
37. 12th February exhibition on planning application reveals that the Malling Brooks Scheme will increase flood risk for 29 unidentified properties.
38. 20th Feb Chairman asks LDC to make publication of full OVS a condition of planning consent. (MD\LFA\Malling Brooks\planning app resp feb 04)
39. 26th February TC sends technical queries on MBS to RuthJolley. (MD\LFA\Malling Brooks\Ruth Jolley 26 Feb)
40. 5th March Chairman writes to Peter Midgley expressing concern that Councillors will have to determine the planning application on totally inadequate information. (MD\LFA\Correspondence\...
41. 18th March Peter Midgley writes to Chairman defending EA position (MD\LFA\Malling Brooks\Midgley messer 18 Mar 04)
42. 20th March TC outlines 4 track stategy for flood resilience in Lewes to Nat. Conference of NFF in 30 minute talk “Beyond Anger.”(NFF\Conferences\2004paper \OLv6
43. 23rd March Ruth Jolley replies to TC 26th Feb offering meeting. (MD\LFA\Malling Brooks\Jolley 23rd Mar)
44. 25th March Chairman Sussex LFDC writes TC pointing out that any delay to MBAS could lead to diversion of funds to alternative schemes that have priority and are ready to go. (Appended to LFA\Action plans\FDC report Apr 04)
45. DEFRA scheme priorities incl 04 05 downloaded from DEFRA website (MD\LFA\FD Funding Oct 02 on\04-05\DEFRA EA 04 05.pdf)
46. 31st March TC meets Ruth Jolley & Graham Kempster to discuss progress of MBFAS Agree that 29 knock on properties are notional and identity depends on nature of flood between approx 5.5 and 6.3 m, fail to resolve Malling Brooks threshold height.
47. 6 April Ruth Jolley Clarifies Malling Threshold but does not resolve (MD\LFA\Malling Brooks\Ruth 6 April 04)
48. May 4th LDC applies for footpath diversion order to allow work on Malling Brooks scheme
49. May 19th Press report that money has been found to complete the Malling Brooks scheme in FY 2004/5
50. May 23rd 5th issue of Joint Newsletter announces work on Malling Brooks .
51. June 7th Contractors move onto Malling Brooks site.
52. June 19th Breakfast photo opportunity to launch work on the Malling Brooks scheme.

Doc references are to LFA\DEFRA\Agenda 29 July 2003

TC 14th June 2004

Action is needed not words!

What do we know about the revised strategy?

Last January the Agency presented indicative budgets to the Sussex Area Flood Defence Committee and the Committee accepted the “low Council Tax” scenario causing a delay on Malling Brooks that has now been averted.

In March DEFRA published revised priority scores for flood defence projects in England,

A covering letter from Elliot Morley that said that grant aid would be available for projects that scored more than 20 points and continued “I will provide you with indicative information for 2005-06 as soon as possible, but in the meantime we will continue to consider projects for start in 2005-06 against our currently-announced indicative threshold for that year of 10. Any subsequent change to the threshold will not affect projects already approved but unapproved projects will be required to achieve the new indicative threshold once it has been announced.”

Putting all this together it seems to me that, by completing Malling Brooks in 2004 the EA will save £790,000 in the following year. This should be used to bring forward vital work on Cliffe and the Downstream storage. This already has sufficient points to justify action, if the EA acts before Elliot Morley moves the goalposts!

LFA is pressing the EA to continue acting on individual schemes in advance of agreement on strategy so that Cliffe can be protected immediately after Malling Brooks.

Why is Lewes Flood Action worried that the Governments review of flood and coastal erosion management strategy will smother action with an avalanche of daughter reviews?

Tom Crossett of LFA has been monitoring the review for the National Flood Forum, which he now chairs. His conclusions, attached, are supported by the Group.

National Flood Forum Board Meeting 8th June 2004.

DEFRA flood and coastal erosion management strategy.
Report by Tom Crossett on the Stakeholder Group Meeting - 24th May 2004.

Colleagues have seen the comments on the latest draft strategy that I circulated before the Stakeholder Group meeting on 24th May. I attach a revised version produced in the light of very helpful comments from Huw Payne and Anthony Crawshaw and discussion at the meeting. The aim is to prepare the ground for an NFF reply to a consultation document that is expected in July.

