Section 4: Assessing and managing the risk of flooding from rivers and the sea and of coastal erosion

4.1

Do you agree that as part of the agenda for implementing a robust and transparent system under this new strategy:

a)

That we should continue with work to put in place a multi-level strategic framework for assessing risk in a nationally consistent way?

Agriculture makes a vital long-term contribution to the national economy and a short-term surplus of world food supplies should not effect long-term national strategy.

b)

That the assessment of risk at all levels should take account not just of economic damage but of environmental and social factors as well?

The need to maintain existing assets should be a priority; failure to do so would represent poor value for money.

c)

That the assessment of risk should involve stakeholders at all levels?

Assessment of risk should be properly representative of the views of carefully selected stakeholders with knowledge and experience of flood defense issues

d) 

That the national system of risk assessment should be the driver to secure the most cost-effective risk management action on flooding and coastal erosion, including prioritization?

Local needs should be taken into account in the first instance.

A centralized approach does little for local needs and accountability.

4.2

Do you agree that the methodology for dealing with scheme appraisals should be developed as proposed using multi-criteria approaches to take better account of non-quantifiable aspects?

Yes.  Approval procedure needs streamlining.

 4.3

Do you have any alternative approaches to suggest?

More attention should be paid to maintaining existing assets.

4.4

If you are a practitioner or have used the existing Defra guidance on scheme appraisal:

a)

Do you have any comments on the general level of detail, format or presentation?

The present system can be disproportionate for small schemes.

b)

Do you find the guidance user-friendly and effective as a decision-making support system?

See above

c)

Have you any suggestions on how the format might be made more effective so that the guidance is easier to use and understand?

See above

4.5

Views are requested on factors relevant to sustainable rural communities that might be included in multi-criteria approaches, and on any alternative approaches that might be adopted to take account of sustainable rural communities, whilst continuing to take appropriate account of urban communities.

Rural communities should not be treated with any less importance than urban communities.

4.6

Do you agree that the present approach to climate change is appropriate, and if not can you identify alternative approaches and the benefits that they would provide?

The guidance is appropriate at present, however it needs to be reviewed each time new information becomes available rather than periodically.

4.7

Do you agree that Defra should review its guidance to see if further encouragement can be given to the adoption of reversible and adaptable flood management and coastal erosion solutions? Can you identify ways in which those undertaking risk management activities can be given further encouragement to adopt resilient and adaptable flood management and coastal erosion solutions?

A more local approach could lead to more innovative/cost effective ideas from the local community.

A national framework discourages new solutions as existing solutions are just passed down.

4.8

Do you agree that the current system of indicative standards should continue?

The optimum standard to achieve best value for money should be obtained.

4.9

Do you have any modifications to propose? If so, please identify the benefits and how implementation of the changes should be funded.

There should be a duty on operating authorities to maintain their systems to a nationally agreed set standard of maintenance.

4.10

Views are welcome on a recent research report regarding alternatives to the current approach that might      provide more consistent standards within the same community.

 It is important not to provide extra protection for one area by putting another area at greater risk. We should strive to provide the optimum cost effective standard of protection for all areas.

4.11

Do you agree that the involvement of stakeholders in assessing risks and management options should be in the context of an agreed national framework?

Unnecessary consultation will produce delays to vital works. Stakeholders should have a meaningful interest in the works.

4.12

Do you have comments on the suggested mechanisms for involving stakeholders at each level of risk assessment outlined above?

Appropriate stakeholders should be given a strict time to respond.

 It should be noted that Internal Drainage Boards promote schemes in their own right.

Section 5: Strengthening the sustainable approach: rural land use and managed realignment of flood plains            and the coast

5.1

Do you agree that approaches that work with natural processes to provide more space for water should be identified and pursued wherever possible within the framework set out in Section 4?

We must learn from the past, once a washland is created it will become overtime an important habitat, and flooding the land will cause an outcry from conservationists.

The washland itself may well be protected from flooding by future designations.

5.2

Do you have comments on the proposed realignment policy?

Valuable fossil fuels are used to transport international food in the present era, this seems to conflict with the Governments environmental and energy policies.

Therefore loss of valuable food producing land causes great concern. Defra appear to have no long-term policy for food production and it is not realistic to rely on a worldwide market indefinitely.

5.3

Do you agree that targets for wetland habitat creation to fulfil Biodiversity commitments should be put in place?

Yes, but this should not treated as flood defense expenditure.

Section 6: The role of rural land management

6.1

Do you have any comments on the proposed approach to rural land management?

Stewardship schemes are unlikely to have a major impact in times of severe flooding.

6.2

Do you agree with the suggested approach of using water level management to bring SSSIs into favorable condition?

Yes, if Water Levels are critical to the condition of SSSI.

Section 7: Measures to reduce flood risk through land-use planning

7.1

Do you agree with the Government’s general approach to managing flood risk through the land-use planning system? In particular, are there any other possible mechanisms for managing flood risk through the land-use planning system?

 Whilst PPG 25 has been very successful in increasing awareness and improving planning.

