Communication, Engagement and Consultation Strategy Flood and Water Management Northamptonshire County Council September 2013
Communication, Engagement and Consultation Strategy, September 2013 CONTENTS
1. COMMUNICATION AND ENGAGEMENT ...... 3
OVERVIEW OF STAKEHOLDER ENGAGEMENT ...... 3 GENERAL PRINCIPLES FOR ENGAGEMENT ...... 3 2. CONSULTATION STRATEGY ...... 4
ENGAGEMENT ...... 4 STAKEHOLDER INVOLVEMENT TECHNIQUES ...... 5 IDENTIFYING RISKS AND MANAGING THEM ...... 6 TAKING COMMENTS INTO CONSIDERATION ...... 6 3. CONSULTATION ON THE NORTHAMPTONSHIRE LOCAL FLOOD RISK MANAGEMENT STRATEGY ...... 7
FIRST PUBLIC CONSULTATION PHASE ...... 7 SECOND PUBLIC CONSULTATION PHASE ...... 10
Tables
TABLE 1-1: WHO AND HOW THE COUNTY COUNCIL WILL CONSULT ...... 4 TABLE 1-2: STAKEHOLDER INVOLVEMENT TECHNIQUES ...... 5 TABLE 2-1: FIRST PHASE CONSULTATION RESPONSES ON THE LFRMS ...... 8 TABLE 3-2: SECOND PHASE CONSULTATION RESPONSES ON THE LFRMS ...... 11
Communication, Engagement and Consultation Strategy, September 2013 1. COMMUNICATION AND ENGAGEMENT
1.1. Effective communication is fundamental to promoting better community relations and awareness of flood risk management issues, and encouraging people at risk to take action before and during a flood. Overview of Stakeholder Engagement
1.2. The 1992 United Nations Conference on Environment and Development raised the importance of stakeholder engagement in environmental decisions, and placed it on an official footing, both in Principle 10 of the Rio Declaration and Agenda 21 (the action plan for sustainable development).
1.3. The requirements of the Convention for stakeholder participation in projects include:
Timely and effective notification of the stakeholders concerned; Reasonable timeframes for participation, including the provision for participation at an early stage; An obligation on the decision-making body to take due account of the outcome of the stakeholders participation.
1.4. The European Union Water Framework Directive (WFD) also places an emphasis on stakeholder participation. In England, the Environment Agency is the authority responsible for implementing the WFD. The Environment Agency is required to consult with stakeholders throughout the process, and encourage the active involvement of stakeholders.
1.5. One of several recommendations of the Pitt Review was to ensure effective public and stakeholder engagement and a coordinated approach to flooding and water management. This recommendation has now been encompassed within the Flood and Water Management Act (2010), which promotes partnership working and community and stakeholder engagement. General Principles for Engagement
1.6. It has been agreed that the following principles shall apply to all work completed by the County Council:
Principle 1: Engagement is a two-way process. We will listen to what people have to say and consider this in developing our assessments and strategies; Principle 2: Engagement will be planned, programmed and publicised. We will link involvement to those key times when input from stakeholders will be valuable in helping us increase our understanding around flooding and water management and when plans and strategies are being produced; Principle 3: Engagement will be relevant and practical. We will ensure that engagement is relevant to the issue and that techniques used are appropriate. Principle 4: The purpose of the engagement will be made clear. We will explain clearly and honestly why people are being asked for their views or opinions and how those replies will be taken on board and used. Principle 5: Responses will be used in an effective manner. We will be clear about why we used the information from the consultation in the way we have.
Communication, Engagement and Consultation Strategy, September 2013 3 2. CONSULTATION STRATEGY Engagement 1.7. There is a formal requirement for stakeholder engagement for much of the work undertaken under the Flood and Water Management Act. Stakeholder engagement will take place early on and consultation will be a two-way process.
1.8. The County Council will choose methods and processes of engagement to make them as relevant and effective as possible. There is no single ‘right’ way to engage, many techniques are appropriate, however the way the Council will do this will depend on the targeted stakeholder and the particular objectives of any specific consultation.
1.9. The County Council will seek to structure engagement in a way that will genuinely gauge the views of stakeholders. Activists and lobbyists will be listened to, but the Council will not see them as necessarily representative of the cause they seek to promote.
1.10. The table below provides information on whom and how the County Council will attempt to consult for all documents produced under the Act Table 2-1: Who and how the County Council will consult
Who Who they represent How to Consult
Elected District/ Local Residents/ Wards These will be emailed the consultation Borough and County material and be informed of relevant Councillors in events specific to the particular Northamptonshire consultation and their interest in it, including member workshops/ presentations/cabinet/scrutiny.
Environment Agency The Secretary of State They will be sent details of the for Environment, Food consultation material and be informed and Rural Affairs and of relevant events specific to the deliver the particular consultation. environmental priorities of Central Government
Local Resilience Emergency Planning; These will be informed by letter of the Forum Hospitals; Primary Care consultation and how they can Trust (PCT); East specifically engage in the process as Midlands Ambulance well receiving update papers via the Service; County Council Flood and Water District/Borough Management Framework. Councils; Environment Agency; Military Northamptonshire Public service Through the receipt of update papers Public Service Board organisations via the County Council Flood and Water Management Framework.
Internal Departments The County Council These will be informed by email of the – County Highways, consultation and how they can Environment Unit, specifically engage in the process. Emergency Planning etc
Highways Agency Department for Will be sent copies of the consultation Transport on behalf of material and be informed of relevant the Secretary of State events specific to the particular for Transport. consultation and their interest in it.
Communication, Engagement and Consultation Strategy, September 2013 4 Who Who they represent How to Consult
Neighbouring Adjoining area Will be sent details of the consultation Unitary Authorities/ material and be informed of relevant County Councils events specific to the particular consultation and their interest in it.
Water Companies Anglian Water Will be sent details of the consultation Thames Water material and be informed of relevant events specific to the particular Severn Trent consultation and their interest in it
Parish Councils Will be sent details of the consultation informing them how they can engage in the process and where they can view the consultation material. Including consultation leaflets & questionnaires.
Residents Residents Will be sent details of the consultation Associations (list) informing them how they can engage in the process and where they can view the consultation material. Including consultation leaflets & questionnaires.
'Community Groups' Specific sectors of the Will be sent details of the consultation – Organisations community, including informing them how they can engage in older people, people the process and where they can view with disabilities, the the consultation material. Including black and ethnic consultation leaflets & questionnaires. community, faith groups and the voluntary sector
Local interest and Specific members of Will be sent details of the consultation pressure groups the public/sectors of the informing them how they can engage in community the process and where they can view the consultation material. Including consultation leaflets & questionnaires.
1.11. When the consultation involves meetings and exhibitions the County Council will hold them in accessible locations and at accessible times of the day for those the consultation seeks to engage with. Stakeholder Involvement Techniques 1.12. The table below provides a brief summary of a number of techniques that may be appropriate to use in the involvement of stakeholders. Table 2-2: Stakeholder involvement techniques
Methodologies to Comments involve stakeholders
Questionnaires and Structured way of obtaining basic information that can be easily Surveys analysed. Able to reach a large number of people, they are convenient, economic and thus a good staring point. They need to be well structured and ensure that the questions are not leading.
Communication, Engagement and Consultation Strategy, September 2013 5 Methodologies to Comments involve stakeholders
Exhibitions Useful way of presenting basic information and options to the public, especially local communities. Able to reach large numbers of people if well advertised. Allows face to face feedback of information.
Public Meetings Enable presentation of basic information to the general public. Allow large numbers of people to be involved in some limited discussion. Need to be carefully managed to ensure all views are heard.
Use of the full range of Engages large numbers of the population, through newspapers the media and the radio. Useful at reaching those who may be more difficult to involve.
Workshop/ Structured group discussions designed to solve problems and presentations identify ways forward. Useful in bringing different groups of experts together.
Identifying Risks and Managing Them
1.13. When planning engagement exercises, the following risks should be considered:
Lack of interest, willingness or trust in the exercise, which will lead to a low response rate; Lack of understanding of key issues; The responses may add little to the debate/ contain insufficient detail; The responses received may represent a narrow range of opinion (e.g. if only specific action groups respond); The responses may not show consensus about the issues and the possible solutions/conclusions.
1.14. The inevitable differences and conflicts arising from responses to consultations will need careful consideration, weighing up and balancing. The County Council will be clear about why it has used the information gained in the way it has.
1.15. The County Council will build in procedures to monitor and evaluate the effectiveness of its engagement exercises. This will let the Council know whether what it is doing is genuinely helping in the way it listens and responds. Taking Comments into Consideration
1.16. The County Council will ensure that it uses any comments it receives to really inform the content of its documents. Engagement will not just be a formal ‘stage’ that has to be undertaken; it will help to shape the County Council’s documents.
Communication, Engagement and Consultation Strategy, September 2013 6 3. CONSULTATION ON THE NORTHAMPTONSHIRE LOCAL FLOOD RISK MANAGEMENT STRATEGY
1.17. The County Council has sought public responses to assist in the development of the Local Flood Risk Management strategy. The public consultation was undertaken in two phases: firstly a generic consultation to determine priorities and objectives for the Strategy, which was linked to the Northamptonshire Flood Fairs; and secondly a consultation on the draft Strategy. First Public Consultation Phase 1.18. To help raise flood awareness amongst the public, and to launch the first public consultation on the LFRMS, a series of Flood Fairs were held across the county in partnership with the Environment Agency and Anglian Water in 2011. The key aim of the Flood Fairs was to provide the opportunity to:
Raise awareness of the County Council’s new role and responsibilities; Consult with local councils/organisations and the public on the Northampton Surface Water Management Plan; Talk to people about the Local Flood Risk Management Strategy being drafted; Identify and inform of areas at risk of flooding; and Advise people of how they can be prepared for a flooding situation and encourage resilience.
1.19. The invitation to attend the fairs went to all Parish and Town Councils, all District and County Councillors as well as all Environmental and Community Groups across the county. The Environment Agency also invited residents located within a flood risk area in the county. The Flood Fairs were held on the following dates:
Wednesday 2 November 2011, 11:00 - 19:00 The Council Chamber, East Northants District Council, Thrapston; Thursday 3 November 2011, 11:00 - 19:00 The Committee Room, South Northants District Council, Towcester; Friday 4 November 2011, 13:00 - 20:00 The Great Hall, Guildhall, Northampton Borough Council, Northampton.
1.20. The County Council actively promoted self-reliance with regard to flood risk and staff were on hand to give advice on the preparation of a Flood Emergency Plan for householders, and also more specialist advice on the preparation of a business continuity plan for businesses who might suffer as a result of a disruptive incident such as a flood. Staff were also promoting awareness of the County Council’s new roles and responsibilities under the Flood Risk Regulations (2009) and Flood and Water Management Act (2010) and informed people about the consultation on the Local Flood Risk Management Strategy.
1.21. Information was available from the Environment Agency on how to prepare community flood plans and personal flood plans, how residents can get involved through the Parish Council flood warden schemes, checking postcodes and encouraging the sign up to Floodline Warnings Direct (a free service that the Environment Agency offer for those that in a flood warning area).
1.22. Representatives from Anglian Water were also in attendance to answer questions relating to the Big Sewer Switchover, which took place on 1 October 2011. They were able to provide advice and guidance on specific issues and were also raising awareness about issues concerning fats, oils, greases and unflushables that find their way into the sewers.
Communication, Engagement and Consultation Strategy, September 2013 7 1.23. The flood fair exhibition brought together a large gathering of flood defence equipment suppliers, manufacturers and specialists. Visitors were able to see at first hand a wide range of products displayed by the exhibitors at the event. The products available showed residents how to protect their homes and businesses from the ingress of water during a flooding incident. These included simple solutions such as "synthetic" sandbags and door guards and air brick covers for homes.
1.24. Nearly 240 individuals attended over the three days as follows:
Forty-seven attendees at Thrapston; Sixty-nine attendees at Towcester; and One hundred and twenty-three attendees at Northampton.
1.25. Fifty four additional historic flooding hotspots were collected from individuals attending the flood fairs over the course of the three days. The data was collected using interactive mapping, which was projected on a large plasma screen.
1.26. Alongside the Flood Fairs, opinions were requested on what people regard as priorities as well as collecting information about areas that have experienced flooding within the county in the past. Feedback forms were distributed to enable the public, businesses, Local Authorities and other organisations to submit responses. The feedback form was also available to download from the Flood and Water Management pages of the County Council’s website.
1.27. The first consultation phase ran for a three month period. The general themes and content of those responses and how the matters highlighted were addressed within this strategy have been set out below. Table 3-1: First Phase Consultation Responses on the LFRMS
Question Consultation Response Northamptonshire LFRMS 1. Having now a) Yes, particularly villages previously a) The strategy will identify the highest had the affected by flooding and how to risk areas in the county and provide opportunity to prevent further events. property level resilience and view the resistance advice. information on the County Including sign-up to flood warden, Council’s flood warning scheme and it will website and to also identify the need for potential attend a Flood flood defence schemes. Fair, are there b) The strategy needs to set out b) It is not the strategy’s place to be any additional insurance measures and what is and specific about insurance measures subject areas is not covered. but will provide advice on the where that you feel to go for further information. should be included in the c) The coverage of subjects appears to c) N/A Local Flood Risk be comprehensive. Management Strategy? d) Consider that there should be greater d) More information has been publicity of the role and provided on the NCC flood and responsibilities of riparian owners in water management webpage. The the management of flood risk. roles and responsibilities will also be clearly set out in the LFRMS.
2. What flood or a) In built up areas there is poor road a) The LFRMS will set out the water drainage. In rural areas there is maintenance regime currently in management neglect of drains and ditches and the place and the proactive initiative of alleviation infrastructure in particular is not the gully clearing regime. schemes do you keeping up with new building. think should be included in the b) The drains and culverts should be on b) N/A regular maintenance programmes.
Communication, Engagement and Consultation Strategy, September 2013 8 Question Consultation Response Northamptonshire LFRMS strategy? c) Brooks and streams in residential c) This is a riparian owner issue and areas should be cleared and the roles and responsibilities will be regularly maintained. clearly set out.
d) Notice given prior to gully gushing to d) N/A ensure vehicles don’t block storm drains.
e) Clearing all the surface and storm e) N/A drain channels of rubbish and blockages immediately before floods occur.
f) Management of smaller brooks and f) N/A waterways should be covered by this plan, which if blocked can have a significant impact on the drainage of water.
g) More regular inspections of drainage g) The will continue to be prioritised systems required. on a risk basis. The process for reporting any issues will be clearly set out in the LFRMS.
3. How should a) Pressure should be placed on a) Riparian owner responsibilities will reducing the farmers to keep ditches in good be clearly set out in the LFRMS. flood risk to condition for the purpose of people, improving water storage or run off property, from fields and conducting away business and excess water in a more controlled the environment manner rather than washing over be prioritised? adjacent roads.
b) The elderly, young, handicapped b) This has all been factored into the should be prioritised. priority grading risk methodology.
c) Greatest priority must be given to c) N/A areas where life is endangered but more concern must also be given to addressing the potential impact of new developments in a catchment area.
d) Priority should be given to life and d) As above then property, business and environment.
e) Emergency funding should be put e) Adequate insurance should be aside for assisting those affected. sought by home and business owners. Funding generally is covered in the LFRMS.