You will have noticed that the DEFRA document is not a draft strategy but “Likely key elements of the new strategic direction”. It is a weaker document than that circulated in November. Commitment to action has been watered down to commitment to think about the need for action. This is worrying and indicates opposition in other Whitehall departments. New circumstances, especially the bleak message from Foresight require a stronger document. What is on the table strengthens the hand of cynics who see the strategy as substitution of words for action.

• NFF should be positive. We should welcome the medium term (25 year) strategy both as a statement of the processes that will translate the aspirations of the DEFRA vision into practical action and a commitment to urgent action on new circumstances. It should confirm;
• that both the medium and long term (Foresight) view will be reviewed every five years.
• DEFRA will implement the medium term strategy by five year action plans (taking the review of flood defence funding, warts and all, as a foundation.) These should set targets and inform the spending review. Action plans should;
       o announce commitments by other Government Departments and partners eg LAs.
       o list delegated responsibilities eg to the Environment Agency
       o say what is others eg those at flood risk and the insurance industry must to do if targets are to be met. (Major role for NFF in this context.)
• In the 2006 strategy (which should also be the next 5 year action plan!) we should be looking for measures to improve flood resilience by improved:
       o community understanding of flood risk
       o flood warnings
       o definition of and support for appropriate community preparation response
• The 2006 strategy will be Governments first response to the Foresight study. The study concluded risks from flooding and coastal erosion will increase over the next hundred years, but however our economy grows and our society develops we should be able to afford to contain and in many cases reduce the probability and consequences of flooding and coastal erosion. Governments Chief Scientific Adviser drew two key messages from the study;
       o Continuing existing policies is not an option.
       o Risks need to be tackled on a broad front.

He concluded “Hard choices need to be taken - we must either invest more in sustainable flood and coastal management or learn to live with increased flooding”. The strategy must accept this challenge and explain how these choices will be made and give commitments to urgent action that is essential now. NFF speaking for those in the front line and wants to see;

• Inclusive debate of what is a “reasonable” standard of flood protection translated into standards that must be attained eventually and pragmatic objectives that reflect what must be done in the next five years to protect the prosperity and vitality of our communities and our quality of life.
• Procedures to make the hard choices that Sir David King refers to. We welcome the strategy’s commitment to multi-criteria analysis (MCA). But the jargon should not obscure the fact that the technique is merely an aid to transparency. It makes clear what factors are being considered in decisions and what weight is given to each factor. We must guard against the possibility that scope for almost infinite refinement of MCA is used to delay decisions or to obscure responsibilities.
• In addition to procedures the strategy should show;
       o How more weight will be given to social factors
       o How the broad balance (best practicable flood management option) will be set between support for those who have to live at unacceptable levels of flood risk and risk management by defences and regeneration in the at risk areas and more widely.
       o How funding will be developed. Risks must be tackled on a broad front in the context of sustainable development but the approach will cause difficulties in attributing costs and benefits. These difficulties must not be allowed to cause delay. The strategy should be part of a wider water management picture. It should aim to force the pace in Europe.

Recommendation.

1 Subject to amendment by Board Members, we comment to DEFRA as indicated above and in the revised stakeholder forum paper.

2 We seek a bilateral meeting and/or participation in appropriate workshops to state our case during the consultation period. (12 weeks from mid July.)

3 We include an article based on this paper in the Newsletter, encouraging affiliates and associates to contribute to the consultation.

4 We promote our views with others, notably LA’s

MD\NFF\policy\network\defra\update strategy post mtg revision

comments by TC on the DEFRA paper in italics
2nd draft 6 June 04

WORK-IN-PROGRESS

This paper is for discussion at the Stakeholders Forum meeting and does not necessarily represent THE final views of Defra.