Housing density policies provide increased run off and make it difficult to find space for sustainable drainage systems. Links with PPG3 require further examination.

In defended areas development should be allowed, provided mitigation measures can be put in place.

7.2

Do you agree that the Government should consider making a Direction in the circumstances outlined?

The present system works well in Lincolnshire and there doesn’t appear to be a need for direction.

If Direction is introduced then it should apply both ways; ie to both refuse and approve applications, based on a review of the evidence available.

7.3

Do you have views on the arrangements described for flood risk assessments, and on whether any changes are needed? The options that might be considered could include

a)

Retain the current arrangements. The Environment Agency would continue to provide information to planning authorities as well as advice on flood risk. There would, however, be no obligation on planning authorities to include flood risk assessments as part of Regional Spatial Strategies and Local Development Frameworks, and therefore be no guarantee that flood risk would be adequately covered in strategies and frameworks, or that the Agency would have sufficient information available to give advice. Similarly at the level of individual development proposals there would be no guarantee that flood risk assessments would be produced.

Encouragement should be given to all Local Authorities to include flood risk in local plans and Regional Strategies.

b)

Make it a statutory requirement that Regional Spatial Strategies and Local Development Frameworks include flood risk assessments where they cover areas of flood risk, as defined by PPG 25. This would require primary legislation and would impose extra costs on local authorities. However, it would ensure that flood risk was adequately covered in strategies and frameworks, and that adequate information was available to the Environment Agency.

Providing the Environment Agency is prepared to verify the flood risk assessments.

Section 7: Measures to reduce flood risk through land-use planning – Cont’d

7.3

Do you have views on the arrangements described for flood risk assessments, and on whether any changes are needed? The options that might be considered could include - Cont’d

c)

Make it a statutory requirement that individual planning proposals include flood risk assessments. This would also require primary legislation and would impose extra costs on developers and local authorities. The benefits would be in ensuring that flood risk was always taken into account, and in providing adequate information to the Environment Agency.

This should not be necessary for insignificant developments otherwise the system becomes discredited.

d)

A combination of (b) and (c).

See above.

Section 8: Integration of drainage management in urban areas

8.1

a)

What kinds of actions do you think would be most effective in delivering more integrated management of drainage in urban areas?

The problems would not be over come by structural change but by mapping all the infrastructure and identifying which body or person(s) is in fact responsible for each component part.

An arbitration procedure could be set up to deal with disputes.

b)

Do you think action should be focused on voluntary incentives or on compulsory requirements, or a mixture of both?

There should be a compulsory requirement to map all infrastructure and all public bodies should then have a duty to maintain infrastructure their in a satisfactory state.

c)

Which end of the spectrum do you think action should be focused on– less intervention or more intervention?

Once responsibility is clarified (mapping of assets) a more integrated approach would follow.

d)

Do you have any suggestions for additional actions, which might be included?

Financial penalties should be imposed for bodies failing to maintain their assets.

8.2

Comments are invited on the options for assigning lead responsibility as described in this Section.

The Environment Agency has an interest in all flood risk and drainage matters and should be the lead authority. The Environment Agency is only responsible for designated main rivers thus there would be no conflict of interest.

8.3

If this consultation exercise shows support for the approach described in Option B in this Section, do you agree with the proposals that there should be piloting of Option B actions and that Defra should examine ways whereby it would fund the preparation of those pilots?

See above. 

Section 8: Integration of drainage management in urban areas – Cont’d

8.4

This Section and associated background paper, referenced in the text, sets out a number of issues and proposals concerning the implementation and management of sustainable drainage systems (SUDS), based on discussion with stakeholders. We would value your views on all of the issues raised, in particular regarding:

•  the different options suggested to clarify ownership and responsibility of SUDS

·         the legislative changes suggested to remove obstacles and disincentives to design and to implement more sustainable surface water drainage systems

The problem of maintaining SUDS in the future will arise if the Government fails to give a clear direction as to who is responsible.

Section 10: Flooding from groundwater

10.1

Defra has recently published an initial scoping study on flooding from groundwater which has yet to be peer-reviewed. All views and comments on the study and suggestions for further development are welcome.

All flood risks should be treated equally.

10.2

Do you agree with the proposed priorities for further research on groundwater flooding? Are there any additional research priorities?

Yes but climate change information will need constantly updating.

10.3

Do you agree that there should be better co-ordination and management of groundwater flooding risks in combination with other types of flooding? Who should be responsible for this? How should this work at the national, regional and local level? How should co-ordination and mitigation be funded?

The Environment Agency should be the lead authority.

10.4

Do you support more accurate, consistent record keeping across England to monitor the frequency and occurrence of groundwater flooding events? Who should be responsible for this?

The Environment Agency as lead authority should maintain a database to help monitor the situation.

10.5

How could groundwater-flooding risk be assessed in the context of the flood and coastal erosion risk management scheme appraisal system? Consultation questions 14

See above

10.6

Should a national database be compiled to monitor rising groundwater in urban areas? Who should have responsibility for maintaining this?