4. Different a) Yes, much clearer now. a) N/A organisations have different b) Roles are clear enough. The acid test b) Roles and responsibilities will be responsibilities is whether the organisations actually clearly set out in the LFRMS. for managing take action rather than studying and flood risk. Are talking about the problems. There is these roles now also a need for greater clarity over clear? If not, riparian responsibilities where there how could they is complex ownership. be made c) No clearer than before the flood fair. c) N/A
Communication, Engagement and Consultation Strategy, September 2013 9 Question Consultation Response Northamptonshire LFRMS clearer? d) Very blurred, nobody admits to it yet d) N/A always prepared to put the blame onto others. Get the drains cleared properly then blame politicians for NOT doing it – typical political approach.
e) There should be better cooperation e) The partnership working approval between Highways Departments and will be set out in the LFRMS – all Anglian, Severn Trent and Thames organisations set out are partners. Water.
5. Are you or a) Yes, we have the Emergency a) This good work will be highlighted your council/ Planning group and we try to inform within the LFRMS. organisation the organisations what is wrong in an involved in any attempt to make improvements. flood risk management b) Yes, an active flood warden trying to b) N/A activity? And if get action out of the County Council. so what? c) The Parish Council has no c) Promotion of flood warden responsibility in this area so it is left schemes and community flood to individuals to take action. plans will be included.
d) No. All local councillors are ignorant d) N/A of duties and responsibilities.
e) Personal examination of potential e) N/A water blockages.
Second Public Consultation Phase 1.28. Once the draft Strategy had been agreed by all partners, the full report and accompanying documents were published for consultation online on the Flood and Water Management pages of the County Council’s website: http://www.northamptonshire.gov.uk/en/councilservices/environ/flood/pages/default.aspx. A feedback form was provided on the website for responses. Opinions were requested on each section of the Strategy, plus specific views on each of the Objectives, the actions within the Action Plan, whether there were any additional actions that could be included, and requests for further information regarding historic flood incidents that have not been previously reported.
1.29. The public consultation ran for three months, ending on Thursday 28 February 2013. The general themes and content of those responses, and how the matters highlighted have been addressed within this Strategy have been set out below. All comments received were analysed and minor changes made to the Strategy as a result. This ‘living document’, will be taken to Cabinet for full approval on the 8th October 2013. The action plan will be updated annually and the full strategy will be reviewed once every three years.
Communication, Engagement and Consultation Strategy, September 2013 10 Table 3-2: Second Phase Consultation Responses on the LFRMS
Organisation & Representation Consultation Response Lead Local Flood Authority Response Proposed Amendment number National One of the main issues with the strategy is that farming needs to Agree. Farmers Union take place on well-drained land to be profitable and productive. 01 Flooded or boggy land is not good for agriculture. The strategy does not recognise this and assumes that it will be Noted. The strategy does not reference land easy to acquire land for flood storage areas or persuade farmers acquisition. It is appreciated that each case to accept floodwater or more frequently flood land – it will not. would need to be assessed on its own merits in terms of the potential costs and benefits of the proposal. Paragraphs 7.3.12 and 7.3.14. If you have got proposals for The attenuation areas that have been flood storage areas agreed with farmers and landowners then identified relate to the provision of storage great. If you haven’t, how will you get these? There will need to required to facilitate future growth. The exact be incentives for farmers to give up productive land and locations have not been established. It will compulsory purchase will not cut it. If proposals are made be for the developers to liaise with the land- without consulting landowners and farmers this could easily lead owners in relation to this matter. There is no to blight and land not being able to be sold. intention to compulsory purchase land.
Paragraph 7.3.16. There is no mention of farming in the section Noted. Add new sentence on the impact that and the damage that flooding and poor land drainage will do to flooding can have on the productivity agriculture. and related profitability of agricultural land. Paragraph 7.3.28. Flooding also occurs because of too much Noted. All sources of flood risk have been rain, saturated soils and watercourses that are not maintained. identified in Section 2 of the Strategy. The You cannot expect catchments to look after themselves without intention is to work with all landowners, ongoing maintenance of channels. No matter how well farmers including farmers to educate them in relation farm, there will always be soil that runs off into rivers and other to their riparian roles and responsibilities, debris that falls into watercourses that has to be removed after a particularly in locations where a flood risk build up in rivers. has been identified. We support paragraph 7.3.29. Noted. Paragraph 7.3.31. We would prefer it if the strategy did not Noted. Each case would need to be Delete final sentence of paragraph encourage a witch-hunt against farmers and mass reporting of assessed on its own merits. 7.3.31. alleged misdemeanours to the Rural Payments Agency. Ise Valley There are two places in the valley where clearance of waterways The maintenance and clearance of Protection that are partly blocked could, if cleared, assist your Flood Risk watercourses plays a key role in land
Communication, Engagement and Consultation Strategy, September 2013 11 Group Management Strategy. If cleared, would assist the prevention of drainage and flood risk management. 02 excessive flooding of the valley in times such as we are now Responsibility for maintenance of experiencing. The first is an un-named stream draining land from watercourses, particularly in relation to the direction of Little Harrowden draining into the River Ise, and roadside ditches, is not generally well the second is a field edge ditch which has not been cleaned out understood. for many years, resulting of excessive flooding of the field If a watercourse or ditch fall within or adjacent to Finedon Station Road and adjacent residential adjacent to the boundaries of your land, properties in Finedon Road. under common law this means that you are legally the “riparian owner” of the watercourse at this location. As a riparian owner you have certain rights and responsibilities, including the maintenance of the bank and bed of your section of the watercourse. Part of the service provided by NCC is to first identify the Riparian Owners and to then outline their roles and responsibilities and ensure that actions are taken/improvements implemented where considered necessary. Kettering Sections 1-7 are appropriate. Noted. Environment The Strategy has much more “management approach” than Noted. Forum; Member hydrologist about it, which given that it is a planning document of British and how few hydrologists are engaged in planning except as Hydrological consultants or with the Environment Agency is not surprising. Society 03 Whilst what used to be referred to as “Return Frequency” usually Noted. Agree that the probability of flood risk Add the following to Section 2 of the in years of floods of a magnitude this is now expressed on 1:30 should be made clearer within the LFRMS: 1:100 risk, but not explained as flood events. Recent events in introductory part of the LFRMS. The probability or likelihood of Cambridgeshire and Devon illustrate this well where properties flooding is described as the chance have flooded several times this year. As a document for ‘lay that a location will flood in any one readership’ this probably needs to be understood by them. year. Floods occur and nature does not always follow a simple If a location has a 1.3% chance of magnitude. Frequency relationships which appear statistically. flooding each year, this can also be expressed as having: a 1 in 75 chance of flooding in that location in any year odds of 74 to 1 against a location being flooded in any year However, this doesn't mean that if a
Communication, Engagement and Consultation Strategy, September 2013 12 location floods one year, it will definitely not flood for the next 74 years. Nor, if it has not flooded for 74 years, will it necessarily flood this year. When we describe the chance of flooding, we give it one of three descriptions or put it into one of three categories: Significant: the chance of flooding in any year is greater than 1.3% (1 in 75) Moderate: the chance of flooding in any year is 1.3% (1 in 75) or less, but greater than 0.5% (1 in 200) Low: the chance of flooding in any year is 0.5% (1 in 200) or less The lower the percentage then the less chance there is of flooding in any one year; the higher the percentage then the more chance there is of flooding in any one year. Page 22 – surely the County has flood risk areas even if the Noted. Northamptonshire does have locally Environment Agency does not think so. defined flood risk areas, but a flood risk area in this context is an area where there is a Nationally significant risk of flooding from local sources, such as surface water, ground water and ordinary watercourses. These areas have been identified using guidance produced by Defra. They were produced by applying the method in the Government guidance to produce 'clusters' of areas where flood risk is an issue and then applying the thresholds agreed by Ministers of 30,000 people at risk of flooding within a 6km grid square area in England. Using this National methodology there are only 10 Flood Risk Areas in England, including:
Communication, Engagement and Consultation Strategy, September 2013 13 1. Bristol 2. London 3. South Essex 4. Medway 5. City of Brighton and Hove 6. West Midlands 7. Leister Principle Urban area 8. Liverpool and Sefton 9. Greater Manchester 10. Kingston upon Hull and Haltemprice. There is probably a need to look back beyond the 2007 event. Noted. The historic flood risk records that are Add additional historic background At a personal level the melting of deep snow after the falls of held do extend back to the 1947, 1958-9 and information in Section 6.1 of the 1947 and 1958-9 produced significant flooding in the Oxford 1964 events. These are included on the LFRMS. Cherwell as Thames catchments. That of 1964 was slowest but hotspot map. there was flooding in the Bedford Great Ouse and Cherwell catchments resulting from no infiltration to frozen ground. This raises the point about catchments. The County Boundary is Noted. It is appreciated that catchment- Add section on cross-catchment marked by historical boundaries. The Welland, the Cherwell and based approach towards flood risk working arrangements in Section 5 of the Nene as well as part of the Great Ouse impact on the County management would be extremely sensible the LFRMS. which contains some of their headwaters and tributaries. Can and this has already been undertaken by the this plan be compatible with those for adjacent parts of Environment Agency when developing Cambridgeshire, Bedfordshire, Oxfordshire, Warwickshire, CFMPs. Although this LFRMS is based on Leicestershire and Rutland. It is this political use of rivers in the County Boundary as this falls within the history which makes consistent planning around their behaviour LLFAs remit, NCC continue to work closely difficult! Within the County the Brampton Nene must no make a with neighbouring LLFAs, to ensure that any divide between “sides” of approaches over outcomes. The 2010 cross catchment boundary issues are Government Act is perhaps more aspirational than its authors addressed. thought. In the context of flooding and flood events the term sewer needs Noted. More information regarding the new Para 3.2 add wording: Sewers and some development – main line sewers, sewer as a term for a sewer standards will be provided. lateral drains connected to the public pipe greater than a certain diameter or cover a Fenland Drain. sewer on the 1st July 2011 were (Section 3.2) transferred into Water Company ownership on the 1st October 2011. There were exemptions and the main non-transferable assets were as follows: Surface water sewers and lateral drains that did not discharge to
Communication, Engagement and Consultation Strategy, September 2013 14 the public sewer, e.g. those that discharged to a watercourse. Foul sewers and lateral drains that discharged to a privately owned sewage treatment/collection facility This ensures that new private sewers are not created after the completion of the private sewer transfer. Section 4 - Since serious flooding affecting either small areas Noted. The Northamptonshire Multi-Agency very badly or large extensive areas sufficiently to cause Flood Plan (MAFP) undertakes this role. disruption of services occurs relatively infrequently should there More information regarding this document is be a countywide overall flood management alleviation structure? set out in Appendix 7 (Civil Contingencies This would both co-ordinate operations within the county, involve and Community Resilience) of the LFRMS. the Boroughs or Districts as well as the water companies and the Environment Agency. It would ensure consistency of approach to managing flood events and enable the training of people to work with flooding. The County Fire Service should be involved together with the Ambulance Services. It should go a long way to meeting the aspirations and requirements of Section 6 refer to in (paragraphs 4.15 – 19). Too much localism and District orientation might well forget that stream and river catchments and their behaviour is not controlled by regulations. Physical structures which reduce the immediate flood risk in an Noted. area may well transfer that problem downstream. (Section 39 paragraph 4.15) as read illustrates that point. In this the Environment Agency’s position is weak. (4.24 Noted. Additional clarification to be provided Include a new section under Section 3 Reservoirs) What is the situation in respect of Flood regarding reservoirs. Legislation on the Reservoirs Act of Management of Reservoirs which are not owned or managed by 1975, and the amendments made by the Water Companies? These could provide capacity to mitigate the FWMA. Explain roles and flooding by holding water. The numbers 25,000m2 and responsibilities under the Act, and 10,000m3 in themselves mean very little. Is the number a requirements to produce onsite and national capacity of the mean capacity? How far do reservoirs offsite plans. such as Thorpe Malsor and Cransley which are no longer in use for water supply fit into the Flood Risk Management plan and to what extent are their present owners drawn into the management process. The need to release water to provide flood water holding capacity might be seen by some to conflict with sailing or fishing interests. This may be especially so if the
Communication, Engagement and Consultation Strategy, September 2013 15 anticipated flood event is of a smaller magnitude than predicted. (Paragraph 4.31) - Rightly focus on motorways and A class Noted. roads. In a flood situation minor roads may have a strategic importance. Rather as illustrated in December events failure to recognise the problems and the risks by motorists absorbed Fire Service resources to ‘rescue’ people. A small step towards public risk awareness could be more water depth indicates boards on ‘B’ and unclassified roads. (4.38) - Whilst not contributing directly to Flood Risk Noted. Para 4.38 add the following Management: - The Centre for Ecology or Hydrology has done organisations to the list: much work on the courses of flooding. Similarly there is Centre for Ecology and Hydrology, expertise in the Institution of Civil Engineers and the British the Institution of Civil Engineers; and Hydrological Society which can be used at the society level and the British Hydrological Society. as consultants. (Section 6) - Whilst 6.1 sets the scene it might be enhanced by Noted. More historical information should be Para 6.1 add additional information reference back to the 1947 floods which certainly has an impact provided. regarding about historic flood risk in in the Fens. Whilst some of this has been attributed to lack of Northamptonshire dating back to management and maintenance during the Second World War 1947. the flooding was substantially the result of rapid snow melt. The estimation of yield of water from snow is difficult. Whilst there is Para 2.10 - add section on snow melt a “simple” metrological conversion to rainfall equivalents, snow and associated ratios. which has lain for days or weeks presents a very different problem. Similarly thunderstorms are frequently localised in their Noted. maximum intensity. Observation would subject the Brampton Nene, the Nene between Northampton and Thrapston might be more thunderstorm prone than other areas. If rainfall data is available for daily totals at Sywell, RAF Brampton and Wittering together with Thurleigh or Cardington this could prove a useful strategy development tool. Map 3 could be one of a ‘series’ of depth-magnitude duration Noted. However due to data protection it is and of return frequency based on the local data. The alternative not possible to provide this level of would be to select a number of locations and provide this as information. tabulated information. Hartwell Parish Does the flooding along Forest Road, Hartwell as a result of Forest Road was identified as a flooding Council blocked drains count as a flood risk due to the size and depth of hotspot, and maintenance falls to NCC and 04 puddles constantly on the road? Anglian Water. The gullies along this road are inspected every other year. They were
Communication, Engagement and Consultation Strategy, September 2013 16 inspected in September and October 2010 and in January 2013. Where a defect has been reported, for example a jammed grid or blocked outlet, corrective action has been taken. NCC would surely be responsible for flooded roads as ordinary The highway is not classified as an ordinary watercourses? watercourse. Para 2.15 of the strategy clearly defines what constitutes an ordinary watercourse. Weedon Bec The Parish Council does not have any comments to make in Noted. Parish Council respect of the Strategy although would like to point out that 05 whilst we have not flooded since the dam at Dodford Mill was completed, we were close to it before Christmas. As Weedon is primarily in a valley we do suffer a lot with run-off Noted. from the hills. The Parish Council holds a stock of sand bags and these were given out just before Christmas to five properties who did suffer flooding issues from the run-off. MGWSP do jet our drains once a year although we have some Noted. underground broken pipes on a road that runs down from a hill and which leads to the village centre. Dingley Parish The overall themes and objectives of the strategy are supported. Noted. Council The roles and responsibilities relating to flood risk management Noted. 06 of all organisations, agencies and authorities are clear. The remit of the local partnership and governance arrangements Noted. is satisfactory Geographic prioritisation makes sense as the degree of risk is Noted. greater in some areas. The collaborative approach is eminently sensible. Noted. We support Objective 2: Local Flood Risk – this is a good way to Noted. assess risk. We agree with the protocol for flood investigations. Noted. We support Objective 3: Enhance the Natural Environment. Noted. Objective 4: Preparedness and Resilience is appropriate. Noted. Objective 5: Flood Risk and Development is sensible. We would Noted. This part of the strategy does especially emphasise the importance of flood risk in considering emphasise the importance of the
Communication, Engagement and Consultation Strategy, September 2013 17 planning applications in flood risk areas. consideration of flood risk as part of the planning process. We support all of the Consenting Policies set out in Objective 5, Noted. Flood Risk and Development. We support Objective 6: Economically Sustainable Approach. Noted We support Objective 7: Riparian Responsibilities. Noted. We support the content of the Action Plan Noted We agree with the proposals for the timescale of reviewing and Noted. updating the strategy. The strategy is well thought out and comprehensive. Noted. Member of There is a danger of the flooding at Desborough (old leisure Noted. The area of Desborough referred to Public centre) fields. The River Ise has been widened. Unfortunately as relates to Main River, which continues to fall 07 a dog walker I am down there every day. I was very concerned within the remit of the EA rather than NCC. for my dogs, as they don’t need to be on leads, and the risk of This area is a natural wet meadow and will them going into the water. The bridge which crosses the river be prone to flooding in high periods of rainfall was completely flooded and there are related safety issues. as experienced in 2012/13. The site is Another concern is once the old leisure centre is taken down and owned by KBC and managed by the Wildlife new houses are built near the flooding what health and safety Trust and therefore any health and safety issues it will cause, let alone insurance costs. I would also like to related issues should be addressed to them question whether sewer water gets into the water? A lot of as this does not fall within the remit of the paper, facial wipes and sanitary towels were found in all the LFRMS. bushes around the banks are the flooding. This is a nice place to walk, and its ruined by the fact of all the unsightly things With regard to debris within the river, this mentioned above, people with families and kids don’t want to would fall within the remit of Anglian Water see this. Services as they have discharge points into the river and the EA will monitor the quality of the water.