PAPER FOR FLOOD MANAGEMENT STAKEHOLDERS FORUM:

likely KEY ELEMENTS OF THE new strategIC DIRECTION

Introduction

1. This paper is intended to update stakeholders on current thinking about the likely contents of the consultation document on the strategy it is planned to issue in the summer. There will be a full 12-week formal consultation period, and we plan to adopt a proactive approach to it. We will outline the arrangements at the meeting. It is not the intention that this meeting of the Stakeholders Forum should pre-empt the consultation exercise, but it would be helpful to have the reactions of the Stakeholders Forum to the topics it is currently intended to cover, in particular whether there are any high-level issues the Forum wishes to raise before the formal consultation is launched. It should be stressed that what follows constitutes work-in-progress, and does not represent the final position on what will be the content of the consultation document.
   The introduction should explain in general terms what the strategy is and how it relates to policies and plans on other timescales and other levels of detail. We note that revision of MAFF/DEFRA/NAW 1993 aims and objectives is covered by another document. But it will be important to show in broad terms how the 1999 High Level Targets exercise and the Review of Flood Defence Funding are being implemented and how these medium term(5 year?) initiatives relate to the annual spending review. The strategy should give commitments to processes that will secure swift and appropriate responses to circumstances as they unfold on the “Foresight” landscape. Success in the integrated portfolio approach advocated by Foresight depends upon effective relations between partners, notably Government, the EA, LAs and other stakeholders in communities at risk. The strategy should make proposals for improvement. So far as the EA is concerned NFF believes that there is a case for considering separation of the operational and some consenting roles of flood management should be separated. The ea would handle those consenting roles that needed to be co-ordinated with their other duties. A flood management agency would undertake the other flood management roles such as strategy, design and construction of schemes, maintenance of defences, flood warning, dealing with flooding aspects of planning applications and consenting of structures from a flood management aspect etc. The board of the flood management agency would comprise the chairmen of the regional flood defence committees, perhaps with a separately appointed overall chairman. They would distribute funding and determine policies. The problem with bringing in coast protection is that local authorities have considerable interests in their promenades that also act as coast protection to seaside resorts. These promenades are often the reason such communities actually exist, and they would not wish to give up responsibility for them. The benefits of such separation of duties would have to be balanced against the costs of yet more reorganisation when the urgent need is to get on with the job. ff
2. Contributing to sustainable development
3. The consultation document is likely to suggest ways in which flood and coastal erosion risk management can make a greater contribution to sustainable development. And how other initiatives in sustainable development will contribute to flood risk and coastal erosion management.
4. First, it is likely to propose an evolutionary approach under which our mechanisms for assessing of flood and coastal erosion risk will over time take more account of environmental and social factors as well as of economic costs and benefits. NFF supports an approach which is risk based rather than reactive. Improved risk assessment is a top priority. Of course we must build on what we have, but the term evolution is does not convey the necessary urgency! There should be firm commitment to initiatives that take forward the “issues” addressed below.

Possible issues include:

