Local Government Group’s response to National Flood and
Coastal Erosion Risk Management Strategy for England
consultation
The LG Group is made up of six organisations that work together to support,
promote and improve local government. These organisations are the LG
Association, LG Improvement and Development, LG Employers, LG
Regulation, LG Leadership and Local Partnerships. The response to this and the
related consultations has been informed by discussion by the LGA Inland Flood Risk
Management Group and agreed by the LGA Environment and Housing Programme
Board on behalf of the LG Group.
Introduction
The LG Group welcomes the opportunity to respond to this important consultation
and the related consultations on Future Funding; Co-operation and Sustainable
Development Guidance. As the key policy framework for managing future flood and
coastal erosion risk, it is essential that local government provides a comprehensive
response to this consultation and the related consultations. The LG Group has
actively encouraged authorities to respond and to send views to inform our own
response. We recognise the volume of work that has been undertaken in drafting the
consultations and the efforts made by DEFRA and the Environment Agency to
involve local government closely in developing the proposals. The LG Group has
been pleased to work with DEFRA and EA during this process and ensure they have
access to a wide range of knowledge and views from our member authorities.
General LG Group comments
The Introduction to the draft Strategy needs a more explicit statement of the
objectives of a National Strategy i.e. to protect communities, protect national
infrastructure and address risk, especially to life.
In general, the Strategy needs to consider the public perception and provide a clearer
picture of how national policy is developed and delivered and how the Environment
Agency and local authorities work together to address risk. Diagrams and illustrations
of the various flood and erosion risks, the extent of these risks and the arrangements
for managing them would be helpful in communicating the importance of the National
Strategy.
We need to ensure that engagement and working together actually happen. This will
require national communication on risk, not just a reliance on local engagement.
The consultation makes clear reference to the accountability expected of Lead Local
Flood Authorities (LLFAs) in managing local investment and priorities, and yet the
parallel funding consultation makes no reference to this, but only to risk management
authorities, local authorities and operating authorities in their role as potential
scheme generators. This is an opportunity missed to clarify roles and avoids the
challenge of how the upper tier LLFA is to influence and seek compromise between
different district council priorities, particularly pertinent in two tier areas.
The Strategy fails to give any overarching support to LLFA’s in how to communicate
acceptably to communities any risks associated with surface water flooding, which
will be much less apparent to property owners than the threat from any adjacent
watercourse. Whilst it is fully recognised that LLFA’s will need to develop local
communication strategies tailored to their communities, some support from DEFRA /
EA in terms of the public needing to be made aware nationally of surface water risk,
and some support for LLFA’s in dealing consistently with the resulting public
concerns about blighting their property values would be welcomed.
We want the Strategy to provide a flexible framework that enables and encourages
innovative and proportionate approaches at the local level
We recommend a greater emphasis on the impacts of flooding on people, the
devastation and disruption caused and the costs to the country as well as to those
affected and to local areas.
There needs to be consistency in describing communities across current government
publications. The National Strategy and related consultations tend to use the term
‘communities, but the Localism Bill tends to use ‘neighbourhoods’. To avoid
confusion, there needs to be an explanation of what the terms are defining, or a more
consistent use of one or other term.
The Strategy should include reference to the important role of Network Rail, which
owns around 50% of culverts.
The Strategy would benefit from a clear definition and differentiation between ‘flood
risk management authorities’ and ‘lead local flood authorities’. It would also benefit
from being clearer about the role of water companies.
A timetable for updates or reviews to the National Strategy should be included, along
with an explanation of how this will link to the wider policy and legislative timetable,
for instance the six year cycle for the Flood Risk Regulations.
The paragraph on Community Focus and Partnership Working contains tensions and
assumptions – for example, that local decision making will by definition by fair and
also increase consistency across boundaries.
Consultation Questions and LG Group response
Q.1 Is there any additional information on risk that should be considered?
We would like the strategy to acknowledge in more detail the possible cumulative
effect of several different risk factors and scenarios where a combination of events
could result in much greater disruption and damage than envisaged by single events.
For example, an obstruction or lack of capacity in a main river or ordinary
watercourse could impact on drainage systems that discharge in to it. This could
cause additional flooding or the surcharge could add to the downstream flood
through conveyance.
Strategic Flood Risk Assessments (SFRAs) are in many areas still relevant and
should be included in the table.
Residual risk needs to be acknowledged as the level of risk for properties will vary
depending on protection/defences in place.
Under Figure 1 ‘delivery’ unitary authorities should be included alongside districts
and IDBs as having responsibilities for ordinary watercourses.
Q.2 Are there any additional aspects of risk that need to be assessed?
Important additional aspects include the impact on people, particularly the long term
health and social impacts and how they affect different sectors (e.g. children, older
people).
The risk to the food security of the country needs to be given greater consideration,
particularly given that food supplies and costs, and the ability to produce a major
proportion of our food in this country are likely to become much more important
factors with the future impacts of climate change and population growth.
We recommend a greater emphasis on the risk of flooding to key transport routes
and the potential impacts on the wider area, the national economy and levels of
confidence in UK plc of losing any of our key roads or rail lines.
The risks of flooding from ordinary watercourses should be included. In areas with a
large ordinary watercourse network, this can be a significant risk, particularly if some
sections are in poor structural or hydraulic condition, or in riparian ownership where
maintenance can be problematic or inconsistent. A mechanism requiring the owner to
undertake essential maintenance or funding for the LLFA to carry out this work would
be helpful in reducing flood risk.
Q.3 The strategy takes into account different sources of risk (for example
coastal erosion and flooding from rivers and surface water). How can they best
be quantified in a way that helps the assessment of the relative importance of
these risks?
The strategy would benefit from a greater emphasis on the frequency of surface
water flooding, the higher likelihood and cumulative impact of frequent, surface water
floods compared to the lower likelihood of river or coastal flooding. We need to
acknowledge the impact of localised flooding incidents that have a knock-on impact
on the national economy – for example flooding of key transport routes, damage to
high grade agricultural land, to national heritage etc.
Likelihood of flooding is also a key factor – low level surface water flood events may
occur much more frequently than more significant but much less likely large scale
river or coastal flooding.
We recommend the Strategy places more emphasis on the impact of coastal erosion
as a permanent loss both locally and nationally.
Q.4 Do you agree with the proposed overall aims of the strategy? If not, please
explain why.
LG Group is broadly supportive of the overall aims of the strategy and considers that
it accurately reflects the aims and recommendations of the Pitt Report. We
recommend that it does more to reflect the broader perspective of coastal erosion
and flood risk.
Q.5 Are there any additional goals that should be included? If so, what are
they?
We would like to see the strategy aiming to achieve much greater awareness of risk
at a personal and neighbourhood level and encouraging more responsibility for flood
protection and resilience. However, messages must be put across in a clear and
easy to understand format.