NCC does not respond to planning application related matters. This is currently a function of the Environment Agency. Deanshanger We are extremely concerned that our village, which has the NCC’s prioritisation assessment calculates Parish Council King's Brook running through it, has such a low profile in your the number of receptors (for example homes, 08 future plans. hospitals, main roads, sewage treatment works) that are at risk of flooding. The assessment is based on the calculated risk
Communication, Engagement and Consultation Strategy, September 2013 18 of flooding rather than records of previous flooding, and the assessment is undertaken on a ward-by-ward basis, so that the wards with the highest number of receptors at risk of flooding can be prioritised for proactive works. We do hope that action is taken to improve your knowledge of NCC will continue to investigate any flooding our village flooding issues. incidents that meet the threshold and will continue to build up our knowledge of flood related matters by working with communities. The historic flooding in the lower part of the village has Noted. Flood risk implications are considered been further complicated with the recent building, over a ten by the Local Planning Authority in line with year period, of many new houses. Many villagers believe that national requirements at the planning the incidents of 'near misses' have increased over this period. application stage. The EA remains a statutory consultee for all future development, which meets the threshold for comment. We broadly welcome your Flood Management Strategy and look Noted. forward to working with you, in order to make Deanshanger a safer and even more pleasant Northamptonshire settlement. We also request that the King's Brook is placed on your asset Noted. All watercourses will be placed on our register. asset register as and when they are identified. The overall themes and objectives of the strategy are supported. Noted. The roles and responsibilities relating to flood risk management Noted. of all organisations, agencies and authorities are clear. Agree with the broad remit, membership and procedures of the Noted. local partnership and governance arrangements. Strongly suggest Deanshanger village has a site visit, and the Noted. Any additional photographic evidence photographic evidence we hold looked at, in order to raise our would be welcomed. profile as an area of high risk ‘near misses’ as well as recorded flooding incidents. Our records show the area of High Street, Patricks Lane, and Noted. These have all been added to the The Green as being main risk areas (2007 last flooding of flooding hotspot data held. properties), plus new flood incident areas of top of Glebe Road, Canal Lane and The Smithy as being of concern to us in recent years.
Communication, Engagement and Consultation Strategy, September 2013 19 Support Objective 1: Collaborative Approach. Noted. We support Objective 2: Local Flood Risk. The Kingsbrook, Noted. flowing through Deanshanger, which regularly causes ‘ near misses’ and floods in severe circumstances, needs to be registered on the formal and centrally held asset register. Yes, we agree with the protocol for flood investigations. Noted. NCC only gained the duty to Presumably, as this was not in place in 2007, Deanshanger did investigate flooding incidents in April 2011. not qualify for monitoring or investigation, although 5 properties Any incidents from this date that meet the were affected by flooding in one flood incident? threshold will be investigated. We support Objective 3: Enhance the Natural Environment. Noted. We support Objective 4: Preparedness and Resilience. Noted. We support Objective 6: Economically Sustainable Approach. Noted. We support Objective 7: Riparian Responsibilities. Noted. We support the content of the Action Plan. Noted. Deanshanger Village Heritage Society regularly clear out the Noted. brook, or those parts possible, with no cost to NCC or SNC, and under their own community awareness programme. However, as We are continually looking for flood wardens a party of a few individuals, with limited resources, the Parish or community flood forums to help provide Council would ask it to be recognised that their efforts are valuable information before, during and after voluntary and constrained by many factors. Their local a flood. The wardens act as the eyes and knowledge is their prime tool against the flooding of the brook. ears in communities at risk of flooding. The Local knowledge is key in the flood management of village wardens’ eye witness reports are invaluable watercourses. to support information on river levels and drainage issues. They can also help ensure that local residents have received flood warnings.
Since the flooding experienced in November and December 2012 and January and February 2013, residents have been volunteering as flood wardens for their community. We recognise the important role played by these individuals, and want to support their efforts and to expand their network by recruiting more wardens.
Communication, Engagement and Consultation Strategy, September 2013 20 Having a flood warden and/or a community flood forum in your community is yet another way of helping to protect your homes. They play a vital role in raising awareness of the dangers of flooding and help residents to stay safe within their communities.
The additional information that a warden can provide, might mean extra precious minutes for residents to save themselves and their property.
There are areas in Northamptonshire that are at particular risk of flash flooding because of the local landscape and proximity of watercourses, so we are urging residents find out how they can prepare for flooding. If you plan what you would do in a flood, you are more likely to stay safe. NCC can help flood wardens and communities with the necessary training and guidance to ensure they are prepared. We agree with the proposals for the timescale of reviewing and Noted. updating the strategy. We would strongly advise that the village of Deanshanger be Noted. regularly monitored through visits and consultation with Parish Council and local residents regarding ‘near misses’( several each year) and flooding incidents which occur in severe circumstances. Some of the latter only sometimes prevented from flooding properties, by the resourcefulness and community involvement of neighbourhood alert teams, as well as the Deanshanger Village Heritage Society Brook Clearances undertaken once or twice each year. Syresham We wish to see a genuinely effective and collaborative approach Noted. Parish Council to the identification and recognition of problems and the taking of 09 relevant remedial actions. Our experience in the past has been that we feel we have been Noted. rather left out of actions to identify and prevent serious flooding, but recognise that this is a mammoth task.
Communication, Engagement and Consultation Strategy, September 2013 21 Although the frequency of serious flooding in this village is not all Noted. These incidents have all been that great, in comparison with other incidents elsewhere in the captured on the NCC Flood and Water county, there have been specific events over recent years [2001, Management historic flood incident 2008, 2010, 2012 and others] which have required external database. agency and emergency services support. They have also attracted some media interest. Distress has been caused to householders in these instances. Noted. We believe that the relevant agencies should develop improved mechanisms for locating and recording incidents and giving them appropriate priorities and acknowledgement back to Parish Council This village experiences flooding on Wappenham Road at the Noted. The improvement scheme outlined in bottom of Bell Lane and Broad Street, including to a small the action plan on Page 105 was completed number of properties located close to the brook and in the lower in 2012/13. Flooding in Syresham is being lying areas where surface water run-off from nearby fields and investigated further. roads shows that drains in some cases are incapable of coping with heavy rainfall and its knock-on effects. This location has been identified as in need of works to prevent future flooding [Page 105 – table entry for Syresham]. We see it has been classified as medium priority with up to 3 years before possible completion. We believe that a more regular pattern of flooding following heavy rainfall has developed with the increasing impact of climate change, thus making our own case a higher priority. Similarly at High Street outside the school, and at the junction of Noted. High Street and the old A43 [Main Road], there are frequent problems of standing water. These issues lead us to believe that there is a need for more regular and detailed investigations and cleansing as a key factor in the eradication of flooding in this village. We recognise that these are issues specific to this village, but to us they are priorities and as such colour our view of the strategy document. We make the following additional observations:- The various objectives as stated are welcomed and cover obvious needs Noted. We feel that translation of objectives into hard action needs Noted. to be better defined – we have made numerous detailed
Communication, Engagement and Consultation Strategy, September 2013 22 submissions to NCC and other relevant bodies and received no responses and have observed no distinctly identifiable actions. Our concern remains that whilst the aspirations of the paper Noted. and proposals are good, and endorsed by this Parish Council, our view remains that practical applications are often lacking. Emergency service responses at times of severe need have Noted. been swift and supportive. Follow up actions at NCC, Environment Agency and other bodies remain disappointing. Action Plan 8.1 objective 1, 4th box P90 – requires greater Noted. All flooding incidents will be and more effective prioritisation to ensure more successful investigated where they meet the threshold recording of events to enable appropriate follow up. for formal investigation. Objective 2 concentrates more on recognised high risk areas Noted. to the detriment of low risk areas – whilst it is acknowledged that high risk areas need a greater focus, this should not be at the expense of other examples which are less frequently highlighted. Improved regular maintenance of existing drainage systems Noted. [including dealing with sewage and effluent] remains a problem to us from time to time. This is potentially exacerbated by apparent disregard for our registered concerns over the capabilities of infrastructures to handle emergency situations when planning applications are being considered. We have taken up responsibilities with Riparian owners in Noted. This approach is fully supported. Syresham to remind them of their responsibilities under objective 7 Stanwick Parish As Stanwick is listed as number 14 on the priority list, the Noted. We are continually looking for flood Council Council would be interested to learn if there is anyway in which wardens or community flood forums, to help 10 the Council can assist NCC in flood related matters. provide valuable information before, during and after a flood. The wardens act as the eyes and ears in communities at risk of flooding.
Having a flood warden and/or a community flood forum in your community is yet another way of helping to protect your homes. They
Communication, Engagement and Consultation Strategy, September 2013 23 play a vital role in raising awareness of the dangers of flooding and help residents to stay safe within their communities.
If you plan what you would do in a flood, you are more likely to stay safe. NCC can help flood wardens and communities with the necessary training and guidance to ensure they are adequately prepared. The overall themes and objectives of the strategy are supported. Noted. The roles and responsibilities relating to flood risk management Noted. of all organisations, agencies and authorities are clear. Agree with the broad remit, membership and procedures of the Noted. local partnership and governance arrangements. Agree with the Prioritisation Assessment in terms of where work Noted. should be geographically prioritised across the county. Support Objective 1: Collaborative Approach. Noted. We support Objective 2: Local Flood Risk Noted. We agree with the protocol for flood investigations. Noted. We support Objective 3: Enhance the Natural Environment. Noted. We support Objective 4: Preparedness and Resilience. Noted. We support Objective 5: Flood Risk and Development. Noted. We support all of the Consenting Policies set out in Objective 5, Noted. Flood Risk and Development. We support Objective 6: Economically Sustainable Approach. Noted. We support Objective 7: Riparian Responsibilities. Noted. We support the content of the Action Plan. Noted. We agree with the proposals for the timescale of reviewing and Noted. updating the strategy. Thrapston Town The overall themes and objectives of the strategy are supported. Noted. Council The roles and responsibilities relating to flood risk management Noted. 11 of all organisations, agencies and authorities are clear.