• Consideration of the need to develop, within a nationally consistent framework, approaches such as multi-criteria analysis (MCA) so as to obtain a truer assessment of costs and benefits and take account of local considerations; the need to improve techniques for expressing environmental and social costs and benefits in monetary/quantifiable terms. Need has been established and we understand that work is already underway. The priority is to deliver an interim systems that builds on that used for appraisal of water company investment in infrastructure and the relatively crude approach adopted for scheme prioritisation advanced in LDW 14. The scope for almost infinite refinement of MCA should not be used as an excuse for delay in action to give greater weight to social and environmental factors. That said we must bear in mind that MCA is not a panacea. It necessary but not sufficient to deliver the most appropriate balance between economic development, social justice and the environment. The approach simply clarifies and orders stakeholder positions and other relevant factors. It facilitates judgement and makes the judge’s deliberations more transparent. The complexity of the Foresight landscape means that influence and inclusion will be issues demanding real debate and the strategy should commit to it.
• Consideration of whether there is a need for better stakeholder participation at the national, regional and local scales when assessing risks, prioritising action and appraising different schemes, and the consultation document will seek views on how this might be achieved. Need has been established; The question is how to make progress in the light of not only emerging arrangements for flood and coastal erosion but also wider changes such as development of the planning system management funding and advances in techniques for stakeholder engagement. There should be commitment to review, but in the interim we recommend the following measures to improve transparency and engagement.
       1. National - justification for size and regional allocation of block grant should be made more transparent by Government and the EA Board.
       2. Regional - NFF favours retention of two tier FDC’s to provide transparency and accountability. However if the single tier approach is adopted there must be commitment to making the new system work. (Our draft letter to Peter Bye refers, see Annex 1)
       3. Local. Loss of area FDC’s is a retrograde step. There should be guidelines for contact between local communities and EA officers. Procedures for reference of controversial issues to the new Committees will be needed.
  At all levels procedures will have to accommodate short lead times and provide accountability. Improvement in stakeholder participation is crucial both to development of MCA that we discuss above and the standards and objectives considered below.
• Consideration of whether in view of DEFRA’s strategic priority of sustainable rural communities, there is a need to consider whether there should be changes to the system of “indicative” standards of protection - which give a broad indication of the levels of protection appropriate to different types of land use - so that the same indicative standards apply to both urban and rural communities. (The actual standard delivered in an individual case would continue to be determined by the appraisal arrangements, including a comparison of all the costs and benefits.) NFF understands from FCDPAG 3 (S6.1) that indicative standards are intended to provide a screening tool rather than an indication of a service standard appropriate to land use. However service standards related to land use are necessary if priorities for action to improve sustainability to be ranked. The strategy should commit to developing such standards and related pragmatic objectives that accommodate affordability and the diversity of flood and coastal erosion management issues. (depth/duration, coastal/river/groundwater/sewer/etc.)The system of standards and objectives that provides the basis of the National Air Quality Strategy provides a pointer as does the concept of fitness for purpose that is used to determine standards for remediation of contaminated land. From the NFF perspective current indicative standards are too low since they expose communities to risks that are unacceptable in modern society. Development of standards and objectives should therefore be linked to the development of MCA. It is also essential to underpin policy shift from reactive to risk based. Flooding is a traumatic but fortunately rare experience. Victims rightly and understandably want their risk to be reduced to zero and usually think first of an engineering solution. Their concern is with what could happen to them tomorrow not with what will happen to a cohort of the population at some time in the future. Flood victim experience should inform standards but it not distort priorities within a risk based approach. If communities that experience a flood have a reasonably high standard of protection, there is no justification for increasing the standard beyond any prevailing standard/objective. Such communities will need to learn to accept that and the fact that the likelihood of another such event is small but not zero. Communities with a lower standard of protection, but who have been fortunate not to have suffered flooding from relatively modest events, must be protected first. (However the extent to which visible action in the immediate aftermath of a flood can help to heal psychological damage needs to be considered, and factored into cost benefit calculations.)

5. It is likely that the consultation document will say that:
   

• broadly speaking the aim is as a minimum to provide the “indicative” standards of protection - in terms of probability of flooding - for different land use types, much as under the current system, but the extent to which we can do so will depend on the overall funding available and provided the there is a cost/benefit ratio of at least 1; This proposal keeps the cart before the horse. Improved risk assessment is beginning to make it possible to estimate the investment needed to provide chosen objectives for protection. A system standards and objectives could be used as a basis for debate of how that investment should be phased in relation to competing claims and changing threats. Foresight has provided early insight. Whilst the study underlines the gravity of the situation it indicates that standards of protection can and should be improved under all scenarios. In the wake of Foresight and the transfer of responsibility for the process to DEFRA there should be commitment to a quinquennial assessment of needs and affordability, building on the study, “Assets at risk”, work by the ABI.
• as far as concerns containing the increase in the consequences of flooding that will result from the increase in the value of assets at risk, the strategy as a whole (such as the proposals on land use planning) are designed to minimise the consequences of flooding; We are not sure what this means. But if it is a commitment to “least cost planning” we welcome it since it will increase returns on public and private investment and thus maximise the rate of improvement. Whilst there will be a majority of “winners” policies must recognise that there will be losers who should be compensated. Valuation must include social environmental and economic factors. Failure to express factors in monetary terms must not be used as a reason to exclude them from appraisals.
• the extra costs indicated by the Foresight Future Flooding project as being necessary over the next 80 years or so should be affordable when measured as a percentage of GDP. This observation is encouraging but requires contingency plans. There should be a commitment to continuation of scenario approach adopted in Foresight coupled with development of procedures for responding to the unexpected which could be well outside historic experience. In short we need to consider how to decide what to do if projected costs appear to become unaffordable.