The national strategy should more clearly encourage local strategies to be ambitious
and innovative in addressing flood risk and acknowledge that future revisions of the
national strategy will reflect good practice and ambition developed in local areas.
Q.6 Are there any other guiding principles for FCERM you would include? If so,
what are they?
The introductory section should set out the need to protect critical infrastructure and
other assets of national importance, including agricultural and heritage land. This is
covered in later sections but it needs to be included from the outset.
Investment in risk management can provide opportunities for economic growth and
development and this should be included in the guiding principles.
Q.7a Are the measures and actions set out in Sections 3.3.1 to 3.3.5 clear? If
not, how can they be improved?
The Strategy would benefit from clarity on how EA’s information on current and future
risks can be accessed.
We will need to involve planning and building control services when promoting
resilience.
EA and local authorities are already working well to prevent inappropriate building in
areas of high flood risk – the LGA National Partners Group produced a report in 2009
confirming that 99% of residential planning decisions were already in line with EA
advice. However, the Strategy should recognise that there are likely to be
considerable pressures to bring development or regeneration into an area.
Public information and understanding is crucial to supporting swift reporting and
resolution of flood incidents. The Strategy needs to maintain a focus on how easy it is
for the public to understand roles and responsibilities around flood and coastal
erosion risk management and how they can be engaged to help develop and support
local and national plans and action.
We recommend a clearer diagram and with arrows going both ways between the
National and Local Strategies.
Understanding Risks: does not really demonstrate how developing and
understanding information will be undertaken. It is not clear what the outcomes of
this list would be or what kind of information authorities and others could hope to
receive.
The paragraph on Planning Risk Management should acknowledge the resources
and commitment required on both sides when involving the community in flood risk
planning, as well as the risk that this will may not be an easy process.
Sections would benefit from shorter, more direct titles. For example, 3.3.3 would be
clearer if it was titled: ‘Helping people to understand risk and take action’. This
section would benefit from a reference to what might happen if local involvement is
not forthcoming.
Q.7b Do the measures and actions give enough specific information on what
will be done and by whom? If not, please can you explain where we need to be
more specific?
The document needs to emphasise the need for collaboration in achieving many of
the desired outcomes. Although a definitive list is helpful where organisations have
very clear responsibilities, in practice good relationships and partnerships will be
crucial in achieving many of the aims of both the local and national strategy and in
ensuring that projects deliver multiple benefits.
Examples of the type of information to be produced would be useful.
It is not completely clear what the relative roles of the EA and local authorities are in
relation to raising public awareness of risk, or how this will be funded.
It would be helpful to clarify how to manage flood risk that spans two or more LLFA
boundaries.
The issue of SuDS and funding for long term maintenance needs to be clarified as
this is the cause of much uncertainty at present.
Q.8 Please tell us about any other measures and actions you would include.
We would prefer the section on insurance to include a more specific commitment by
government to ensure the wide availability and affordability of insurance and for
Related to this is the need for advice on the likely implications of producing flood risk
maps, as this can have an impact on property values, and the cost availability of
insurance.
We would like Chapter 3 to have a wider focus, as at present the emphasis is more
on the number of homes protected than on the wider impacts of flooding on people,
education, travel, employment etc.
Lessons learned from recent flood events could inform a paragraph on e.g. essential
elements for effective response.
Decisions made on protecting coastal areas and how they are communicated have
the potential to cause alarm and even blight and the Strategy should acknowledge
this.
Q.9 Are you aware of any barriers to the implementation of the measures
discussed in Sections 3.3.1 to 3.3.5? If so, how can Defra and the Environment
Agency help overcome them?
Whilst LG Group is very much in favour of supporting pooled resource and
encouraging these kinds of arrangements – we are leading some work with national
partners on Alternative Sources of Income for Flood Risk Management – these might
in practice not be as straightforward or easy to achieve as desired and the strategy
needs to acknowledge this and be updated as evidence emerges. Different
organisations have different financial timescales and processes to follow. There are
also potential difficulties if a number of property owners have riparian responsibility,
or it is not possible to identify a riparian owner. A clearer commitment by Government
to address barriers to joint funding needs to be included in the Strategy.
Whilst we hope that multiple benefits can be achieved, there is also the potential for
measures to lead to a conflict of interest. For example, some actions to protect land
could have a negative impact on biodiversity, so the Strategy will need to include
some advice on how conflicting interests might be resolved.
The Capacity Building programme is delivering a much needed series of workshops
and e-learning to support LLFAs and build knowledge. This kind of support will need
to be continued over the next few years to help LLFAs during the implementation of
the legislation.
We need to achieve some national agreements between local government and the
water industry to provide clarity locally over how local flood incidents will be
investigated and addressed following the transfer of private sewers later in 2011.
This will ensure incidents are handled swiftly and efficiently.
Consistency in data collection is crucial to good partnership working and advice from
Defra/EA will be very helpful.
A lack of local ownership or involvement could be a barrier, as well as different local
interpretations of guidance and information.
Reduced resources generally could make it much harder to involve local responders
or coordinate partnerships and drive activity.
We want to raise awareness of flood risk and encourage protection and resilience
measures at the same time that we avoid causing excessive alarm or blight.
Difficulties in achieving this balance could create a barrier to implementation.
Q.10a How should the relative risks to people, property and business
(including agriculture and food production) be taken into account?
We need a greater emphasis on the (immediate and long term) impacts of flooding
and living with flood risk on people, rather than the current emphasis on protecting
properties.
The role of Local Strategies in defining how relative risks will be considered is key to
this – they will clarify what criteria have been used to prioritise identified flood risk. As
well as people and properties at risk, these should also assess the economic value of
infrastructure, agricultural and amenity land, key transport routes and the local
economy, together with the long-term cost of losing or restoring such assets.
The long term impact of losing agricultural land needs to be factored into any
calculation of risk, as the subsequent cost of importing food and an increased
dependency on global food markets could then be seen as a much more costly risk
to the nation, as opposed to a risk merely to the local area and economy, or as a risk
based only on the value of the land itself.
Decisions will be aided by consistency in collecting and sharing information.
Q.10b How should the risks to people, property and business, and improving
and protecting the environment and habitats be balanced?
At a national level, the risks to people, property and businesses should be balanced
with the need to improve and protect the environment and habitats by applying
established sustainable development principles. Please see our separate response
to the Sustainable Development consultation.
It is important that decision makers consider the needs of future generations and
their dependence on and need for healthy natural environments when making any
decisions about protecting present homes and businesses. Their decisions should
never compromise future generations. The detail of how relative risks and protection
will be balanced will largely depend on the Local Strategy and local priorities.
Please also see responses to 10 a) above.