Communication, Engagement and Consultation Strategy, September 2013 24 Agree with the Prioritisation Assessment in terms of where work Noted. should be geographically prioritised across the county. Support Objective 1: Collaborative Approach Noted. We support Objective 2: Local Flood Risk. Noted. We agree with the protocol for flood investigations Noted. We support Objective 3: Enhance the Natural Environment. Noted. We support Objective 4: Preparedness and Resilience Noted. We support Objective 5: Flood Risk and Development. Noted. We support all of the Consenting Policies set out in Objective 5, Noted. Flood Risk and Development. We support Objective 6: Economically Sustainable Approach. Noted. We support Objective 7: Riparian Responsibilities. Noted. We support the content of the Action Plan. Noted. We agree with the proposals for the timescale of reviewing and Noted. updating the strategy. Ashton Parish Ashton PC in South Northants notes that it is not identified as Noted. NCC’s prioritisation assessment Council one of the 14 wards (out of 144) that are ‘...most vulnerable to calculates the number of receptors (for 12 surface water flooding’. Ashton lies in a bowl, and is glanced on example homes, hospitals, main roads, 3 sides by higher ground. Flooding, albeit short lived from both sewage treatment works) that are at risk of surface water and sewerage (that we acknowledge is the remit flooding. A number of different flood risk of Anglian Water) is both regular and significant. scenarios are assessed to include each source of flood risk (surface water, The PC prepared a report in response to the granting of groundwater and river flooding) and a range Planning Permission by SNC for 9 wind turbines – the MI Wind of flood severities. The assessment is based Farm, their ref S/2011/1421/MAF – because the concrete pads on the calculated risk of flooding, rather that required as part of the infrastructure will massively increase the records of historic flooding, which are amount of surface water run-off that will ultimately arrive in the included in the hotspot historic hotspot data. village. The assessment is undertaken on a ward-by- ward basis, so that the wards with the Ashton PC considers that the parish is therefore at (increased) highest number of receptors at risk of risk of surface water flooding and would like to be included in the flooding can be prioritised. list of 14. Surface water flood risk (based on the Flood Map for Surface Water data) is
Communication, Engagement and Consultation Strategy, September 2013 25 Northamptonshire’s adopted ‘local flood risk information’. Based on this assessment, Salcey ward which includes the village of Ashton features in joint 74th place out of 144 wards within Northamptonshire for a 1 in 30 probability flood event from surface water, and joint 102nd place out of 144 for a 1 in 200 probability (more extreme) flood event. For both assessments, the ward is still considered ‘high’ priority, on a scale of ‘very high’ to ‘low’. Comparatively, for fluvial flood risk (flooding from rivers) Ashton features in joint 88th position for a 1 in 100 probability flood event and joint 100th place for a 1 in 1000 probability flood event. Ashton village has a history of flooding problems documented Noted. In this situation we would recommend back to the 1800’s. The main concern in our village is the that a flood warden be elected or community regular flooding of two streams which pass through the village flood forum created, to help provide valuable and when flooding occurs causing motor problems for both information before, during and after a flood. residents and motorists. The two streams are: The wardens act as the eyes and ears in Stoke Road stream - this flows from north to south from communities at risk of flooding. The the direction of Roade village. Major Flooding problems wardens’ eye witness reports are invaluable occur where this stream crosses Stoke Road in the to support information on river levels and village. drainage issues. They can also help ensure Hartwell Road stream - This flows from east to west from that local residents have received flood the direction of Hartwell village - Major Flooding problems warnings and take any necessary action. occur where this stream crosses Hartwell Road in the village. Since the flooding experienced in November and December 2012 and January and Additional flooding also from this stream, occurs in “little Ashton”, February 2013, residents have been to the east side of the village. A recent example of flooding volunteering as flood wardens for their occurred during the afternoon and evening of 21 November community. We recognise the important role 2012. The Stoke Road stream became flooded, causing the played by these individuals, and want to drains to deposit raw sewerage along Stoke Road. This problem support their efforts to expand their network was further enhanced with some vehicles driving through the by recruiting more flood wardens. deep water at speed, so depositing both raw sewerage and toilet paper up the walls of nearby houses. This problem is NOT an Having a flood warden and/or a community isolated incident and has been reported before. I met Anglia flood forum in your community is yet another Water engineers at the location, who informed me that they had way of helping to protect your homes. They
Communication, Engagement and Consultation Strategy, September 2013 26 just come from a nearby, flooded sewerage treatment works. play a vital role in raising awareness of the The Hartwell Road Stream also became flooded, causing dangers of flooding, including highway problems to traffic on the Hartwell Road. Within a very short dangers and help residents to stay safe time, the water had risen to car headlight level. This caused within their communities. many vehicles to malfunction and so had to be abandoned. It was over 24 hours before all the vehicles were finally removed The additional information that a warden can with car transporters. During this period, water from theses provide, might mean extra precious minutes streams came to within inches of a number of homes built along for residents to save themselves and their the streams. property. Historical documents suggest that flooding of this nature occurred approximately two to three times each year with a There are areas in Northamptonshire that major flood every few years or so. are at particular risk of flash flooding because of the local landscape and proximity of watercourses, so we are urging residents find out how they can prepare for flooding. If you plan what you would do in a flood, you are more likely to stay safe. NCC can help flood wardens and communities with the necessary training and guidance to ensure they are prepared. Such as producing community flood plans, ensuring that the community understands their risk and what can be done to minimise them. We are finding in recent years that minor flooding is increasing Noted. This would NOT be classed as a and we seem to be expecting two to three, or more, major floods major event. In Northamptonshire a major (as described above) each year. 1998 and 2007 were also event has been described as flooding examples of serious, major flood problems. In one situation the internally affecting 20 dwellings or more, or 8 whole village was cut off for over 24 hours and many villagers businesses, or one or more critical services were left stranded, unable to get home in the evening. I have or a major transport link. This incident would described the most recent flooding example on the 21 November be classed as a ‘less significant’ flood event. 2012. We also had similar flood conditions just 17 days earlier on the 4 November 2012, which were reported to the authorities and our village Parish Council. It does seem that the occurrences of serious flooding in Ashton are becoming more regular. This extreme flooding is becoming quite common in our village NCC as Lead Local Flood Authority does not and our concerns are that the proposed development, despite comment on planning related matters, this developer’s reassurances, will cause additional major flood responsibility remains with the District issues beyond those we experience already. Authority and the Environment Agency.
Communication, Engagement and Consultation Strategy, September 2013 27 Corby Borough Corby has secured funding for the preparation of Flood Risk Noted. This work is being supported by NCC. Council Management Study. Consultants are due to be appointed to 13 carry out this work which will be completed before the end of 2013. Objective 5: Flood Risk and Development is consistent with the Noted. NCC has been supporting the work of emerging North Northamptonshire Joint Core Strategy Review the NNJPU in relation to flood and water and therefore this objective and the actions that will contribute to matters. its achievement are supported. Action plan to be updated to acknowledge work being Noted. Agree that the LFRMS should be Action Plan to be updated to undertaken by Corby Borough Council in partnership with the updated. acknowledge: County Council and Environment Agency in relation to the Flood - The work being undertaken by Risk Management Study that consultants have recently been Corby Borough Council in appointed to carry out; and also the detailed studies and surveys partnership with NCC and the EA that Atkins have been appointed to carry out in preparation for in relation to the Flood Risk applying for funding for the Corby Culvert (p100). Management Study. - The detailed studies and surveys that Atkins have been appointed to carry out in preparation for applying for funding for the Corby Culvert. Highways The HA supports the draft strategy and agrees with the aims set Noted. Agency out. 14 The HA will continue to be a part of the Northamptonshire Flood Noted. and Water Management Operational Group to assist NCC fulfil its statutory roles and implement the strategy over flood risk. We will continue to help identify and mitigate flood risk on our Noted. network and work with you to improve contingencies for when flooding occurs. The safe operation of the Strategic Road Network (SRN) is our Noted. concern and we are pleased to note that this, and the partnership between NCC and ourselves, is reflected in the draft strategy. The HA will work with NCC and the other partners as described Noted. in the draft strategy to alleviate future flood risk as it effects the SRN. Borough Council The overall themes and objectives of the strategy are supported. Noted. of Welling- The roles and responsibilities relating to flood risk management Noted.
Communication, Engagement and Consultation Strategy, September 2013 28 borough of all organisations, agencies and authorities are clear. 15 Agree with the broad remit, membership and procedures of the Noted. local partnership and governance arrangements. It seems logical to priorities on a geographic basis given the Noted. flood risk areas. We support Objective 1: Collaborative Approach. Noted. We support Objective 2: Local Flood Risk. Noted. We agree with the protocol for flood investigations. Noted. We support Objective 3: Enhance the Natural Environment. Noted. We support Objective 4: Preparedness and Resilience. Noted. We support Objective 5: Flood Risk and Development. Noted. We support all of the Consenting Policies set out in Objective 5, Noted. Flood Risk and Development. We support Objective 6: Economically Sustainable Approach. Noted. We support Objective 7: Riparian Responsibilities. Noted. We support the content of the Action Plan. Noted. Agree to reviewing and updating every 3 years, but with triggers Noted. as mentioned to update more regularly if required. Consider some mechanism introduced to make the riparian Noted. NCC have been promoting owners more responsible and more proactive for the awareness in relation to Riparian roles and maintenance of watercourses adjacent to their land especially in responsibilities through the Flood Fairs, the event of flooding incidences. updating the Flood and Water Website: http://www.northamptonshire.gov.uk/en/coun cilservices/environ/flood/pages/default.aspx, producing leaflets and guidance material in relation to this subject, writing to Riparian Owners where flooding issues have been highlighted due to lack of maintenance, publishing articles the National Farmers Union magazine, and setting out the roles and responsibilities through the LFRMS, but in particular Objective 7.
Communication, Engagement and Consultation Strategy, September 2013 29 NCC would be pleased to explore other mechanisms with the BCW in relation to raising the profile of Riparian Responsibilities. English Heritage We are concerned that none of the strategy objectives, listed on Noted. Objective 3. Is all encompassing and Add the word historic to Objective 3. 16 page 2, refer to the historic environment. We recommend that an refers to the wider environmental benefits. Enhance the Natural and Historic additional objective is added to the list of objectives: ‘Protect and This would also include the historic Environment section from Para 7.3.1 enhance the historic environment’. This would need to be environment. to 7.3.42. developed in section 7 of the document. While 7.4.5 of Objective 4 and 7.5.55 (Design and evaluation) of Noted. Objective 5 make reference to the historic environment, the historic environment needs to be referred to in the objectives listed on page 2 to raise its profile, as is the case with the natural environment. Enclosed is a document produced by English Heritage and the Noted. It would be helpful if English Heritage Environment Agency, ‘Catchment Flood Management Plans and were to produce a guidance document the Historic Environment’, 2007, which will provide guidance on specifically related to the Legislative how the strategy can address the historic environment. Since requirements of the LFRMS. this was produced, the assessment of impacts on heritage assets has been based on the impact on its significance. Schemes may also provide opportunities for the enhancement of Noted. Further clarification to be provided. Section 7.5.50 – 7.5.59 to include heritage assets. English Heritage should be consulted where reference to English Heritage any proposals for flood management affect designated heritage consultation requirements and will assets, particularly highly graded assets, including their setting. refer to the potential to enhance heritage assets. Paragraph 6.18, page 39, only lists Grade I and II* buildings, but Noted. Grade II listed buildings and the assessment should also consider other nationally designated conservation areas were deliberately heritage assets, i.e. Grade II listed buildings, scheduled excluded to prevent the weighting of priority monuments and other nationally important but undesignated towards more historic settlements. Grade II archaeological sites, registered parks and gardens and listed properties will still be included as registered battlefields. If the level of data considered is to be individual property receptors. Scheduled consistent with the natural assets listed, locally listed buildings Monuments, undesignated archaeological and structures, which might include historic bridges and sluices, sites, registered parks and gardens and should also be considered. Locally listed buildings are often battlefields were excluded for their very within conservation areas and may be identified in the nature. The impact of flooding on these Conservation Area Appraisal; conservation areas should also be historic assets were considered minimal, included in the assessment. All of this information will be on the most are monuments, underground or county Historic Environment Record. parkland/gardens, where the implications of flooding are considered minimal. However an
Communication, Engagement and Consultation Strategy, September 2013 30 action has been included within the LFRMS to assess the potential flood risk on designated historic assets. A proper assessment of the potential impacts of flooding on Noted. The methodology for prioritisation will heritage assets may require the amendment of the list of ‘highest be updated annually as and when more priority wards’ (Map 8 and page 48). information becomes available. Page 98 refers to a project to ‘Undertake an opportunistic study Noted. to identify floodplain storage opportunities along River Nene Corridor’ and there is also reference to flood storage at a number of other sites across the county. When looking at options, the impact on heritage assets and their setting should be considered. This would include the effects on archaeological sites and areas where there are good historic landscape survivals. Works to historic structures, such as locks and sluices should also be sensitively undertaken. Similarly, the proposed schemes in historic settlements need to ensure that their character is not negatively affected, especially works are proposed within conservation areas. We advise you to consult your county historic environment service when such schemes are being developed. We note that potential impacts on heritage assets have been Noted. identified for some of these schemes in the SEA, e.g. West End, Silverstone, page 71 and King’s Sutton, page 72. As indicated above, there will be occasions when English Heritage should also be consulted. Paragraph 4.5 of the SEA states that the Strategy sub-objectives Noted. Main Objective and subsequent text Cultural Heritage included within adequately cover Cultural Heritage and Landscape, but, based to include additional reference to Cultural Objective 3 and section 7 of the on our comments above, this does not appear to be the case. It Heritage and landscape. LFRMS also appears that some of the recommendations regarding heritage are not accepted by NCC, e.g. pages 28 and 29. While this might be justified in these particular instances, it reinforces the need for the historic environment to be given greater consideration in the document as suggested above. Box 4.1 Proposed Project Checklist – We welcome the proposed Noted. Include historic landscape character Box 4.1 updated to include historic items for cultural heritage and landscape; the latter should as identified in the HLC, part of the landscape character. include historic landscape character as identified in the HLC, Northamptonshire ECA, and, in line with the part of the Northamptonshire ECA, and, in line with the European Landscape Convention, European Landscape Convention, townscape character, e.g. as townscape character, e.g. as identified in identified in Conservation Area Appraisals. Conservation Area Appraisals.