6. Secondly, the consultation document is likely to propose building on what we have already done by further implementation of flood management and coastal erosion solutions which work with natural processes. This will involve considering options which:

• Restore natural processes;
• Realign river corridors and shorelines;
• Remove Government-funding for the maintenance of defences where this is no longer justified.

7. An approach along these lines would be in line with the Water Framework Directive (which will be a strong driver towards selecting solutions that work with the natural processes of rivers and the sea). The approach would include water storage and realignment of coastal defences, both of which have been identified by the Foresight Future Flooding project as responses that score well in terms of sustainable risk reduction. NFF supports the approach advanced in paras 5 -7, where appropriate, but not as an overriding principle. Clearly these are important tools within the integrated portfolio of responses discussed below and should incorporated into MCA.
8. To ensure the approach is delivered, the consultation document may suggest that targets for wetland habitat creation should be put in place for the Environment Agency. This would make a contribution to meeting Biodiversity Action Plan targets. NFF recommends caution and calls for balance. There should be complementary targets for social gain and economic targets should be expressed in comparable terms. People will need to be reassured that the EA , which rightly champions the environment in many of its roles, does not have an inappropriate environmental bias in the flood management context. eg in advice on planning applications and its development of integrated flood management strategies. The issue again underlines the importance of rapid development of MCA.

Integrated portfolio of responses

9. One of the key messages of the Foresight Future Flooding project was that an integrated portfolio of responses to deal with flood and coastal erosion risks will be more cost-effective and more sustainable than relying on engineering solutions alone. Working with natural processes will be part of that portfolio. The consultation document will deal also with other elements of the portfolio. Brief details of the main elements are set out in the following paragraphs. NFF supports the integrated portfolio approach. The strategy should propose mechanisms for determining the best practicable flood and coastal erosion management option (BPFMO, by analogy to BPEO) both strategically and on a project basis. The aim would be to secure the most effective balance between, defences, regeneration and self help through warnings, preparation and insurance having regard to the full spread of stakeholder interests. There should be consistency of approach in MCA and BPFMO and there could be synergy. The strategy should also make clear delegations of authority.

(i) Land use planning

10. This was highlighted by Foresight as a key response in terms of risk reduction and sustainability. The main messages are likely to be:

• re-statement of the existing Government commitment to ensuring that its development and planning policy seeks where possible to reduce, and certainly not to add to, the overall level of flood risk;
• extension of the Environment Agency’s statutory consultee role to all planning applications in areas notified by the Agency as at risk of flooding or likely to add to flood risk;
• if further monitoring indicates a significant reversal of the recent decline in developments proceeding against the advice of the Environment Agency, a commitment that the Government will consider putting in place call-in procedures for such developments;

The consultation exercise will seek views on various options concerning the production of flood risk assessments and whether their production should be made compulsory. NFF supports the main messages but considers that there are wider issues. These stem from the acute shortage of development land and the importance of maintaining the social and economic fabric of communities that have developed in, what wisdom of hindsight shows, to be inappropriate locations The need is to increase the weight given to flood risk as one of the material planning considerations, but to refine criteria for determining when development or redevelopment of the floodplain might be justified. As knowledge improves dogma should be tempered by common sense. There should be incentives and resources for floodplain re - development briefs that address questions on long and with adequate precaution. Consideration should be given to planning exchanges; for example contaminated brownfield sites in the flood plain might be devoted to conservation and amenity use in exchange for greenfield land. In terms of national development the need is for comparison of the benefits of securing development land by redevelopment of the flood plain as opposed to other ways eg the remediation of contaminated land. Plans should be laid having regard to the normal turnover rate of buildings and infrastructure, eg 3% pa for light industrial and retail space, 1% pa for the residential housing stock and will, of course, need to adopt the scenario approach.

(ii) Integration of drainage planning in urban areas

Foresight drew attention to the potentially serious risks posed by localised flooding in towns and cities caused by the sewer and drainage systems being overwhelmed by sudden localised downpours. (As part of the strategy work we have also done some innovative work on the threat from groundwater flooding.) Recent experience of flash flooding has again illustrated the importance of this area.