Q.11a How far is it possible to distinguish between FCERM benefits and other
benefits (for example, to agriculture, land drainage, health, recreation, and the
environment)?
One aim of effective flood and coastal erosion risk management is that projects and
routine maintenance should aim to achieve multiple benefits. It will be useful in terms
of attracting additional sources of funding for the various benefits of schemes and
management practices to be accurately assessed and recorded.
Q.11b What is the best way to quantify these additional benefits and how
should they be considered in FCERM decisions on priorities and funding?
Health, social and recreation benefits may be more difficult to quantify, although
there has been some in-depth research on the long term health and social impacts of
the 2007 flooding in Hull on different age groups. Established Strategic
Environmental Assessments will be helpful in quantifying benefits.
Q.12 How may the current arrangements for emergency response be
improved?
There needs to be an effective mechanism by which all the relevant emergency
response organisations communicate at an early stage and throughout any incidents.
Relationships developed through Local Resilience Forum Flood groups help to raise
and maintain awareness of flood risk and share knowledge and experiences before a
flooding event, which then prove to be valuable in the event of a future flood
emergency.
Multi-Agency Flood Plans (MAFPs) should help develop good working relationships
between partners. In some areas there are on-going working groups with those
partners involved in developing MAFPs – e.g. representatives from the County
Council/EA/ unitary and district councils/Met Office/Police/Fire/Ambulance etc.
Continued close working relationships across agencies can help ensure there is a
robust notification scheme in place, to bring together all relevant parties at the
earliest stages to monitor events and nominate officers to keep in regular contact
with each other throughout a flooding/potential flooding incident.
Emergency response should benefit from the stronger partnership arrangements,
sharing of information and more strategic consideration of risk management that the
National and Local strategies will aim to deliver. Information sharing should include a
clear assessment of the impact of a critical infrastructure site flooding on the
provision of e.g. water, electricity, etc. This will enable the risk to be properly
assessed and where necessary multi-agency plans to be written and coordinated
across LRF areas.
Current arrangements and work in hand e.g. Collaborative working; LRF; Reservoir
Plans; Climate Change Recommendations; Recovery Plan and MAFPs are
adequate. However, in most parts of the country the utility companies are less visible
and accessible than they might be. Category 2 responders are not compelled to
engage as fully as Category 1 responders. This was identified as an issue in the Pitt
Review, particularly where flooding affected critical national infrastructure, water
supplies etc. After the 2007 floods the LGA recommended that arrangements were
changed to ensure utility companies and others were required to play a much fuller
role in preparing for and responding to flood emergencies. We understand some
areas have new Category 2 LRF Groups which may help to address this issue in
those areas. A stronger compulsion on Category 2 responders, particularly water
companies, to share information, would be helpful.
The section on emergency response would benefit from a short explanation of the
role of LRFs.
Lessons learnt from 2007 and other recent flood events will be helpful in continually
improving emergency response. The National and Local Strategies should be
reviewed in the light of lessons from future significant flood events.
The LG Group can help to facilitate future forums and discussions between the
Environment Agency and Emergency Planning advisers to support continued
improvements in emergency response arrangements.
Q.13 Are the responsibilities of the key organisations managing flood and
coastal erosion risks clear? If not, please explain why.
The key duties are clear, although communicating these to the public must not be
overlooked. It will be essential to clarify the division of responsibilities in two tier
areas over land drainage powers. To date, there has been some confusion. With the
reduction in the local government settlement, many authorities will be forced to curtail
many activities that are permissive rather than statutory and this could then
undermine the objectives of the local strategy (and cumulatively the national strategy)
and the ability of other risk management authorities to deliver their responsibilities.
The timetable for commencement of all provisions in the Act needs to be
communicated as soon as possible, so that the various risk management authorities
are able to plan for recruitment, training and the development of the organisational
framework required to manage their responsibilities efficiently.
Different organisations may also prioritise flood risk differently. This could hamper
developing a deep understanding of the risk or identifying/implementing alleviation
measures.
The high level aims around co-ordination of different plans and policies may not
translate easily into the operational practicalities of the various risk management
authorities and partnerships. This is something that the local strategies will need to
address by establishing clear links across different plans and strategies and making
sure that there is consistency between local, catchment and national levels. Effective
partnership working will be key to achieving this.
The Strategy needs to clarify the term ‘coastal erosion risk management authorities’.
The role of and permissive powers of district councils are acknowledged, but the very
difficult financial situation and the reduced resources which districts will have to
manage over this spending period mean that in reality many districts could find it
difficult to continue to provide the same level of support as previously.
We need to make sure that Local Planning Authorities (LPAs) are clear about their
responsibilities. Whilst LPAs are taking into account river and coastal flooding, they
will also need to take proper account of surface water flood risk and properly use the
surface water flood maps. In addition LPAs will need to tackle the issue of Flood Risk
(particularly from surface water) in emerging Local Development Frameworks
(LDFs). Further advice on the implications of the Flood and Water Management Act
may be needed. The National Strategy could help provide the statutory basis on
which LPAs could strengthen their LDFs.
Q.14 Please tell us if any organisations or groups should be added and what
their role might be.
Section 4.2 should include Internal Drainage Boards which in many areas (around
10% of the country) play an essential role in drainage and water level management.
Marine Management Organisations should be included in relation to their role in
development that might affect coastal erosion and flooding.
We would like a greater emphasis on the role of Water and Sewerage Companies,
which must have regard to the national and local strategy. Under the Act the
Companies are designated risk management authorities and are required act with
regard to national and local flood risk management strategies. The role of OfWat in
supporting policies and actions that help reduce flood risk must also be included – for
example, by making it easier for W&SCs to take on assets, help to retro-fit SUDs and
support agreements between W&SCs and LLFAs on responding to sewer flooding.
The role of the insurance industry in potentially driving behaviour that reduces flood
risk and damage should be acknowledged.
Private companies may have different drivers to public bodies.
The final strategy should also be clearer about the role of RFCCs in relation to
LLFAs.
Q.15 Do the organisations identified in Chapter 4 have the skills and
capabilities available to carry out the roles identified above and achieve the
required outcomes? If not, how should these be secured?
The LG Group has conducted various surveys of member authorities since 2008
where they have consistently voiced their concerns about capacity and skills required
to deliver their new responsibilities. There are acknowledged shortages in some
fields, particularly planning and engineering and there are new roles around coordination of partnerships and flood management activities, where new skills are
required. LG Group is represented on Defra’s Capacity Building Programme Board
and we support the programme of workshops and e-learning that the Environment
Agency is delivering as part of its contract with Defra. There are some important
elements such as training for elected members which have not been developed but
which will be essential in building awareness and political support, particularly in
those areas without recent experience of flooding. This is increasingly urgent if flood
management teams are able to secure the resources and on-going political
commitment they need to build their capacity and expertise.