Communication, Engagement and Consultation Strategy, September 2013 31 Table 5.1 LFRMS Monitoring Framework, Cultural Heritage – we Noted. Change reference to ‘heritage Heritage assets referred to in Table suggest that it refers to ‘heritage assets’ (in line with the NPPF) assets’. 5.1 and the third column should refer to English Heritage; we maintain the National Heritage List for England and the National Heritage at Risk register. It is possible that more heritage assets may become at risk as a result of climate change. Could there also be a more positive indicator which identifies the Noted. This will be undertaken as part of See Section 7.3.17 and the action number of designated heritage assets that are no longer at high action within Action Plan to assess impacts within the Action Plan to assess risk of flooding as a result of action taken? of flooding on heritage assets. impacts of flooding on heritage assets. EDT Scrutiny Funding for flood defences on the rivers in Northamptonshire Noted. If funding is received for defences on Committee should be directed towards measures to manage the overall the rivers in Northamptonshire, all options 17 water flow rate, rather than used for defences at individual and implications will be considered on a locations that cause problems to be moved downstream into case-by-case basis different areas The Local Flood Risk Management Strategy should clearly set Noted. The LFRMS already sets out the The prioritisation methodology set out out the prioritisation process used to identify the wards to be prioritisation process used to identify the in Section 6 of the LFRMS, will be given the highest priority for actions to assess and address flood wards to be given the highest priority for clarified. risk. actions to assess and address flood risk. The final draft Local Flood Risk Management Strategy be Noted. It has been agreed that the final draft reported to a future meeting of the Committee for further scrutiny LFRMS be reported to a future meeting of before it is presented to the Cabinet for agreement the Committee for further scrutiny before it is presented to Cabinet for agreement. The Committee be informed of future updates to the Local Flood Noted. The Committee will be informed of Risk Management Strategy on an ongoing basis future updates to the LFRMS as and when they occur. The Committee recommends that appropriate training be Noted. Appropriate training will be delivered delivered to elected members at the local planning authorities in to elected members at the local planning the county about the Lead Local Flood Authority's authorities and within the county council, responsibilities and powers relating to the planning process regarding the LLFA's responsibilities and powers relating to the planning process The Committee acknowledges the programme of implementation Noted. relating to the Flood & Water Management Act 2010. Kettering What is the nature of ground water flooding (6.9)? This might Noted. Provide clarification on source and Para 6.10 add ‘This data has used the Environment have two connotations: a) ground water saturation of normally nature of groundwater data. top two susceptibility bands of the Forum; Member permeable soils and rock, resulting in low or no infiltration. British Geological Society (BGS) of British Given the amount of Pleistocene glacial and peri-glacial 1:50,000 Groundwater Flood Hydrological materials on the surface of much of the permeable and porous Susceptibility Map and covers
Communication, Engagement and Consultation Strategy, September 2013 32 Society soils as rocks this is likely to be highly variable and not easily consolidated aquifers (chalk, 18 linked with soil type or soil group. Where areas have been sandstone etc) and superficial worked for ironstone or other minerals – rocks and restored the deposits. It does not take account of problem could be better locally or worse. B) Localised flooding the chance of flooding from into the basements and foundations of buildings either by groundwater rebound. It shows the infiltration through the cellar or basement walls or floor. Might proportion of each 1km grid square give a surprise on a Monday morning or after hearing storms where geological and hydro perhaps some days later! It could come up through the floor! geological conditions show that groundwater might emerge. With surface water and ground water, clay soils might give some Noted. indication of where the liability is; but in terms of risks described in Section 6 these compared with stream and river flow are low. That is not to write that the type of flooding is insignificant particularly to any building development. Soil water and ground water infiltration capacity and movement are important especially in rural development areas where full drainage capacity for rain and surface water is not laid. The risks are low but where stream flood risk exists needs to be considered. Map 3, if it is to inform future development planning as well as Noted. This map is not intended to inform “emergency planning response” is very urban and to existing development planning. It identifies all of the urban areas. NCC might be encouraged to look back before locations where flooding has previously 1947 using newspaper records and even parish documents to occurred and has been recorded and see where such floods have affected in the past. Research from reported to NCC. The information could local newspaper archives certainly from c1800. The Avon – however be used to inform site specific Flood Welland – Nene watershed and upper reaches might be Risk Assessments. This information has instructive as a substantially clay catchments. been collected from a number of different sources and we continue to expand our knowledge as and when flooding is reported. Whilst climate change could be significant over medium – long Noted. Additional clarification and Add the following to Section 2 of the term historically it is less significant than freak statistically nearer explanation will be provided in relation to the LFRMS: the extremes of the statistic – weather events. Much of the 18th probability of flooding. The probability or likelihood of and 19th misery illustrated by painters and engravers resulted flooding is described as the chance from weather events although some were associated with a that a location will flood in any one series of cold winters in the early 19th and wet summers in the year. 1840-1850 period. The research and background work which If a location has a 1.3% chance of has gone into these maps does need complimenting. Perhaps flooding each year, this can also be for the lay person quite what 1:200 years scenario means should expressed as having: be made clear. My friend at the Institute of Hydrology always a 1 in 75 chance of flooding in “complained” that the notion of “return frequency” was not that location in any year
Communication, Engagement and Consultation Strategy, September 2013 33 particularly helpful although it perhaps is the best we have! It is odds of 74 to 1 against a location safer to be prepared for a random pattern of events. Certainly being flooded in any year do not give the impression that because Northampton flooded in However, this doesn't mean that if a 1998 it would necessarily be 2028 before that magnitude event location floods one year, it will happened again! definitely not flood for the next 74 years. Nor, if it has not flooded for 74 years, will it necessarily flood this year. When we describe the chance of flooding, we give it one of three descriptions or put it into one of three categories: Significant: the chance of flooding in any year is greater than 1.3% (1 in 75) Moderate: the chance of flooding in any year is 1.3% (1 in 75) or less, but greater than 0.5% (1 in 200) Low: the chance of flooding in any year is 0.5% (1 in 200) or less The lower the percentage then the less chance there is of flooding in any one year; the higher the percentage then the more chance there is of flooding in any one year. As section 7 highlights the more collaborative work is done and Noted. is shared between everyone responsible for any aspect of flood limitations as amelioration the better. As a former lecturer at Bedfordshire University I would suggest Noted. that a three year cycle of revision with the responsible people allows for retirement, promotion, reorganisation beloved of managers and new methodologies and information. This would allow all interested parties within the county and expertise from outside to be brought together for a day or so to learn about: - i) current thinking on flood hydrology and control – possibly some introductory sessions ii) Recent problems in Northamptonshire and adjacent counties – local authorities with flooding – perhaps to review the
Communication, Engagement and Consultation Strategy, September 2013 34 previous ten years, where what time of year, how or who ere affected. iii) Update briefly i) and ii) or listen to proposed solutions – or work in progress. There might even be an excuse at the right time of year for a boat trip on the River Nene! Section 7 overall contains a great deal of sense. It would Noted. possibly help if the Environment Agency took a more outward role with riparian land owners – even more with small streams and field drains so that where responsibility lies for flood risk attenuation and limitation is known and understood. This paragraph is written on Thursday 14th February following Noted. over night snow melt. Loddington Brook flowing into Thorpe Malsor Reservoir is flowing both through the cut-off channel created for improvement in the 1950’s by the landowner at about three quarters bank full and through the meander loop which can be seen on early ordnance survey 1/2500 plans and 1:0,000 maps as its then course, but is not overflowing. Not having a current meter I cannot safely calculate the cumecs. One thing that is certain that even on valley sites and certainly as valley floors you cannot avoid surface waters. Floods represent their depths and over bank flows represent the biggest risk to people and property. The old river management by lock keepers and weir operators has a lot of virtues in terms of providing early warnings and setting the flood risk reductions in process. Clipston Parish First of all I would like to congratulate you on this initiative and Noted. Council the high quality of the documentation that I have read. In turn, I 19 have reported this back to the Parish Council. We are very supportive of this initiative and we know how devastating flooding can be to communities. Clipston has not been exempt from this problem over the years Noted. This site specific matter will be raised although the dam that has been put into the River Ise near to the with our flood risk management partners as a road running to Kelmarsh has alleviated the issue for our Parish point of concern. to a large extent. However, with the knowledge of the likely increases in rainfall over shorter, more condensed, periods of time which, in turn, will potentially lead to greater flooding Clipston Parish Council would like to point out that it believes that the dam in the River Ise has, in its view, a good potential to be breached or overcome, which would lead to serious flooding in our parish. We would, therefore, request that this particular
Communication, Engagement and Consultation Strategy, September 2013 35 point is given adequate attention please in any control of local flood planning. In the meantime I wish you every success with this initiative. Noted. Kettering Over the past week or so the weather conditions have made me Noted. Agree to add additional information Para. 2.11 and 2.12 to include: Environment aware there is a type of ‘flooding’ which may well be out with the on agricultural runoff plus include the “Runoff” is rainfall that does not soak Forum; Member normal classifications. That is run-off from agricultural land incidents with the historic hotspot data into the land or enter a drain or river, of British which may concentrate at points created by the topography and but flows over it instead. Runoff does Hydrological when deep enough flows across a road into a channel or along not necessarily cause a problem if it Society that road. Whilst in itself not particularly hazardous, especially if flows into drains or watercourses, 20 marked by a triangular temporary road hazard FLOOD sign, if it or on to land where it can soak away freezes, as two examples locally have then there becomes a without causing problems. However in problem which can be then closely related to the LFRMS. some cases runoff flows into the road Two examples include: (which can then freeze and create a - On Sunday 17th February run-off on the lane between the danger to road users), people’s Loddington Orton Road and the Rothwell – Loddington Road homes or land, where it can cause froze on the road surface which caught a cyclist out – damage and disruption. Runoff may causing him to fall off! He seemingly was not injured, just also pass into small ditches or shaken. channels that run through or adjacent - Yesterday 19th February run-off into the Kettering – Pytchley to property, and if not maintained Road from fields as traffic entered the village had frozen, these can become blocked. This type possibly the road has been treated with salt as there was a of flooding can also originate from considerable amount of slush and this has refrozen. I write farmland. This is a particular risk from experience as there was a minor “bump” to my car by a where soil has been compacted or motorist, caught out since all other roads seemed to have vegetation removed either seasonally been “dry” whose car slid on the lubricated surface as more by ploughing, or temporarily as water flowed over the slush. topsoil is stripped to allow for development, so that rainwater is no longer able to soak into the ground. Instead the rainwater flows over the land, carrying soil with it to create a “muddy flood”. The farmland itself can be damaged because the floodwater can carry away topsoil and even crops. This raises the point about where a flood hazard, possibility in Noted. The responsibility remains with the itself to shallow to be classified as a flood occurs by run-off from landowner, however NCC is collecting data fields what should the response be? This year is particular with on low points on the highway and “wet periods” and snow melt has given rise to this type of minor landowners contacted where considered flooding on many roads, classified AUB and local roads. The necessary in terms of highway safety
Communication, Engagement and Consultation Strategy, September 2013 36 water may become concentrated by the topography and become implications. This type of flooding is highway almost a channel flow or more usually sheet flow across the road related, and therefore should be reported via surface. If the latter it may freeze with ground temperatures the Street Doctor service. around -20C. What I am suggesting is that consideration be given to locality there “risk points and determining how best there also can be alleviated. Northampton No comment to make apart from supporting the contents of the Noted. Borough Council document which we have had the opportunity to input into in the 21 drafting stage. Harpole Parish The overall themes and objectives of the strategy are supported. Noted. Council The roles and responsibilities relating to flood risk management Noted. 22 of all organisations, agencies and authorities are clear. We agree with the broad remit, membership and procedures of Noted. the local partnership and governance arrangements. We agree with the Prioritisation Assessment in terms of where Noted. work should be geographically prioritised across the county. We support Objective 1: Collaborative Approach. Noted. This section (Objective 2: Local Flood Risk) mentions about Noted. The overall budget for highways is people logging calls with Street Doctor concerning blocked reducing to make efficiencies; however this drains/ditches etc, but as the council funding has been cut in this will not affect front-line services or the area, even if calls are logged will the council have resource to highway drainage budget. carry out work in this area, or is it just paying lip service so people think something is going to happen. The protocol for flood investigations mentions in this section NCC cannot prevent the development on the about ‘Encourage natural flood risk management’, would this flood plain and does not provide comment on mean that you would stop building on flood plains? With all the planning applications, this responsibility recent flooding that has taken place the council are still remains with the EA. The Local Planning approving construction on flood plain land such as that at Authorities (LPAs) have a responsibility to Pineham, even local housing in Harpole has suffered badly from ensure that development is consistent with flooding, are proper assessments going to be carried out before the National Planning Policy Framework building as to the capability of drainage, run off water etc. sections 104-108 and the additional Technical Guidance dealing with flood risk. This section (Objective 3: Enhance the Natural Environment) Matters relating to hedgerow and tree covers such issues as encouraging Farmers to plough the land a removal remain with the LPAs. They have certain way and encouraging woodlands, is there now a mind set the power to protect hedges in the in the council to stop farmers taking up hedges & trees to countryside that are of importance either increase field size to aid the ease of cultivation? ecologically or historically. The Hedgerow
Communication, Engagement and Consultation Strategy, September 2013 37 Regulations, introduced in 1997, require that anyone who wishes to remove a hedge in the countryside must notify the LPA by submitting a Hedgerow Removal Notice.
On receipt of the application, the Council must consider whether or not the hedgerow is 'important'. This assessment is based on a set of criteria contained within the Regulations that cover the age, archaeological, historical, wildlife and landscape value of the hedge. There are a few exemptions from the need to notify, the main one being that the hedgerow is within the curtilage, or forms the boundary, of a dwelling. Hedgerows that are shorter than 20 metres may not need consent to be removed. We support Objective 4: Preparedness and Resilience as long Noted. as funds are put in place to do this. We support Objective 5: Flood Risk and Development. Noted. We support all of the Consenting Policies set out in Objective 5, Noted. Flood Risk and Development. We support Objective 6: Economically Sustainable Approach. Noted. We support Objective 7: Riparian Responsibilities, are the Noted. Yes, when a flooding incident has council going to survey areas that have suffered multiple occurred, which meets the threshold for flooding events to see if land owners have not kept the water investigation, a formal investigation will be courses clear? carried out. This will determine which authorities and individuals have relevant flood risk management functions; and whether each of those authorities or individuals has exercised, or is proposing to exercise, those functions in response to the flood. We support the content of the Action Plan. Noted. We agree with the proposals for the timescale of reviewing and Noted. updating the strategy.
Communication, Engagement and Consultation Strategy, September 2013 38 West Northants The LFRMS is welcomed as an important means of managing Noted. Joint Planning the implementation of a consistent and timely approach to the Unit management of local flood risk from surface water, groundwater 23 and ordinary watercourses across West Northamptonshire and the rest of the county. The new approach to the implementation of sustainable Noted. drainage schemes is particularity welcomed, because each of the Sustainable Urban Extensions (SUEs) in the WNJCS require the provision of adequate flood risk management, including surface water management from all sources, for which sustainable drainage (SuDS) could be a whole or part of the overall design approach to each SUE. It is a requirement of the submitted West Northamptonshire Joint Noted. Core Strategy (JCS) to require all SUEs development proposals to be accompanied by a master plan and to ensure that necessary infrastructure, including for water, is required to be phased alongside the delivery of development. The master plan approach will also take place taking account of the specific water and flood risk policies in the JCS that seek to ensure that the proposed new development considers water treatment supply and water quality and does not increase flood risk within those developments or increase flood risk downstream. Each SUE will also include elements of structural green space Noted. and wildlife corridors which could be considered in terms of the overall drainage of the area and locations for the design of sustainable drainage systems to enhance the appearance, biodiversity and recreational potential of the SUEs. As part of the JCS evidence base the West Northamptonshire Noted. Water Cycle Study Final Report was published in September 2011. In terms of flood risk and water management the report complements the Strategy and provides advice on the type of SUDs that may be suitable based on geology, source protection zones and aquifer characteristics for each SUE. The submitted JCS includes a strengthened and integrated Noted. approach to water resources, water quality and flood risk management from all sources. In addition to fluvial flooding there is also an increased risk of surface water flooding following periods of heavy rainfall, more intense storms due to the potential effects of climate change which can also impact where
Communication, Engagement and Consultation Strategy, September 2013 39 wastewater drainage is ineffective. A specific new paragraph indicates the changes brought about by the Flood and Water Management Act. The overall themes and objectives of the strategy are supported, Noted. especially as regards the objective for Flood Risk and Development and Enhance the Natural Environment. The submitted West Northamptonshire Joint Core Strategy Noted. (JCS) includes objectives to ensure strategic new development allocations are located and designed so as to be resilient to future climate change and risk of flooding. Policy S10, Sustainable Development Principles, seeks to “promote Sustainable Drainage” and Policies BN7a and BN7 provides an integrated approach to water issues, flood risk and promote SuDS. Policy S10 sets out to “Protect, conserve and enhance the Noted. natural and built environment and heritage assets” and the whole of Section 10 of the JCS, the Built and Natural Environment, details Policies to positively influence new development and the natural environment. The roles and responsibilities relating to flood risk management Noted. of all organisations, agencies and authorities are clear. However, it should be acknowledged that the degree of complexity of the new responsibilities introduced at a time of cuts to public service is likely to result in challenges to the level of co-operation and priority given to this topic against other priorities. In particular, the introduction of the SAB Approval Body will call for greater levels of co-operation with the Borough and District Councils at a time when staff resources are likely to be under pressure affecting the capacity to input into the process. The Prioritisation Assessment is useful additional data to use Noted. with at local planning level. The focus of the LFRM activity should increase the understanding of the impacts and location of surface water flood risk which can be used in future Local Plan preparation. The collaborative approach depends on expertise and Noted. The SAB will be fully funded through prioritisation of the activity in a time when resources are the application fee process. The adoption stretched. Collaboration will not achieve the objectives of the and maintenance budget in relation to SuDS
Communication, Engagement and Consultation Strategy, September 2013 40 LFRMS without access to sufficient funding and expertise. is yet to be determined by Defra. This matter However, it is difficult to see how the expertise to service the will be fully addressed as part of the SAB SAB will be adequately funded in this time of pressure on public development and the production of the SuDS sector funding. guidance. We support Objective 2: Local Flood Risk. Noted. Objective 3: Enhance the Natural Environment is strongly Noted. supported and the WNJCS sets out policies to underpin development which takes account of the water environment and flood risk as a whole. It is difficult to envisage the step change necessary to improve the environment, including the water environment and the aspirations of the Natural Environment White Paper given the current resources situation.