11. The consultation document is likely to seek views on a proposal that integrated drainage plans be produced so as achieve better co-ordination between the different bodies responsible for addressing these various sources of flooding. The aim would be to achieve better overall management of “surface water” drainage, such drainage being defined as drainage of what is sufficiently clean as not on its own to count as sewage. This has the potential to benefit not just flood management, but water resource management and water quality as well. (We see this as a tangible benefit flowing from the decision in 2003 to combine flood management with other water policy responsibilities in the same DEFRA Directorate.) NFF supports action in this vital area. There should be immediate adjustment of;
         - the MCA drivers in next round of water company asset management MCA to give greater weight to the social impact of sewer flooding
         - guidance on urban surface water management.
    Reallocation of responsibilities and funding pressures are leading to a decline in the capabilities of la drainage departments. This needs to be reversed or compensated for. Looking further ahead we believe that sustainable river flood management should be addressed within catchment management plans. The challenge should not be underestimated. Catchment management plans that try to address all aspects of management of the catchment in one document may fail to do justice to any of them, particularly flood management. On the welsh coastline, and the Dee estuary was a particular example, individual plans were prepared for each aspect that required management. A shoreline management plan covered flooding and coastal erosion. These plans were compared and areas of conflict between them identified, which was not as frequent as one might have imagined with each body trying to take views of others into account. A sub-committee of all the various managers talked the conflicts through with the managers of the conflicting plans and the set of agreed individual, detailed plans became the overall strategy for the particular length of coastline or estuary A similar approach could be adopted for Rivers, using Catchment Flood Management Plans as the basis for setting out the aspirations for flood management. Integrated Surface Water Drainage Plans should be separate from the Catchment Flood Management Plans, the latter dealing with water on the river side of any defences and the former on the land side. Interactions between the two - overtopping of defences from the river side and discharge of land side drainage to rivers - would need to be considered. The strategy should commit to pilot studies.
12. The consultation document may also seek views on where lead responsibility should rest for the production of such integrated drainage plans, and on the possibility of pilots and the arrangements for funding them. Long term responsibility for implementation needs to be addressed in advance of pilots

(iii) Flood resistance and resilience measures

13. Resistance measures are aimed at keeping water out of a building, or at least minimising the amount that enters, whilst resilience measures are aimed at facilitating the recovery of buildings following a flooding event. insofar as they relate to new buildings in particular these measures are complementary to the land use planning measures outlined at (i) above.
14. The main points in the consultation document are likely to be:

• confirmation that the Building Regulations can and should be used to promote the inclusion of flood resistance and resilience features in new buildings;
• the Building Regulations already contain provisions that can have secondary flood resilience benefits; in the light of the confirmation referred to in the previous indent and of the results of research due to start this year, the Government may consider amendments to the Regulations to promote further resistance/resilience;
• Government encouragement to local authorities in high-risk areas to consider requests for assistance with flood protection/resilience products under existing arrangements which give local authorities more flexibility to decide how they provide home improvement grants, loans, help and advice to the most vulnerable in their areas;

how can owners of existing properties be encouraged to install more flood resistant and resilient products?

NFF supports these measures but considers that they do not go far enough. The costs and benefits of private or local authority investment in flood resilience need to be considered just as rigorously as public investment in collective measures. However the basis for such appraisal is weak and poorly understood by those at risk. Research and education is required to empower individuals and local authorities. In particular individuals need to be able to establish their flood risks and understand the measures that they could adopt to mitigate particular levels of risk. The development of the current Indicative Flood Plain Maps into more comprehensive Flood Hazard Maps, containing information on defence standards, depth of flooding etc. should be taken forward as a matter of urgency to enable individuals to establish their individual flood risks. The strategy should set targets for progress and quality assurance. Errors can have serious consequences and undermine confidence. We understand the pressures that lead the EA to introduce the policy changes announced last autumn in “beyond flood defences”. However we are very worried that communities, households and businesses are very poorly placed to respond to them. More specifically it would be rational for retrofitting of flood protection/resilience to be developed as an extension of the same integrated system as capital flood defence. This would get round the existing problems of flood protection provision affecting the cost:benefit score for flood defence and put in place a range of flood alleviation options running from flood defence through temporary barriers to household protection and resilience.