The foundation degree programme which now has 45 placements in local authorities
must be continued over the long terms to ensure that more authorities have the
chance to build their local knowledge and establish some additional capacity
affordably. LLFA’s should be encouraged to develop skills in-house, as local
knowledge is often key to understanding and managing flood risk.
Joint working across different service areas, between local authorities or with the
water industry could provide a way to overcome some skills shortages and resource
issues. However, putting in place joint working arrangements will itself require some
very specific skills and on-going support. Good practice case studies and models of
joint working showing the possible benefits will be helpful in terms of winning support
from senior management and politicians to establish such arrangements, but in many
areas this will need to be supported by access to external expertise, secondments
etc.
The key challenge for all authorities over the current spending period will be in
securing sufficient funding to fully resource both existing and new roles. While there
are some opportunities for efficiency savings from improved co-operation and coordination, there will be set up costs in achieving this and barriers to overcome, such
as rules and timetables around the transfer of staff and funding between
organisations. It could take a number of years for many authorities to build their
resources to a level where they can fulfil all aspects of the legislation. Therefore, it is
very important that the expectations of Government and local people are managed
accordingly and authorities are encouraged and supported and not unfairly criticised
if they are unable to implement all parts of the legislation immediately. There will be
start up costs in establishing partnership arrangements that can help address
capacity issues and we do not see any allowance for such costs in the impact
assessment for the legislation.
Managing expectations is very important. On the back of the Pitt Report there is
already an expectation that LLFAs will be making a significant contribution to
reducing flood risk, but this is only achievable if the appropriate level of funding is in
place.
Q.16 Do you agree with the overall objectives for the proposed changes to the
funding system as set out above? If not, please can you explain your answer.
LG Group agrees that the objectives of the funding proposals are broadly in line with
the Pitt recommendations and could provide more areas with the opportunity to
access some national funding. This in turn should encourage a greater acceptance of
the beneficiary pays principle and enable very worthwhile projects to go ahead,
where under the current system they might never reach the cost benefit criteria to
attract any national funding. In addition, the funding proposals could encourage more
creative solutions to flood management problems and encourage the relationships
and partnerships to drive much greater ownership of flood management at the local
or catchment level.
However, whilst beneficiary pays principles appear a much fairer way of sharing
government funding, we do have some important reservations. It will be important
that any new system recognises and rewards the national benefits that some local
schemes might deliver – for instance work to improve a watercourse or more
effectively manage drainage or water levels in one location could significantly reduce
flood risk for a key transport route, valuable land, cultural or heritage site further
downstream.
It is also crucial that all the beneficiaries of schemes are identified. Models and case
studies will help all areas to develop effective assessment mechanisms to identify the
various costs and benefits to a range of people, organisations and businesses. The
funding scheme should be flexible enough to ensure that contributions can be fairly
assessed and recouped. In many cases, it could be argued that the ‘beneficiaries’ of
a proposed scheme – i.e. those that currently suffer from a flood risk or problem –
should not be the ones that contribute to the cost of the solution if in fact their flood
problem is caused by activities in another location or by a separate group of people
or organisation. At the same time, any local schemes that do go ahead as a result of
contributions from local people or businesses will need to be properly assessed in
terms of their possible consequence to overall flood risk in other parts of the
catchment.
We would be very concerned if a policy of increased local funding evolved into a
policy of decreased central funding of flood risk management.
The key problem that we see at the moment in terms of attracting more local funding
to enable schemes to go ahead, is the availability of extra funding in organisations
and in some more deprived areas
There must be the option for the local levy contribution to be subject to a much
greater degree of local accountability through the LLFA directly. The new roles and
responsibilities on the LLFA, together with the increased profile of locally-raised
funding in a context of greater local accountability, raises important questions about
the use of local levy on the current regional basis, as opposed to retaining it within
the local area. There is a strong argument for a proportion (or the entirety) of an
LLFAs local levy to be retained in this way, backed by local member scrutiny of the
schemes or services funded from this source.
The Local Levy should be extended to be able to be spent on Surface Water flood
risk management schemes (as this is the major local support of Grant In Aid funding)
– currently it can only be spent on river and coastal works.
Q.17 Please tell us about any other options for prioritising and justifying
maintenance and managing situations where ongoing maintenance cannot be
justified from national budgets.
Decisions should be based on risk. In terms of national funding for EA maintained
systems, there may be cases where there are clear benefits locally, but the wider
benefits are minimal and make it difficult to justify continued funding. In these cases,
it would be helpful for EA to consider agreements or innovative funding arrangements
with the relevant LLFA(s) and partners which could enable projects to be continued
or enhanced in ways that provide additional or even national benefit. There are some
regulations or bureaucratic barriers that prevent some maintenance activities being
taken on by landowners and these should be reviewed. The potential of increased
risk through lack of maintenance needs to be understood.
S106 agreements, Business rate retention, BIDs, Community Infrastructure Levy etc.
could all potentially be used to provide additional funding. However, these kinds of
additional funding options will not be feasible in all places, for example where land
values or populations are low or where any additional development is not viable.
Q.18 How often should local strategies be reviewed and who should be
involved in the review?
It may be necessary to make frequent updates to the Local Strategy, particularly in
the first years as understanding of local flood risk improves and also in response to
local flood events and the success or otherwise of local partnerships and projected
funding arrangements. It seems sensible that more comprehensive reviews of the
Local Strategy are informed by and linked to the six year cycle of the Flood Risk
Regulations. Significant flood events (including those in other areas), new insights or
information on climate risks, major changes to funding, local development or the local
economy could all necessitate a review of the Local Strategy to ensure it remains fit
for purpose. Availability of skills and changes in the projected national or local
funding sources could all make it necessary to review significant sections of the
Strategy, if not the whole Strategy, on a more regular basis, so the timetable for
review should be flexible enough to respond to local or national events or changes in
circumstance. Any review of the Local Strategy should involve all the organisations,
public consultation etc which helped inform the original Strategy.
The scrutiny process will help LLFAs to assess whether simple updates are required
or if a more thorough review is necessary, so a roughly annual scrutiny process could
be very helpful in this respect.
Q.19 Should reports on the implementation of the national strategy assess
progress against specific milestones and activities? If so, what should these
specific milestones and activities relate to?