It is important that the LFRM process is strongly linked to the Noted. Northamptonshire Local Nature Partnership. The submitted WNJCS supports through Policy Objective 5: Noted. Flood Risk and Development and promotes the use of SuD systems in all Sustainable Urban Extensions. The creation of the SAB process further complicates decision Noted. making at the local level on planning applications and needs long term funding for maintenance in place. The suggestion of the production of specific SPD is welcomed; Noted. however it may be more appropriate for the local planning authorities to agree to prepare a common SPD for use by the LLFA. The implications of the implementation of Policy 7 may be to Noted. Each consent when determined reduce the biodiversity and amenity of the ordinary watercourse requires the assessment of environmental and affect natural vegetation and trees. impacts, including biodiversity. Policy BN7 in the submitted WNJCS seeks to increase the Noted. design standard for the Upper Nene catchment including reference in 7.5.44. 7.5.40 – The JPU supports these principles some of which are Noted. incorporated into WNJCS policy. 7.5.42 - Policies BN7a and BN7 of the submitted WNJCS apply Noted. however the over reliance on the EA to ensure consistency and compliance may be inappropriate. 7.5.55 – This section needs greater emphasis on the role of Noted. Agree. Greater emphasis will be placed on
Communication, Engagement and Consultation Strategy, September 2013 41 JCS/ Local Plans policy as a statutory document. the role of JCS/ Local Plans policy as a statutory document at section 7.5.55. The JPU supports a co-ordinated approach to Objective 6: Noted. Economically Sustainable Approach. The actions, aims and costs related to WNJCS SUEs are Noted. indicative as the Policy refers to “flood risk management, including surface water management and from all other sources”. It will be for a later processes when assessment has been undertaken to determine the actual proposals. We agree with the proposals for the timescale of reviewing and Noted. updating the strategy. Woodford cum We support the overall themes of the objectives of the strategy. Noted. Membris Parish Council The roles and responsibilities relating to flood risk management Noted. 24 of all organisations, agencies and authorities are made clear. What is not made clear is who what or which organisation is the Noted. Further clarification should be The following text will be provided in first point of contact. If this is the Lead local Flood Authority provided. the LFRMS: which in this case would be the local Council is there a If the flooding is an emergency department or person there to contact. Contact Fire and Rescue by calling 999. This service is primarily responsible for saving life. They may also pump out floodwater from your property. During flooding, you should focus on the safety of yourself and others. If the flooding is highway related Use the Street Doctor service to report flooding relating to a highway such as blocked ditches, blocked drains or flooding on a road. If the flooding is from a burst water main or sewer flooding Contact your service provider Anglian Water Services Thames Water Utilities Severn Trent Water
Communication, Engagement and Consultation Strategy, September 2013 42 For all other flooding Use our online report form to report all other flooding. Please note that this service is not to be used in an emergency situation. We will endeavour to respond to your submission within 21 days.
Our online report form can also be used to tell us about historic flooding that has affected your property or community. We agree with the broad remit of the local partnership and Noted. Task groups are only initiated when a governance arrangements but suggest that Local Flood Risk specific skills set or local knowledge is Operational Groups and Project Management Task Groups are required. These groups do not include the one and the same, based at local level with people with local local community, but we are able to work knowledge for example Parish Councils. closely with communities. Regarding the Prioritisation Assessment, the first priority should Noted. Agree. This demonstrates the be risk to life. If only one property floods yet that property houses importance of local flood wardens and or an old or infirm person, that is more important than many acres community flood forums, which are essential of industrial or farm land whatever the economic cost. to help provide valuable information before, during and after a flood. The wardens act as the eyes and ears in communities at risk of flooding. The wardens’ eye witness reports are invaluable to support information on river levels and drainage issues. They can also help ensure that local residents have received flood warnings and residents with a higher level of vulnerability are supported within the community.
We recognise the important role played by these individuals, and want to support their efforts to expand their network by recruiting more flood wardens.
Having a flood warden and/or a community flood forum in your community is yet another way of helping to protect your homes. They
Communication, Engagement and Consultation Strategy, September 2013 43 play a vital role in raising awareness of the dangers of flooding and help residents to stay safe within their communities.
The additional information that a warden can provide, might mean extra precious minutes for residents to save themselves and their property.
There are areas in Northamptonshire that are at particular risk of flash flooding because of the local landscape and proximity of watercourses, so we are urging residents find out how they can prepare for flooding. If you plan what you would do in a flood, you are more likely to stay safe. NCC can help flood wardens and communities with the necessary training and guidance to ensure they are prepared. Objective 1: Collaborative Approach is all very good in principle Noted. but if the environment agency ignores local opinion as they tend to do, then there is no point in any other proposals. We support Objective 2: Local Flood Risk, but why so much Noted. The studies and strategies do not just money is wasted developing plans and strategies when one man assess the problems, but also a significant with local knowledge and the authority to instigate required element of computer modelling is undertaken changes is all that is needed. Allocating £100,000 for a to enable solutions to be assessed, which management study seems wasteful. adds a significant cost to a project. The funding for such projects and studies would be gained from a number of different sources through the partnership working approach. We agree with the protocol for flood investigations but with Noted. This type of request can be put greater emphasis on basic drain and gully maintenance. forward via the Street Doctor service. Necessary flood prevention work can enhance the natural Noted. environment if done with thought and imagination as with all construction and maintenance. This whole section (Objective 4: Preparedness and Resilience) Noted. can be summed up by again proper maintenance and common sense.
Communication, Engagement and Consultation Strategy, September 2013 44 In Objective 5: Flood Risk and Development: Perhaps Noted. The flood alleviation requirements for encouraging the fitting of large rain water storage tanks in all such developments are set by the National new housing constructions. In the 1930/40 this was standard Planning Policy Framework and are enforced policy in many areas and should be considered again, along with by Local Planning Authority, with the encouraging retro fitting of such tanks. Landowners should also statutory consultee response being provided be encouraged to dig large ponds and lakes to drain the land, by the EA, where development thresholds water livestock and attract wild life. are met. There should be one authority in each area (dealing with Noted. It is understood that this could be consenting) otherwise it is all too complicated and too much as considered a complicated process, however usual is lost in bureaucracy. this requirement is set out within Legislation. NCC is however working closely with the Environment Agency and the Internal Drainage Board to ensure a consistent and joint up approach to consenting. Where a new development affects the water displacement of the Noted. Once the Sustainable drainage area the full cost of flood prevention as a consequence should systems (SuDS) Approval Body has been be carried by the developer. There should also be some sort of established through legislation, the approval, guarantee as the effect of the development may not be adoption and maintenance of SuDS will sit determined for some years. with NCC. Could there be incentives of some sort to good management of Noted. Landowners in receipt of Common water courses on private land rather than just punitive measures. Agricultural Policy (CAP) payments already A lot of flooding is caused by rainwater running off swamped and receive funding which should be used to water saturated farm land, where the ground has been carry out Soil Protection Reviews and compacted by years of use. identify any problems with soil erosion and runoff and help identify solutions to the problem. If it appears that a farmer is not managing their land in a way that minimises run-off and soil erosion, you can raise this matter with the Rural Payments Agency which is in charge of enforcing CAP cross- compliance. Should not the land holder be held responsible if his land is not Noted. Yes landowners can be held properly draining? Draining ditches should be maintained and responsible. If flooding is being caused by enlarged if not adequate and there are many methods available blocked drainage channels or inadequately to aid water absorption. As with new developments land owners drained land, the Agricultural Land Tribunal should be held responsible for damage caused by water runoff may be able to help. In spite of its name, this where steps could have been taken to prevent it. More time tribunal can deal with drainage on all types of should be spent on the work required and less time thinking up land, not just agricultural land. The tribunal strategies righting reports, development studies, initiative studies has powers (under the Land Drainage Act
Communication, Engagement and Consultation Strategy, September 2013 45 risk assessments and the like. Flood prevention is flood 1991) to order a landowner to carry out work prevention let’s just get on with it. to maintain or reinstate drainage ditches. The tribunal can also give you authorisation to carry out works on a neighbour’s land in order to protect your own property. It is currently free to make an application to the Agricultural Land Tribunal. However you will need to cover the costs of providing maps and other information, and may also wish to hire legal representation. For more information see the Defra website. Natural England Strategic Environmental Assessment (SEA) Noted. 25 Natural England agrees with the objectives, baseline and scope of the SEA. We agree that the methodology used to determine impacts and mitigation is acceptable and we have no objection to the preferred option (the draft Local Flood Risk Management Strategy). The significant sustainability effects of implementing this strategy Noted. must be monitored in order to identify unforeseen adverse effects. The potential indicators for monitoring the natural environment are clear and appropriate (SEA Environmental Report Part 3, table 5.1 p36). However it is not clear what the programme of monitoring would Noted. Agree programme of monitoring Proposed addition to SEA to include be. The plan does not include any procedures for addressing within the SEA needs to be made clearer. any procedures for addressing adverse effects revealed by monitoring or for remedying at an adverse effects revealed by early stage, unforeseen adverse effects caused by the plan. This monitoring or for remedying at an is a requirement of the SEA Regulations and therefore we would early stage any unforeseen adverse recommend that Northamptonshire County Council provide this effects caused by the plan. information. Habitats Regulations Assessment (HRA) Updated Screening Noted. Report Natural England agrees with the conclusions of the report, i.e. that a likely significant effect of the Local Flood Risk Management Strategy (LFRMS) on Upper Nene Valley Gravel Pits SPA/Ramsar site cannot be ruled out at this stage. However, we appreciate that due to the high level nature of the LFRMS, it is not possible to determine the significance of impacts at this stage before scheme designs, mitigation measures etc are known.
Communication, Engagement and Consultation Strategy, September 2013 46 We advise that any scheme arising out of the strategy which has Noted. Agree. Wording amended to ensure that all been identified in Table 10 (p25) of the HRA as having a likely schemes arising out of the strategy significant effect should be subject to a project-level HRA in (identified in Table 10, Page 25 of the order to fully evaluate any impacts on the designated site and to HRA) likely to have a significant ensure appropriate measures are in place to avoid any adverse effect, should be subject to a project- effects on integrity. level HRA in order to fully evaluate any impacts on the designated site and to ensure appropriate measures are in place to avoid any adverse effects on integrity. We agree with the screening out of other European sites both Noted. within Northamptonshire and close to county boundaries as not being likely to be significantly affected by the LFRMS. Wildlife Trust In the Prioritisation Assessment, the Environmental impact score Noted. 26 is currently calculated based on an assumption that flooding of any natural asset is negative. This is not necessarily the case and often natural assets have evolved to adapt to flooding at certain times of year. Other sites are more sensitive to flooding, especially at certain times of year. The natural functioning of the floodplain should be encouraged. I am pleased to see that further investigation into the risk to natural assets is identified in the action plan. The prioritisation of wards is likely to direct physical works to Noted. NCC support the concept of working those defined geographical areas. Natural flood attenuation at a catchment-based scale and continue to measures are better considered at a much larger scale, and do so with flood risk management partners, therefore are likely to be avoided in preference of simpler site- however in terms of holding administrative specific measures. A catchment wide or sub-catchment powers, these relate to the county boundary approach to natural flood attenuation would be beneficial to only. overall flood-risk reduction, climate change resilience and environmental improvement. I have some concern over the actions proposed, particularly in Noted. All consenting works require the the Preparedness and Resilience section, which refer to consideration of environmental implications. improvement of water courses to maximise their drainage Also when Riparian Owners are made aware capacity. This has significant potential to cause environmental of their responsibilities, specific reference is damage by over-deepening, straightening and removing made to ensuring that any works undertaken vegetation from the channel. These measures would not only be have a minimal adverse impact on the detrimental to wildlife but would impact on the WFD ecological environment, for example by avoiding any status in a negative way. disturbance to the soil of the bed and banks of the watercourse, and considering the
Communication, Engagement and Consultation Strategy, September 2013 47 adverse impacts of the works on any protected species. We recommended to avoid undertaking any intrusive works before late September when vegetation naturally begins to die back and the wildlife should not be nesting / breeding. It is also recommended that any waste produced from the maintenance of a watercourse be left on top of the bank for a few days to allow any organisms within the waste to migrate back into the watercourse, after which the waste should be removed. More consideration needs to be taken to attenuation measures Noted. outside of the channel, and storage of water in the floodplain in appropriate locations. There also seems to be a strong focus on increasing the Noted. It is not the intention of the strategy to provision of flood storage reservoirs, which limits the potential to provide one large flood storage reservoir. deliver environmental benefits. The investigation of multiple The intention is to explore options with smaller measures to slow and store water that could be partners. The assessment of options will implemented upstream of the area affected by flooding would include environmental assessment. give greater environmental, water quality and landscape character benefits than a single flood storage reservoir. This approach is likely to be more complex because of the need to involve multiple private landowners, but ought not to be ignored because of this. Targeted provision of agri-environment schemes, supplemented Noted. by a monitoring programme and funding of up-front capital works by developers/NCC is a way that this could be delivered simply. I would like to see an action that requires NCC to investigate in Noted. The numerous studies and strategies more detail the potential for natural flood management activities already set out in the action plan will include to contribute to managing flood risk in Northamptonshire, and this assessment. ideally trial the approach. When the action for objective 7 is implemented care will be Noted. When Riparian Owners are made Para 7.7.5. Add: Any flood risk needed to ensure that riparian owners are also aware of the aware of their responsibilities, specific management work undertaken should potential environmental impacts of channel/bank maintenance reference is made to ensuring that any works have a minimal adverse impact on the such as disturbance to breeding birds and removal of water vole undertaken have a minimal adverse impact environment, for example by avoiding habitat. on the environment, for example by avoiding any disturbance to the soil of the bed any disturbance to the soil of the bed and and banks of the watercourse, and banks of the watercourse, and considering considering the adverse impacts of
Communication, Engagement and Consultation Strategy, September 2013 48 the adverse impacts of the works on any the works on any protected species. protected species. We recommended to You are recommended to avoid avoid undertaking any intrusive works before undertaking any intrusive works late September when vegetation naturally before late September when begins to die back and the wildlife should not vegetation naturally begins to die be nesting / breeding. It is also back and the wildlife should not be recommended that any waste produced from nesting / breeding. It is also the maintenance of a watercourse be left on recommended that any waste top of the bank for a few days to allow any produced from the maintenance of a organisms within the waste to migrate back watercourse be left on top of the bank into the watercourse, after which the waste for a few days to allow any organisms should be removed. within the waste to migrate back into the watercourse, after which the waste should be removed. Map A 9 which presents the Habitat Opportunities actually Noted. Agree. Para 7.3.5. Add link to the Habitat shows existing BAP habitat as well as the habitat opportunities Opportunities Map: but the legend is not clear about this. The habitat opportunity http://northamptonshirebiodiversity.or map is difficult to interpret on its own, so it would be good to g/habitat-opportunity-map.htm where place a link on this map to the background information can be http://northamptonshirebiodiversity.org/habitat-opportunity- found. Add BAP reference to legend. map.htm where the background information can be found. I think that it is important to include within the communications Noted. The whole of appendix 9 will need to Produce a separate Communication, strategy a clear message about alternatives to hard flood be updated to reflect the outcome of the Engagement and Consultation defences to reduce the expectation for all flood risk areas to be three month consultation on the LFRMS. The Strategy document to cover this protected by hard defences. Communication Strategy is much more information. focused on engagement and education techniques. It does not include technical flood alleviation advice. Table 4.1 of the SEA re: biodiversity, flora and fauna – an Noted. Protected species and the habitats enhancement measure was suggested, but I think that this and species found in un-designated needs to go slightly further to include protected species and the sites to be added to Table 4.1 habitats and species found in un-designated sites. The role of a checklist for riparian owners could be considered – for an example see the biodiversity checklist in the North Northamptonshire Biodiversity SPD. This would come into play for operations that a riparian landowner is expected to undertake without previously seeking consent. Member of I have made comments relating to the lack of actual public Noted. NCC has undertaken robust public public involvement and in particular those organisations that have local, engagement in relation to this LFRMS and
Communication, Engagement and Consultation Strategy, September 2013 49 27 historic knowledge and expertise that represent the public. If the other flood and water related work. The issues raised about the failure to undertake proper discussions extent of the engagement is set out in this with these organisations particularly the Nene Flood Protection document. Alliance are not progressed very soon there is bound to be much wider concern generated and can not be in the best interest of residents. You state a collaborative approach with local partners and Noted. NCC has provided several stakeholders to secure and optimise resources, expertise etc, is opportunities to feed into this LFRMS in a essential but the NCC’s practice fails to achieve this. NCC also variety of ways and continues to promote the fail currently and during this consultation to engage with people submission of information and evidence with local knowledge and understanding of local flood risk. related to any historic flood events.