The need is for a free information service on the characteristics of the expected flooding (source, depth, frequency, duration, velocity, quality of flood warning and lead time, content of floodwater) together with advice on the most appropriate flood protection/flood resilience options in view of the flooding, the characteristics of the property and the needs of the occupants. This should be coupled with;

• A grant system to encourage installation of household flood protection or resilience measures.
• The removal of vat from flood protection products.
• A closer co-operation between the agency and the insurance companies who in many ways hold the key. Insurers need to make the provision of flood cover dependent upon take up of flood warning - this would also drive the improvement of flood warning systems - and upon the installation of flood protection, or resilience, or both as necessary.

(iv) Flooding of and from the transport network

15. The main issues raised in the consultation document are likely to be:

• views are likely to be sought on the possible production of guidance for use by local authorities in respect of “non-strategic” roads (which account for the majority - about 97 per cent - of the road network). Such guidance would be a sister document to the design manual already in use for strategic roads which fall to the responsibility of the Highways Agency, and would draw from that document as appropriate. The guidance would cover design and maintenance issues, and drainage systems in particular;
• whether the urban road network should be covered by the proposed integrated drainage plans - see (ii) above - and it should be possible in such plans to consider how some parts of the road system might be used for flood mitigation in extreme events. For example, it might be appropriate to designate individual roads for use in severe events as flood corridors to move water away, thereby helping to avoid damage to property;
• views are likely to be sought on how the use of railway earthworks/structures as flood defences might be made more effective.

NFF welcomes the intention to include flooding of and from the transport system in the strategy. We note occasional, planned, use of roads as drainage channels and support research and systematic guidance that will allow the practice to be developed and exploited. We also recommend that the vulnerability of the transport system to flooding and its management under flood conditions should also be addressed. Transport can a key aspect of flood response plans so that prediction of the extent of dislocation during flooding is important. Emergency planners should also be able to evaluate the importance of transport links so that non critical links can be closed early in order to avoid damage and risk. Responsibility issues need to be addressed also. Attention should also be paid to pollution risks from transport
Highways play a major part in the causes of flooding. A highway authority can raise a road by resurfacing for example without any permission or consultation, and highway causeways/bridges/culverts that lack sufficient capacity or are of inferior design are a well-documented cause of flooding all over the country.

The strategy should also recognise the need to consider the threats and opportunities created by flooding of other parts of infrastructure besides transport and urban drainage

(v) Coastal Issues

16. The section on coastal issues will seek to open the debate about management arrangements in particular the split of responsibilities between local authorities and the Environment Agency, and about the strategic framework for coastal issues, to lead up to the review in 2007 envisaged in the Delivery Plan for implementing the conclusions of the Funding Review which were announced last year.
17. Other sections of the strategy deal with raising awareness of flooding and with flood warning and emergency responses.

    Flood Management Strategy Unit
    18 May 2004

    ANNEX 1 Effective flood defence committees.

    Self explanatory insert to Bye letter.

    “We have reservations about the transparency, accessibility and effectiveness of the present flood defence committees. We are disappointed that it seems inevitable that representation will be reduced in the new streamlined system. We look therefore to you to work with incoming independent Chairmen to ensure that the new system is more effective despite the initial handicap of an apparent democratic deficit. Measures and good practice that we should like to see you champion include;

• Transparency in relation to the way in which the Board allocates the DEFRA block grant to Committee areas.
• Designation vacancies for independent members with special knowledge of social aspects of flood risk in addition to those reserved for conservation specialists.
• Wider publicity for committee meetings; availability of papers before meetings and draft minutes immediately afterwards, rotation of venues through the region.
• More opportunity for stakeholders to present views to Committees.
• A consistent basis for regular progress monitoring for the whole EA strategy and coherent recommendations for change.
• Stakeholder input to development of a more refined system of priority assessment based on multi criterion analysis, consistent with arrangements for agreement for of water company investment in infrastructure.
• Effective arrangements for Committee involvement in development and implementation of shoreline and catchment management plans.
• A Committee duty to oversee the Agency’s policies on planning advice.

We appreciate of course that the new committees will have to operate at a relatively strategic level. We therefore look to you also to champion effective arrangements for Agency officials to engage stakeholders locally and subject to scrutiny by Committees.”

This page last updated 10 January, 2006