It will be helpful to have some milestones in place to be able to measure progress
and assist with benchmarking comparisons with other organisations. These should
on the whole be understandable by the general public and not require specialist
knowledge of flood risk management. A small number of high level milestones, such
as numbers of properties or people, national infrastructure and productive land being
taken out of flood risk, numbers of properties benefitting from flood protection or
resilience measures, clear links established across all the plans and strategies
relating to local/catchment areas. The milestones should relate to the high level
principles in the National Strategy, the overall aims of the Strategy, key legislative
requirements and the need to embed awareness of flood risk and actions to reduce
risk within all flood risk areas. Milestones could also include for example expansion of
SUDs schemes, an increase in planning decisions that meet agreed principles of not
building on in flood risk areas and of actively reducing local flood risk. Availability of
affordable insurance might be an indication of how well the National Strategy is
perceived to be managing flood risk.
Q.20 There are two levels of information: statutory guidance and advice. Are
there any areas where we are proposing to provide advice where you consider
it should be statutory (that is provided as guidance)? If so, please explain why.
There is currently some confusion regarding the exercise of land drainage powers by
LLFAs and Districts. There may be some merit in providing a stronger steer on
granting consents under the Land Drainage Act s. 2.3. Equally, where SUDS are
mentioned, it depends on which aspect of SUDS is being referred to. It would be
helpful to have certainty on the processes in the planning system, and these should
be consistent nationally.
We would also welcome your views on the following over-arching questions:
Q.21 What primary objectives in FCERM should the strategy achieve over the
next 12 years?
The Strategy should:
 provide a clear and consistent framework that is easily understood and
embeds awareness and effective mechanisms within the policies and
decision making of all the risk management authorities.

encourage awareness, responsibility and practical action by individuals,
neighbourhoods and businesses.

create an overarching vision that creates consistency between all relevant
plans and strategies.

result in effective partnership arrangements and working practices, supported
by innovative and efficient pooling of staff and funding resources.
The effect of the Strategy should be confidence amongst the public and businesses
that flood risk is being effectively managed at the national and local level and that this
in turn provides the certainty for affordable flood insurance to be made available in all
areas.
The strategy should achieve better management of flood and coastal erosion risks. It
is not possible to eliminate those risks entirely so we must be reconciled to living with
a degree of risk. Of course, a national strategy will not achieve better risk
management by itself. Risks have to be managed locally, where they occur and so
improved management will be better facilitated by good, well supported local
strategies which involve all partners.
The strategy should help to further embed the risk based approach but other
objectives like community focus / partnership working, sustainability and ‘multiple
benefits’ will need to be achieved locally and will be more dependent on sound local
strategies and partnerships. The concept of multiple benefits is good in principle but
will need to be considered locally especially in locations where resources are limited
and viability questionable.
The strategy is not very clearly set out and numbered and should be more specific
about exactly what are the ‘primary objectives’
Q.22 Is the risk-based approach to FCERM appropriate and does the approach
suggested take account of the main risk factors?
The approach is appropriate at the level of major flood protection schemes but less
so in relation to surface water flooding and maintenance of watercourses. There are
many day to day activities that LLFAs will need to manage which contribute to flood
risk management - enforcing and consenting, investigating flooding incidents,
establishing and maintaining asset registers, designating and monitoring assets etc.
which must be undertaken regardless of local levels of risk, and cannot easily be
assessed on a risk-based approach.
Authorities are getting better at identifying the different sources of flooding and the
different risks. However, it has to be recognised that flood (and coastal erosion) risks
are not the only risks that have to be taken into account when decisions are made.
We may have to offset and balance these against social and economic risks.
Q.23 Are there any barriers to local action that need to be removed or reduced?
The pooling of resources and funds, mentioned in the consultation document, will
require intervention from Defra and the EA to allow distinct funding streams to be
merged, or to channel funds into a separately established joint fund. There will need
to be greater flexibility for LLFAs to determine allocation of their local levy
contributions according to local circumstances in furtherance of the Local Flood Risk
Management Strategy. The RFCC could play a powerful role in promoting coordination between neighbouring LLFAs to ensure that local levy funding can be used
to best effect where catchments cross administrative boundaries and a joint
approach between LLFA areas is required.
We are getting better at identifying and tackling barriers. It is important that
everyone’s point of view is respected and that we support new and emerging
partnerships so that they work effectively and involve all relevant organisations. If
more costs are to be devolved locally, LLFAs will have to work hard to make this
work and persuade communities and businesses of the merits.
Local Government Group’s response to Future Funding for
Flood and Coastal Erosion Risk Management consultation
General LG Group Comments
The LG Group has always maintained that local investment should complement,
rather than replace national investment. There are important national strategic
arguments for increasing investment in flood risk, not least of which is the need to
support the availability of affordable insurance, which the industry is unlikely to offer if
they do not have confidence that sufficient funding is being provided in managing
flood risk across the country.
National funding for flood risk management had been rising steadily since the 2007
floods. However, the Spending Review announced an 18% cut in national funding,
from £673m in 2010/11 to around £525m in each of the next four years and more
recently, it has become clear that this has translated into an even bigger cut in capital
funding for planned flood defence schemes from £354m in 2010/11 to £259m in
2011/12. Together with the 27% overall reduction in the local government settlement
over the next four years, we can expect this to present real challenges for both the
Environment Agency and local authorities in maintaining existing defences, taking
forward new projects and achieving an intended reduction in national and local flood
risk from the sea, main rivers and surface water.
This is unfortunately the wider context within which any new system of funding flood
protection schemes will be developed. Any local or national benefits from the
proposed new system may be less apparent or less able to be realised because of
the wider funding restraints and cuts to major projects.
Our members accept the political reality that it is not possible for central government
funding to meet all the future investment needs and that additional sources of funding
must be found. It is however a very difficult time for local authorities, given the local
government settlement, to find additional local funding and to manage a more
complex system. The natural transition period will be helpful, but schemes are
planned years in advance and authorities will need to develop their understanding
and skills very soon if they are to be able to put forward viable proposals at the first
opportunity. Therefore, DEFRA will need to provide resources or forums to ensure
that the financial implications are fully understood within a very short timeframe.
Authorities support the aim to give local areas more determination over funding and
to create more transparency over which projects get funding.
Payment for Outcomes relies on the LLFA having the resources and ingenuity to
secure significant contributions from communities or other sources in order to make
schemes viable. This will clearly be extremely challenging at a time when LLFAs
need to reduce and reprioritise their service priorities, and potential contributors are
equally suffering from the national economic position.
Members are not convinced that project costs will always come down as a result of
the proposals. There may be some potential to reduce costs but we would want to
see evidence emerging before this expectation or assumption is used to inform an
assessment of future funding needs.
Some of the proposed additional funding streams rely on a solid business base so
this opportunity will depend on local circumstances. Some areas are less inherently
economically successful than others and we would be concerned if the net result of
the proposals was to exacerbate differences in economic viability.
Larger schemes will also not deliver within the next 4 year time period.
Members have suggested that Defra looks at the Greater Manchester carbon fund as
a model for bringing together different funding streams.