You must engage fully with the Nene Flood Prevention Alliance Noted. At each stage of public engagement, and other such bodies/stakeholders as failure to satisfy their all environmental groups were contacted genuine concerns could well result in another large flood of direct for their views and opinions and to properties and loss of life. provide any additional information or evidence they may hold. It is not logical to treat the county’s surface water and ordinary The LFRMS has reviewed all sources of water course issues in isolation to main river flooding, as one flooding. Whilst the responsibility for main impacts the other especially in Northampton Town and that is river remains with the Environment Agency, why a truly effective collaborative approach is needed. NCC work extremely close with in partnership with them. The roles and responsibilities relating to flood risk management Noted. of all organisations, agencies and authorities are acceptable. I do not agree with the broad remit, membership and procedures Noted. The Partnership arrangements were of the local partnership and governance arrangements – the proposed and agreed by Cabinet Members involvement of the public or organisations like the Nene Flood in October 2010. Prevention Alliance is essential to get to a true picture of the historic flood position and proper assessment of current risks. This is why NCC’s current failure to truly collaborate could produce a very real flood disaster for the town. Prioritisation Assessment reads well but is in reality totally Noted. Northampton does have one of the misleading, when statements are made that the ‘flood defences best flood protected town centres anywhere provide the town one of the highest design standards in the in the UK. The flood defences now in place country’. continue to offer protection to a one in 200 chance of flooding from the River Nene. What is needed is the concerns of the Nene Flood Prevention Noted. A 10-month independent review, Alliance and others to be addressed and either properly and commissioned by the Environment Agency independently found that they are covered within the current and involving local people in the affected
Communication, Engagement and Consultation Strategy, September 2013 50 flood prevention infrastructure or a plan created to eliminate the areas has been undertaken. increased risk identified. The actual flood levels documented in The Northampton Standards of Protection the 1998 flood need to be the used in any modelling and not the Review was carried out by international incorrect levels currently in use. design and engineering consultants, URS Scott Wilson, who examined the improved flood defences built by the Environment Agency since the floods of Easter 1998. Once again fine words (Objective 2: Local Flood Risk) but Noted. raising community awareness is one side of the story the other is engaging with, listening to and acting on what local people with local knowledge can impart. I agreed that people must know if there is a flood risk and how to protect their properties but NCC must engage with local knowledge so residents feel that the NCC are planning to mitigate the underlying cause of flooding that has already or could impact their property. I agree with the protocol for flood investigations except I failed to Noted. The outcome of the investigation Para 7.2.14: Add - upon learning of identify the method of advising the person flooded of the process should be made clearer with an event within Northamptonshire the decision to investigate or not and if an investigation takes place timescales provided. Several Food Investigating Officer will follow the the conclusion thereof. Will this be by letter and backed up by a Investigation Reports have already been established ‘Flood Investigations website or is it neither? completed. Those affected have had the Protocol’ whereby it will be opportunity to meet with officers and inform determined whether an investigation the investigations. Those affected are should be carried out, taking into contacted once the report has been finalised account the available resources and and published online. significance of the event. Where an investigation has been carried out a ‘Flood Investigation Report’ will be completed and published on this webpage: http://www.northamptonshire.gov.uk/e n/councilservices/Environ/flood/Pages /Flood-Investigations.aspx and those communities/individuals that have been affected will be contacted direct. I support Objective 3: Enhance the Natural Environment. Please, Noted. The process of public engagement is just ensure proper engagement that reassures residents that clearly set out in this document. their fears are being listened to and that improvements will be addressed in priority order, They are then empowered to understand that the way forward or to suggest other ways to
Communication, Engagement and Consultation Strategy, September 2013 51 achieve a satisfactory solution. I support Objective 5: Flood Risk and Development, excellent.. Noted. I support all of the Consenting Policies set out in Objective 5, Noted. Flood Risk and Development Yes I support Objective 7: Riparian Responsibilities. The Noted. emphasis should be strongly for main river flooding, ordinary water course flooding as well as closed drainage systems, to build in wherever possible and at intervals along these systems, flood water retaining measures. These are in addition to on-site methods of sustainable drainage. Particularly, with climate change, prolonged heavy rainfall will quickly overwhelm on-site sustainable drainage systems so the ordinary watercourses, main river systems and closed drainage systems need, flood water storage systems to reduce the water flow and hence prevent downstream flooding. This is very important, particularly for built up areas such as Northampton Town as it will be very vulnerable in such heavy prolonged rainfall. Agree with the proposals for the timescale of reviewing and Noted. updating the strategy, including public engagement as emphasised before. Anglian Water We have no further comments on the draft strategy, given our Noted. 28 previous involvement in the development of the document. Bedford Group The Strategy reads well. The only comments for consideration Noted. Agree. Section 7.5.26 shall read “make the of Internal I’d make are: relevant payment as set by Drainage 1) 7.5.26 would it be worth saying “… make the relevant legislation, which is currently £50”. Boards payment as set by legislation, which is currently £50”. This 29 means, that if Defra alter the figure following their current consultation, you don’t have to reissue the strategy? 2) From our experience, even with good planners’ SPG/SPD Noted. Agree. The guidance will emphasise The matter of non-restricted access drainage documents, developers and landowners always that designers, developers, constructers and for maintenance and operation will be want to plant and build too close to flood risk assets owners must provide adequate space for emphasised in sections 7.3.20 (watercourses, SuDS etc), so I’d always recommend re- access, maintenance and operations. (blue/green space), 7.3.33 (tree emphasizing that designers, constructers and owners have to coverage) and 7.5.2 (SuDS). provide adequate space for access, maintenance and operations. 3) I am pleased you have included the adoption of model Noted. Agree. Byelaws, but I’d also repeat the need for non-restricted
Communication, Engagement and Consultation Strategy, September 2013 52 access for maintenance and operation in sections 7.3.20 (blue/green space), 7.3.33 (tree coverage) and 7.5.2 (SuDS), so that it is wholly obvious to developers that they cannot landscape right up to the edge of asset making un- maintainable. Desborough Approach to the overall themes and objectives of the strategy Noted. Town Council looks practical. 30 Unclear why document says no flood risk area identified, when a Noted. Northamptonshire does have locally Table 4-1 Provide more clarity number of wards in our area of Kettering Borough are listed in defined flood risk areas, but a flood risk area regarding how a National Flood Risk the Public Summary. in this context is an area where there is a Area is identified. Nationally significant risk of flooding from local sources, such as surface water, ground water and ordinary watercourses. These areas have been identified using guidance produced by Defra. They were produced by applying the method in the Government guidance to produce 'clusters' of areas where flood risk is an issue and then applying the thresholds agreed by Ministers of 30,000 people at risk of flooding within a 6km grid square area in England. Using this National methodology there are only 10 Flood Risk Areas in England, including: 1. Bristol 2. London 3. South Essex 4. Medway 5. City of Brighton and Hove 6. West Midlands 7. Leister Principle Urban area 8. Liverpool and Sefton 9. Greater Manchester 10. Kingston upon Hull and Haltemprice. Maps are too small for DTC to be able to comment on accuracy Noted. Due to restriction on the data of hot spots. provided, insurance implications and data protection issues, this is the scale that must be used, to avoid individual properties being identified.
Communication, Engagement and Consultation Strategy, September 2013 53 The prioritisation of St Giles Ward Desborough is noted, this Noted. NCC will continue to work closely with contains Tailby Meadows which is of special interest. The River the North Northamptonshire Joint Planning Ise meanders have been re instated and it is a local priority that Unit (NNJPU) to ensure that this matter is access along the river through to Rushton, including for fully considered. wheelchair users should be delivered as part of the North Northants Core Spatial Strategy. Exact area which needs to be kept free from development needs clarification. Street Doctor should be the preferred reporting mechanism; Noted. Agree. Para 7. 2.15 sets out the Para 7. 2.15 – add: consideration to 999 or 101 should also be a route. process for reporting via the Street Doctor If the flooding is an emergency: process. Contact Fire and Rescue by calling 999. This service is primarily responsible for saving life. They may also pump out floodwater from your property. During flooding, you should focus on the safety of yourself and others. If the flooding is highway related: Use the Street Doctor service to report flooding relating to a highway such as blocked ditches, blocked drains or flooding on a road. If the flooding is from a burst water main or sewer flooding: Contact your service provider: Anglian Water Services Thames Water Utilities Severn Trent Water For all other flooding: Use our online report form to report all other flooding. Please note that this service is not to be used in an emergency situation. We will endeavour to respond to your submission within 21 days. Our online report form can also be used to tell us about historic flooding that has affected your property or community. Consideration should be given to re planting fast growing Noted. Para 7.3.33-7.3.36 sets out the species like willow which can be used as biomass fuel source. proposal to increase tree coverage. All native
Communication, Engagement and Consultation Strategy, September 2013 54 Regular flooding can help in the preservation and enhancement and appropriate species will be explored. of valuable wild meadows, which can also be used for grazing. Extent of flood risk area in St Giles ward to be accurately defined Noted. to preserve meadows and control extent of possible house building impact. Objective 6: Economically Sustainable Approach appears Noted. sensible. Objective 7: Riparian Responsibilities appears to be a sensible Noted. approach. Would like to see funding and timescale to establish footpath It is not the role of the LFRMS to establish extensions along Ise from Desborough/Rothwell to Rushton. funding and timescales for this type of project. Environment The detailed provided in the overall themes and objectives of the Noted. Agency strategy is good and clearly defines the intended way forward 31 and thinking in relation to local flood risk. The roles and responsibilities relating to flood risk management Noted. of all organisations, agencies and authorities are clear, the EA has previously responded and made comments on this section which have been incorporated. The EA is in agreement with the governance arrangements and Noted. is happy to continue to be a member of the Strategic Flood Risk Management Board, Local Flood Risk Operational Group and project management/task groups. The EA broadly agrees with the prioritisation and feels that Noted. It is the intention that this future iterations of this living document should ensure that wards methodology would be regularly updated in are re-considered in light of any new information. For example, light of new data. following flood events and our continued joint understand of flood risk (i.e. the shared schemes tool and future discussions of property level protection across Northamptonshire). Could you clarify whether map 3 includes flooding from main Noted. Map 3 does include flooding hotspots Para 6.3 to be amended to be more river. from all sources, including main river. explicit as to what data is included in Map 3. To strengthen this section it could be amended so that the Noted. Main chapter of the report amended priority assessment, climate change section and summary of to summarise the highest priority high priority wards all include reference to surface water wards. The full results for all flood risk flooding, fluvial risk and groundwater flooding. scenarios will be provided in an Currently it appears that surface and ground water flooding are appendix. considered in the assessment section, surface water flooding
Communication, Engagement and Consultation Strategy, September 2013 55 and fluvial risk in the climate change section then only surface water in the summary section. Under fluvial flood risk the EA is happy for main river to be referenced. A worthwhile addition to the summary of highest priority wards Noted. Agree. The highest priority areas will Identification of highest priority wards section could be to look at locations with risk from multiple be reviewed for all sources. This will provide has been updated to look at all three sources of flood along with a high sensitivity to climate change. an overall indication of the wards at most risk sources of flood risk. This would highlight where we need to work in partnership and from all sources. would provide an indication of where the interaction between surface water and fluvial risk needs considering. To show consistency with the National FCERM strategy, in Noted. This is considered to be a separate Update WFD compliance in appendix particular the catchment approach reference to CFMPs could be methodology, however a short review could to also include CFMP compliance made within the fluvial flood risk part of the priority assessment, be included within the LFRMS, which assessment. Summarise CFMP policy climate change and summary of high priority wards sections. references the CFMPs priority areas. areas and assess how the LFRMS There are various sources of information in the CFMP that could objectives are compliant with these be used, for example flood extent maps with defences for 10%, policies. 1% and 0.1% (both for the catchment and detailed maps for Northampton, Kislingbury, Kettering, Wellingborough and Oundle); tables of the number of properties currently at risk; a map within the summary report which highlights areas with greatest numbers of properties at risk; for climate change we have tables of properties and graphs comparing current and future numbers. This information could be included and then compared with the assessment of local flood risk priority areas identified within the strategy. A final summary of priority areas within the CFMP could be Noted. Would prefer to reference these Update WFD compliance in appendix made by including the policy map and description of the policies. rather than include, particularly as they are to also include CFMP compliance It should be noted that CFMPs cover main river and ordinary intended to be updated in the near future. assessment. Summarise CFMP policy watercourses. A useful introduction to the CFMPs (for example Use CFMPs to add more context. areas and assess how the LFRMS as described in the Cambridgeshire Flood Risk Management objectives are compliant with these Strategy) could also be included using the summary document policies. i.e. where it is, size of catchment, how it is rural in nature- page 4 of summary. A summary of the risk can be taken from page 7 of the summary report, first paragraph under where is the risk? To provide a common thread throughout the strategy reference Noted. Disagree. The action plan will remain to the high priority areas could be increased and more detail on objective based. The objectives for each of this added throughout the strategy. For example, for each the priority areas are set out generally within priority area a summary of the risk, and objectives and measures the action plan. The level of information is to manage this risk could be made. The priority areas could be considered too detailed at this stage for a highlighted within the relevant objectives and further strategy document. The intention is that each
Communication, Engagement and Consultation Strategy, September 2013 56 incorporated into the action plan. For example, format the action community will have a Community Flood plan using priority areas rather than objectives and add a column Plan, which will include this type of to indicate which objectives are relevant. information. It would be useful to include a description of how the high priority Noted. This should be made clearer within Prioritisation section needs to areas relate to hotspots. the Strategy. introduce how the methodology links with areas of flood hotspots and ensure consistency with language. Enterprise Zone + LDOs - Of note is that a number of the wards Noted. The LFRMS is not a planning Update references to studies and identified as being at the highest risk are within the Northampton document. NCC is working closely with the strategies. Enterprise Zone (EZ) of which there is no reference to. It should authorities putting these LDOs in place to Objective 5 add section on LDOs and be noted that the EZ will compromise of a number of Local ensure that flood risk matters are fully Enterprise Zones. Development Orders (LDOs) which will replace the need for considered. planning applications. This report makes reference to a number of assessments to support planning applications but fails to include guidance on the requirements regarding flood risk for any proposals within the EZ that will not require planning permission due to the relevant LDO. One of the guiding principles of the National FCERM strategy is Noted. This document Clearly sets out how Add the Pathfinder scheme under ‘community focus and partnership working’. To strengthen links communities will be engaged. A greater Objective 4. to this principle a clearer picture of risk for local communities emphasis for community engagement will be could be provided as suggested by the comments on high incorporated into the action plan. priority areas made in question 4. In addition, community involvement could be reinforced within the action plan, for example are communities involved in the design of any potential responses to flood risk? Communities will be a key partner in addition to other RMAs in delivering flood risk management and this could be emphasised throughout the strategy. The Local Strategy needs to be consistent with the National Noted. There needs to be greater clarity in Provide a review of CFMPs and FCERM strategy; to highlight this, a section on the National relation to how the LFRMS is consistent with RBMPs in Appendix 5. strategy could be added to this objective For example, an the National Strategy and how the CFMPs introduction to the National strategy and the guiding principles. and RBMPs have been used to inform the Add section on National Strategy at It would be really useful to see clearly how the Local strategy is work. Section 3 (legislation). consistent with the National strategy. Perhaps this could be achieved using text boxes throughout the objective sections i.e. Add National Strategy to list of within objective 3 ‘enhance the natural environment’ have a box document references. stating that this links to the multiple benefits guiding principle of the National Strategy. Add a summary of how NCC is Within this section it could also be explained how the County working with the EA, looking at FDGiA
Communication, Engagement and Consultation Strategy, September 2013 57 Council and EA are working together to understand the risk and and partnership working. share a joint vision and plan to manage the risk which will link to the MTP development i.e. the shared schemes tool. Links to the Emphasise that this strategy looks at CFMP could also be referenced, see comments under question local issues, but that when looking at 4. For example, where do priority areas of the strategy and options for schemes and other work CFMP overlap? How we can work together to understand the these will be looked at from a interaction of local and main river flooding? How do the catchment perspective to ensure that objectives and measures in the local strategy link with the risk is not to be pushed upstream or CFMP? One of the guiding principles of the National FCERM downstream to other areas. strategy is a catchment based approach. Although the intention of the local strategy is local risk it must be ensured that objectives and measures ‘make sense’ at the catchment scale i.e. do not cause conflict, that actions within the catchment are joined up and the impacts on other parts of the catchment are considered. Authorities must seek to avoid passing risk on to others within the catchment without prior agreement.