The LG Group recognise that there will be some limits on national funding for flood
and coastal erosion risk management and that the country needs to develop new
sources of investment to address the challenges of future climate change, population
and development growth highlighted in the Environment Agency’s 2009 Long Term
Investment Strategy report.
There are strong arguments for expecting a contribution from beneficiaries towards
the cost of flood protection schemes. Defra’s proposals go some way towards
ensuring that limited national funding goes further by part funding most projects and
requiring local areas to find the additional funds to ensure projects go ahead.
Enabling additional local investment in flood risk management could help to raise
awareness of flood risk, create more resilient local areas and offer communities a
bigger role in securing their neighbourhoods against future flooding.
We accept the potential of the local levy to fill small (maybe 5-10%) funding gaps to
allow high priority projects to go ahead.
It will be difficult to maintain the political priority on flood risk management when key
service areas are facing severe funding pressures. All councils are increasingly
aware of the number of people who live or work in flood risk areas, the social and
economic impact of flooding and the very high cost benefit of investment in flood risk
management. However, LG Group will need to work hard to maintain a focus on flood
risk and the benefits of action to reduce risk, particularly in those areas that have not
suffered a recent flood.
Funding for Lead Flood Authorities’ new responsibilities under the Flood and Water
Management Act is providing a minimum of £110k per lead flood authority, with
additional funding based on local flood risk. Member authorities tell us that their costs
in implementing the legislation will be several times higher than the funding available
and significant up-front costs for staffing and systems will outweigh the long term
savings that Defra have built into their funding calculations. Against this background,
the scope for local authorities or their communities to contribute more towards the
funding of flood protection schemes will be limited, particularly in some areas. Flood
risk management will be one of many service areas competing for additional
resources and local resources are finite.
Any new system should recognise and reward the national benefits that some local
schemes will deliver – for instance investment by one area could significantly reduce
flood risk for a key transport route, valuable land, cultural or heritage site further
downstream.
All the beneficiaries of schemes should be identified. Models and case studies will
help all areas to develop effective assessment mechanisms to identify the various
costs and benefits to a range of people, organisations and businesses. The funding
scheme should be flexible enough to ensure that contributions can be fairly assessed
and recouped. In many cases, it could be argued that the ‘beneficiaries’ of a
proposed scheme – i.e. those that currently suffer from a flood risk or problem –
should not be the ones that contribute to the cost of the solution if in fact their flood
problem is caused by activities in another location or by a separate group of people
or organisation or a lack of maintenance by a neighbouring risk management
authority. At the same time, any local schemes that do go ahead as a result of
contributions from local people or businesses will need to be properly assessed in
terms of their possible consequence to overall flood risk, or indeed economic
development in other parts of the catchment.
We would not want to see a situation where wealthier areas that can more easily
access local contributions are able to put in place a range of schemes which
cumulatively create an increased flood risk to another area, or have the effect of
attracting businesses or development away from other areas which are more
dependent on such businesses or development growth. The National Strategy and
future funding arrangements must have checks and balances in place to prevent
deprived areas becoming increasingly deprived or rural areas becoming depopulated
because they are unable to match the fund-raising activities of their neighbours.
The key problem that we see at the moment, in terms of attracting more local funding
to enable schemes to go ahead, is the availability of any extra funding within many
organisations and in some more deprived areas.
Future funding must clarify the difference between development and regeneration.
We support work to secure developer contributions to enable more ambitious
schemes or additional schemes to be undertaken.
We need to ensure that the proposals are supported by a comprehensive set of
models informed by distributional analysis of how changes to funding distribution will
affect different areas – rural / urban; comparative wealth / deprivation; density etc.
Lastly, the proposals need to emphasise that the future funding system is there to
support the strategic management of flood and coastal erosion risk management.
Otherwise, they could be interpreted as merely encouraging schemes on the basis of
a local area’s ability to raise contributions, regardless of their impact on or role in
delivering the National Strategy.
Consultation Questions and LG Group response
Q1. Do you think that the existing funding prioritisation and allocation system
should continue, in which Government focuses on funding the most costbeneficial projects?
There are some clear losers from the present system, including many rural areas and
schemes to address surface water flooding. However, the present system is relatively
straightforward and does not rely on a complex system of relationships, skills and
funding arrangements being developed in every local area.
Q2. Do you have any other comments or anything to add to the analysis in
Section 1?
This could mean that schemes are progressed around the country with insufficient
equity in terms of priority and this may be seen as a post code lottery.
For example, some schemes, particularly coastal defences, are relatively expensive,
at the same time that coastal communities are often relatively less able to access
additional sources of funding.
Q3. Do you agree with the objectives in Section 2? If not, which would you
change, or what others would you add?
LG Group is broadly in agreement with the objectives. We particularly welcome the
recognition of climate change impacts. It is important that the potential impacts of
future climate change on food production and food security are properly recognised
within the funding system. Agricultural land should be given an appropriate value that
reflects what will be an increasingly important role when climate impacts and
population growth are projected to make food costs and food security a much bigger
consideration.
We have some reservations over the ability of the proposed funding system to
achieve all the objectives.
Q4. Do you agree with the guiding principles outlined in Section 3? If not,
which would you change, or what others would you add?
LG Group agrees with the guiding principles. The opportunity for all proposed flood
protection schemes to be able to access some government funding is to be
welcomed and is an improvement on the current system which means that some
potentially valuable schemes never meet the cost benefit criteria and have no hope
of ever being implemented.
We recommend that the benefits are not just based on numbers of properties but
take into account a wide range of factors.
Excluding properties built or converted for housing from January 2009 from the
funding formula may ensure that new builds are appropriately defended or made
resilient. We would recommend that the starting date is aligned with the
commencement of the Flood and Water Management Act in April 2011 or with the
implementation of provisions for SUDS in 2012. Otherwise, it is creating a
retrospective application which would penalise residents who have moved into new
build properties while the previous system was in place.
However, with overall government funding cuts for the next four years of 18%
compared to 2010/11 and with recent announcements of even bigger cuts to EA’s
capital spending programme, we are not convinced that it will be possible in practice
to achieve more schemes.
Q5. In particular, do you agree that the costs of protecting new development
should not fall to the general taxpayer, now or over the long-term?
Yes, we agree that this is right, but this should only apply to completely new
development, rather than regeneration schemes, where it may be impossible in more
deprived areas to attract developers without some central funding for flood
protection.
Q6. Do you agree with the rationale for the ‘payment for outcomes’ approach?
The LG Group agrees with the rationale, but we have reservations about the details
of the approach. Please see our general comments above.
We support the principle of seeking contributions from the private sector, which
clearly benefits from investment.
Q7. Do you agree that a payment for outcomes system would be more likely to
deliver the objectives stated in Section 2, in comparison with the current
prioritisation and allocation approach? An accompanying impact assessment
provides a more detailed comparison.
It could be argued that in some areas, for some communities, the payment for
outcomes system presents them with less choice, as they may be forced to accept a
less ambitious scheme and/or they may be forced to raise local funding in order for
the scheme to go ahead, where currently they could expect to have a fully funded,
comprehensive scheme.
We would suggest that the impact assessment and scenarios also include coastal
erosion.
Q8. Do you have any comments or suggestions on the role of RFCCs and the
local levy?
It is not yet clear how RFCCs will prioritise their spending. The Local Levy should be
extended to be able to be spent on Surface Water flood risk management schemes
(as this is the major local support of Grant In Aid funding) – currently it can only be
spent on river and coastal works.
Local authorities and IDBs will need to be fully engaged in the RFCC as it will be
making crucial decisions affecting the viability and progress of their projects.
It will be important for water companies to be fully involved in the RFCC.
Q9. Do you have any comments on the analysis in Section 6, or your own
views of the potential benefits and risks of the payment for outcomes
approach?
We need much clearer evidence that the local funding streams required by the
proposals will be achievable. If local funding is a large component, and is then
not forthcoming (a likely scenario in the current climate), the effect will be that the
Defra funding will not actually be drawn down in all but a few cases, even if it has
nominally been pledged. This could then dramatically reduce spend on flood
defence. We might then see local authorities and communities taking the blame for a
lack of progress in schemes, rather than the system that government has created.
In the current financial climate, beneficiaries may not be able or willing to pay. Other
options for accessing local funding, such as contributions from developers,
businesses etc. based on future rises in land value and economic development, are
dependent on economic confidence and expansion of development, which may not in
practice materialise.
We are concerned that the analysis makes assumptions that greater pressure on
funding could drive down the cost of schemes and increase efficiencies. We will need
to look at the evidence over a number of years before we can be certain that this will
in fact happen.
How will 'community' be defined for the purpose of raising the funds (will it be the
local authority area, or a subset of this, a town, parish or some other 'community'
area)? If too large a 'community' is selected, then most residents will see no benefit
and may not support something that they are being asked to fund, whereas if it is set
too 'locally' then the cost to each resident could be unaffordable. There could be
significant benefits to commuters, tourists, businesses, insurance companies and
central government but these benefits will be impossible to factor in. The proposal fits
in with the localism agenda, but the LG Group is not convinced that it is completely
practical or appropriate to do so in the case of flood and erosion risk policy.
Q10. Do you have any suggestions for improving the way a payment for
outcomes system might work?
Preliminary Flood Risk Assessments should be helpful in providing evidence on local
flood risk.
We would recommend extending the use of the Indices of Multiple Deprivation to
Outcome Measure 1.
Q11. Do you agree with these outcome measures for future periods? If not,
which would you change, or what others would you add?
We welcome the recognition within the Outcome Measures of the differences
between flood and erosion risks. However, the valuation of OM3 implies erosion risk
is similar to flood risk, when it is impossible to apply an average annual damage to
erosion. We need OM3 to adequately reflect the permanent loss associated with
erosion risk as opposed to the short or long term damage associated with flood risk.
OM 6 needs to allow for funds to be spent on the enhancement or restoration of
existing intertidal habitat. This is potentially as valuable in terms of habitat and
potentially a much cheaper option than creating new habitat.
In relation to new development, please see comments under Q4 and Q5.
Q12 Do you have any comments on the indicative payment values for each
outcome, or the underlying assumptions used in their calculation?
The proposed level of grant payable in respect of OM1 seems to suggest that
Government is seeking benefits 18 times what it is prepared to invest. Many of the
infrastructure assets that are protected may be in private ownership, but nevertheless
they are national assets. This applies to the major utilities and to railways and
historic assets. While some might be regarded as purely commercial, they should
more properly be considered as being in the ownership of the wider community and
having a benefit to that wider community. This important point is not reflected in the
proposed new system.
We would suggest that OM1 is split so that assets that are clearly of benefit to the
wider community qualify for a higher rate of benefit than the currently proposed £1
per £18 of benefit.
If the valuation of OM3 remains based upon rental, it is important that the values
reflect actual market rents and that these are adjusted regularly in line with inflation.
We support the principle of higher payments for properties in the highest risk zones
and the most deprived areas
Q13 Do you have any views on the National Priority Programme and the
threshold above which projects would be selected for it?
The concept of a National Priority Programme appears sensible. The methodology
described appears appropriate and it gives some certainty to those schemes that
provide the greatest benefit. It does not, however, make provision for taking forward
schemes thought to be urgent.
We would suggest that all schemes achieving120%, not just EA schemes, are
included in the National Priority Programme. We would not want schemes led by
local authorities or IDBs to have to reach a higher threshold than EA schemes.
Q14 Do you have any suggestions or preferences for determining what each
RFCC’s share should be, once funding has been allocated to the National
Priority Programme.
Historic spend and need will be helpful in determining each RFCC’s share of funding
but this would be less easy to assess in terms of surface water risk management,
However, information from Preliminary Flood Risk Assessments should be helpful in
determining need and expected spend.
In general funds should be distributed according to where the greatest benefits will
be realised.
If funding is based on anticipated delivery against OMs, there may be a built in
prejudice against coastal protection schemes, which can only score against OM 1
and OM 3 (whilst flood defence schemes can score against OM 1, 2, 4, 5, 6 and 7.
Q15 Do you have any other comments or suggestions on how prioritisation
and funding allocation should work?
No comments
Q16 Do you have any other comments or suggestions on these funding and
delivery arrangements?
The proposals have the potential to make funding of schemes quite complicated, as
funding could come from the local level, Grant in Aid and additional contributions, in
turn making decisions more complicated. The communities who are set to benefit
from such schemes will need to be able to understand the decision making process
and why some schemes are able to go ahead and others are not. LG Group
recommends that this issue is addressed, to ensure on-going engagement and
confidence by local communities in the funding system.
Q17 Do you agree that it would be inappropriate under the new system to
allow payments to made under OM2 and OM3 in relation to households not
actually at risk of physical damage?
Yes, assuming that properties that became uninhabitable through loss of utilities
continue to be included in the benefit calculation when an alternative cannot be
provided.
It must be clear that other impacts on householders will be considered under OM1.
Q18 Do you have any comments or suggestions on the key project metrics
or the way in which they would be calculated?
No comments
Local Government Group’s response to draft statutory
guidance for Co-operation between Authorities and
requesting Information
Consultation Questions and LG Group response
Q1. Does this guidance sufficiently explain what we mean by co-operation? If
not, what elements are unclear?
The guidance sets out some clear principles but it does not go into the detail of
practical working arrangements, shared funding etc. This will be essential to reducing
costs and to achieving the ‘savings’ which the new burdens assessment for the Act
and the Future Funding proposals envisage. We need to investigate how water
companies and other utilities can overcome some of the current rules that constrain
their ability to enter flexible funding arrangements with local authorities and others.
Q.2 Does this guidance explain how the power to request information should
be exercised in a reasonable way? If not, how might it be improved?
The guidance adequately explains the powers but needs more detail and examples.
Q.3 What barriers to co-operation and information sharing need to be
addressed?
Our members tell us that the main barriers are:

Having a common format to enable partners to easily access available data

Reluctance by some WaSCs to share data due to confidentiality concerns
Q.4a How much more effective do you feel statutory guidance would be than
non-statutory or no guidance?
Statutory guidance would help if informal partnership working/co-operation fails.
Our members report that obtaining data from non-statutory partners – private
businesses, local landowners, utility companies, rail companies etc. is proving more
difficult because there is little incentive for these partners to co-operate. Where an
informal approach fails, there is a need for statutory guidance to apply in these
situations.
Q.4b We have assumed that there will be a 25% saving in time dealing with
information requests because of statutory guidance and advice to follow, as
everyone will be working within a common framework. Please tell us if this is a
reasonable assumption or whether it should be more or less.
We would like to see evidence to support this assumption. Having guidance will
ensure the process occurs, but we are not sure if this will make it any easier or save
costs in reality.
Q.5 Do you have any suggestions for new sections to be included in this
statutory guidance? If so, please provide details.
The need to involve all utility companies, railways, etc. in FCERM and require them
to co-operate and share information.
It would be useful to include a section on the role of Coastal Groups in cross
boundary co-operation and co-ordination of coastal activities.
Q.6 If you are likely to be asked for information, are there any issues that may
make it difficult for you to respond?
Confidentiality issues and internal systems could make it difficult for any Risk
Management Authority to respond swiftly.
Q.7a How many requests for information do you feel a lead local flood
authority might make in any year?
This will probably depend on each LLFA’s local flood strategy, local occurrence of
flooding incidents, etc. so this is unpredictable.
Q.7b If you have dealt with comparable requests before, how long might you
expect it to take?
Less than 4 hours (short)
One to two days (medium)
Over one week (long) - unless the data/information is very easily
accessible
Other (please specify)
Please see individual local authority responses.
Q.8 Do you feel that the functions that the guidance relates to need to be set
out within it? If so, which option as expressed at the start of Annex B is the
most appropriate to use?
Yes.
Options 1 or 2 are preferred.
Q.9 Is there any additional non-statutory advice or supporting information you
would particularly wish to see (for example best practice or model agreements)
that would help further encourage co-operation and information sharing?
Case studies and model agreements (e.g. partnership terms of reference,
memoranda of understanding) are always useful. LGID has 6 case studies of local
partnership working on our flood web pages, but the LG Group is keen to be involved
in developing more specific case studies / models of working with utilities.
Local Government Group’s response to draft statutory
guidance on Local Flood Authorities’ contribution to
sustainable development
General LG Group comments
LG Group welcomes the proposed guidance and the opportunity it presents to embed
sustainable development principles within flood and coastal erosion risk
management. There are many opportunities within FCERM policy and practice to
promote better awareness of sustainable development and achieve innovation in the
way that we protect our environments and populations now and ensure they are
much better prepared for future climate change impacts.
Consultation Questions and LG Group response
Q1. Do you agree with the definitions of sustainable development used in this
guidance? Would you add anything further to the definition provided?
The definitions of sustainable development used in the guidance are consistent with
those generally used by local authorities.
Q2. How do you think local flood authorities currently contribute to sustainable
development? Are there other aspects of sustainable development or local
flood authority activity that should be referred to or given more prominence in
this guidance?
The contribution of local flood authorities to sustainable development currently varies
enormously, depending upon the maturity of the authorities’ flood risk management
function. However, it is difficult to completely separate the flood risk management
function of an authority from its overall contribution to sustainable development. In
many authorities they will be undertaking work on e.g. spatial planning or emergency
planning, which is very closely linked to sustainable development
The activities identified in the guidance are extremely comprehensive and will aid
project sponsors in the development of more sustainable responses to flood risk.
One aspect of sustainable development that is covered, but perhaps deserves more
prominence is the promotion of integrated approaches to land management, where
issues of flood risk and environmental benefits are considered alongside economic
sustainability and issues such as food security.
The guidance should recognise that there will be economic growth, leading to
development and this can sometimes be in conflict with flood risk. Arguably, these
conflicts can be resolved or balanced through sound spatial planning.
2.12 should recognise that promoting well-being will often involve economic growth.
Under 2.13 , Guidance should recognise that in some areas traditional defences will
remain essential if we are to safeguard food production and food security.
Section 2.14 only identifies environmental ‘multiple benefits’ and should include some
economic examples.
With regard to 2.17, local authorities are likely to find management of local
watercourses more challenging as financial and staff resources decline.
Q3. Can you suggest other sources of information that we should include in
the guidance?
There should be a reference to Planning Policy Statement 4: Planning for
Sustainable Economic Growth.
Box B.1 should include PPS25 which is a key part of the Government’s policy on
Flood Risk.
Q4. Does this guidance provide the level of information that you require, if not
what changes would you make?
The consultation was launched at the same time as the consultation on future
funding for flood risk management. It would seem appropriate that projects which
satisfy the sustainable development themes identified in this consultation would have
the greatest chance of success in meeting the criteria for funding, but the links
between the two documents are not entirely clear.
Further advice on the relationship between achieving sustainability goals and
securing funding is necessary.
Q5. This guidance is for local flood authorities. Should the Environment
Agency be required to have regard to this guidance in addition to their existing
duties towards sustainable development?
We agree that it is important that all Flood Risk Management Authorities are asked to
have regard to the same guidance.
There needs to be more recognition and understanding of the link between FCERM
and sustainable economic growth.
Q6. Do you agree with our assessment of the likely costs and benefits (outlined
in the Impact Assessment)? Do you have examples of tangible costs or
benefits resulting from adopting sustainable development approaches?
The assessment of costs and benefits does not refer to or relate to the costs that
local flood authorities might incur in the implementation of the guidance.
Though costs are likely to be justifiable in most cases, the promotion of some swift
and straightforward flood alleviation measures may be compromised if the tests used
to demonstrate sustainability are not applied in a proportionate manner.
An example from a related aspect of project delivery is the time, money and effort
that goes into some procurement systems to ensure ‘best value’, where the ‘savings’
are routinely outweighed by the administrative effort involved.
Q7. Do you agree with our preferred option (option 3 in the Impact
Assessment)?
We agree that option 3 is the most appropriate way to proceed, provided that it is
appropriately built into the process for allocation of funding.