The following points could be considered: Have CFMPs been used to help set the strategic direction for flood risk management? Are all measures within a catchment joined up? Do the measures proposed pose any unacceptable transfer of risk up or downstream? How does the strategy contribute to achieving the objectives and measures (actions) within the CFMP? To address the above it may be necessary to have a specific section on the strategic/catchment approach and in addition add in relevant information into each of the objectives and make it clear that it is supporting the catchment approach guiding principle of the National Strategy. Having had the opportunity to comment on several Noted. investigations, the protocol appears to be appropriate. 7.3.9 – Can we amend this paragraph as we cannot be sure that Noted. Agree amendment. the measures proposed will not cause deterioration. See paragraph 2.5 in the SEA introduction and paragraphs 4.16-4.18 in the SEA part 3 assessment report as examples of alternative text. This is a comprehensive section that supports the sustainability Noted. Agree to add additional actions Add the following to the action plan: and multiple benefits guiding principles of the National FCERM de-culverting, natural flood risk
Communication, Engagement and Consultation Strategy, September 2013 58 strategy. However, the direction set out under this objective is management, blue/green not followed through into the action plan. It would be good to infrastructure, increased tree cover, strengthen the action plan with additional actions that can deliver actions for catchment sensitive the ambition of this objective i.e. actions relating to de-culverting, farming and the Nene Valley Nature natural flood risk management, blue/green infrastructure, Improvement Area increased tree cover, actions for catchment sensitive farming and the Nene Valley Nature Improvement Area. The strategy does consider WFD and has developed an Noted. Agree. 7.3.9 Amend wording to reflect approach to ensure that the measures proposed do not cause wording used in Part 3, Para 4.16-18 deterioration to water bodies or prevent future improvement to of the SEA. water bodies. To further strengthen links to WFD the strategy could indicate how it contributes to the improvement of water bodies, and what the relevant River Basin Management Plan means for the local strategy. The River Basin Management Plan describes how WFD should Noted. Agree. Objective 3 – include RBMP actions. be achieved in LLFA areas and sets out at a local level, what Add the actions agreed within the actions (measures) need to be implemented to achieve the WFD investigations for objectives of the WFD. There are a number of measures listed in Northamptonshire into the action plan the River Basin Management Plan that may be delivered through under this objective. development and implementation of the local strategy- see Also add consistency – deterioration, measures and annex B,C and D of the Anglian River Basin how strategy can influence Management Plan. To make clear links to the River Basin improvements. Where there are Management a section on this could be included within this improvements to be had, add section objective and the action plan. In addition, the actions agreed into Aim in Action Plan to say that within the WFD investigations for Northamptonshire could be WFD opportunities should be added into the action plan under this objective. explored. Within this section, further detail could be added to make Noted. Agree additional wording to Para 7.3.2 – reword to reflect the reference to the need to balance social, economic and compliment wording at Para 7.3.2. need to balance social, economic and environmental aims/objectives to develop sustainable flood risk environmental aims/ objectives to management measures that deliver wider benefits. There is develop sustainable flood risk separate Defra guidance on how sustainable development may management measures that deliver be achieved. This could be used to include a relevant section on wider benefits. the social, economic and environmental balance. Information from the SEA could be summarised into this section Noted. Agree. Add to Section 7.3 “Both the HRA and to highlight sustainable decision making (social/economic and the SEA were developed alongside environment objectives) and the consideration of alternative this Strategy and have therefore been options. used to inform sustainable decision making throughout, including the development of social, economic and
Communication, Engagement and Consultation Strategy, September 2013 59 environment objectives, and the consideration of alternative options” 7.3.37 Should be titled Catchment Plan rather than ‘Catchment Noted. Agree. Amend Para 7.3.37 to Catchment Sensitive Farming’ (reference to CSF should be under ‘Review Plan rather than ‘Catchment Sensitive Land Management Methods’, p.63 – there is some crossover Farming’. here with NIA land advisor). Increased Tree Coverage, p.64 should mention the Rockingham Noted. Agree. Para 7.3.33 mention the Rockingham Forest for Life initiative. Forest for Life initiative: “By 2025, the Forest for Life will be nationally recognised as an exemplar climate change initiative for the regeneration of the Rockingham Forest. It will enhance the natural and cultural environment, reinforce ancient woodlands, capture carbon, link fragmented sites and create wildlife corridors to provide a sustainable landscape for all to enjoy. The regeneration of the Rockingham Forest will raise awareness of a wide range of environmental and related issues and be fully supported locally. It will be an innovative and purposeful means of bringing businesses and communities together around a common cause. It will make the area more resilient and contribute to it being one of the most attractive landscapes in England to live in, work in and visit.” Outcomes: Businesses and communities see themselves as part of the local solution to a global issue Ancient Woodlands are reinforced and carbon is captured to mitigate climate change Fragmented sites are linked and wildlife corridors created
Communication, Engagement and Consultation Strategy, September 2013 60 Employment in traditional woodland based and land management jobs is increased and the local economy is more prosperous as a result More leisure, recreational and educational activities have increased green tourism for positive economic and social gains Eighty hectares per year over an initial fifteen years Enhance the health and well being of local communities Nene Valley NIA text is fine – there is no real need to go into Noted. detail under the various objectives at this stage. There is no reference to the Local Nature Partnership – the LNP Noted. Agree to add reference to the LNP. 7.3.42. Add reference to LNP. area matches the County boundary. Overall, objective 4 is supported as a logical way forward. Could Noted. This information is now included more information about the nature of the flood risk information within the Defra Pathfinder project. pack mentioned in the bullet/actions be included? Will it be progressed through the LRF welfare and community resilience group? Does it relate to the NCC ‘In case of emergency’ leaflet that is being updated to incorporate more about flood risk? Will the action to update the MAFP address the risk to Noted. All emergency plans including the Add link to community flood plans, vulnerable residents/locations? MAFP consider how we prioritise the which will identify vulnerable people. deployment of limited resources, this usually takes account of where we can have the greatest effect, greatest risk for greatest need. Where possible we will put in place mechanisms to identify and support vulnerable people. Section 7.4.8, could this section be amended to reflect the role Agree. 7.4.7 Add a section on the role that that the EA has in relation to providing advice on the production the EA has in relation to providing of community flood plans and promotion of the flood warden advice on the production of scheme. community flood plans and the promotion of the flood warden scheme and how we will deliver these
Communication, Engagement and Consultation Strategy, September 2013 61 in partnership. The EA supports this section (Objective 5: Flood Risk and Noted. Development) as it reinforces the objectives of the FWMA and NPPF on a local level. There is clear reference to other guidance etc and in particular the SPD which we will work with NCC to develop. WFD assessments Noted. Update appendix 5 to include impacts Appendix 5. Add “New schemes that Para 7.5.56 (page 79) requires any planning application for a that new schemes/development can have on affect the water environment may flood alleviation scheme to be accompanied by an assessment WFD. impact the biological, of Water Framework Directive implications. This report should hydromorphological, physico- include either WFD assessment guidance within an annex to this chemical and/or chemical quality document (to be agreed with NCC) or a suitable link to the elements. Any of these impacts could relevant guidance. It should also be confirmed what lead to deterioration and potential organisation(s) will be responsible for reviewing and advising on improvements to water bodies and the suitability of any assessment. New schemes that affect the hence the need for a preliminary water environment may impact the biological, assessment, which should have hydromorphological, physico-chemical and/or chemical quality regard to these matters. The LPA as elements. Any of these impacts could lead to deterioration and decision maker on these planning hence a preliminary assessment will need to have regards to all applications will likely secure via a four. The LPA as decision taker on these planning applications condition(s) any measures identified will likely secure via a condition(s) any measures identified that that will achieve WFD requirements.” will achieve WFD requirements. The EA has no concern with the content of the proposed Noted. consenting policies as they are in line with Defra recommendations. The reasoning behind the policy approach rather than byelaws has been explained which is helpful. It is perhaps a matter for consideration during future updates of the strategy whether this approach is sufficiently robust or if District and Borough Councils will need to create byelaws on behalf of NCC. 7.6.7- Has the LFRMS achieved this i.e. are the actions put Noted. Para 7.6.7 outlines what the indention 7.6.7 – Add the following ‘as we move forward the most cost beneficial and sustainable option? is moving forward. This does not suggest forward and consider the action in that we have achieved this as part of the more detail’ at the end of the LFRMS. sentence. 7.6.8- how are the high priority areas factored into the LFRMS Noted. The following activities will be given Objective 2. Add section on the and actions plan- for example how is flood risk going to be precedence in the high priority areas: Pathfinder project as this will develop managed in these areas? Is funding going to be prioritised to Data collection and registration of these actions. these flood risk areas? Information on how the actions have existing assets, particularly focussed on
Communication, Engagement and Consultation Strategy, September 2013 62 been prioritised would be useful. Ordinary Watercourses and surface water features; Assessment of potential flood risk on designated Local Nature Reserves, Local Wildlife Sites and Special Protection Areas; Assessment of potential flood risk on designated historic assets; Review of flooding hotspots and investigation into the cause of historic flooding along with the assessment of suitable flood mitigation schemes; Designation of assets which have a significant flood defence function; and Establish regular, proactive culvert inspection and maintenance regime on council owned assets. The studies and strategies have been prioritised on the perceived level of urgency to complete the work. The EA supports the inclusion of this section (Objective 7: Noted. Riparian Responsibilities) as it provides useful information about rights and responsibilities. In particular, the information about nuisance flooding is not readily available elsewhere. Further information on funding could be included within the Noted. Information from the Defra pilot study Action Plan. The general approach to action plan. For example, an identification of where funding is which NCC took part in has been included funding is set out in Objective 6. Add already secured and where there are funding gaps. More detail within the action plan. this note to the beginning of the action from the Defra pilot study that Northamptonshire took part in plan. could be included within the action plan. To increase links to the CFMP and catchment approach the Noted. The SNC SWMP would cover Add the following CFMP actions to following CFMP actions could be added: Towcester. Action Plan: Objective 2- for the Towcester policy unit in the Great Ouse Objective 2. Study along Wood CFMP there is an action for a study along Wood Burcote Burcote Brook. Brook. The Welland & Glens policy unit in the Welland Groundwater study. CFMP has an action for a groundwater study. In the Great Add CFMP to Source of Ouse CFMP it mentions possibly undertaking a SWMP for information for SNC SWMP. Towcester, does this need to be reference with the SNC Objective 3 - environmental SWMP action? In the Nene CFMP there is an action for a enhancements, land management SWMP in Wootton does this need to be included for future
Communication, Engagement and Consultation Strategy, September 2013 63 consideration? and remove structures. Objective 3- there are actions within the CFMP for Objective 4 - continue with flood environmental enhancements and land management (in warning activities and particular in relation to areas where our aim is to reduce improvements, maintenance). In the River Welland CFMP (Welland & Glens ensure that opportunities are policy unit) there is an action to remove structures. taken within minerals and waste Objective 3/6- within each of the 3 Anglian CFMPs that cover development/ action plans to use Northamptonshire there are actions to reduce maintenance mineral extraction sites to store activities. flood water. Objective 4- nearly every CFMP policy unit has an action to continue with flood warning activities and improvements; this is a really important way of managing the consequences of flooding. This action could be developed further in discussion with the EA flood resilience team. The Great Ouse CFMP has an action for floodplain storage which could be added in addition to the Nene storage action. Objective 5- nearly every CFMP has an action to link flood risk management with planning, redevelopment etc to ensure flood risk elsewhere is not increased, we make space for water and incorporate resilience measures. There is a lot of information included on this within the objective text which has not been incorporated into the action plan. Also within the Great Ouse CFMP there is an action to ensure that opportunities are taken within minerals and waste development/action plans to use mineral extraction sites to store flood water. This could be included and extended to the River Nene catchment. The timescales in the action plan should be checked and Noted. Agree Update action plan to show that the updated if necessary before the LFRMS is published. E.g. Corby SWMPs have been commenced. SWMP on page 91 will not be completed in 2012/2013. It would also be useful to consider dates for actions marked as high priority where this is later than the dates for medium or low priority actions. E.g. ENC SWMP is high priority with a date of 2015 whereas the AW CCTV action on the same page (page 93) is medium priority for 2014. This may simply be a case of adding footnotes about “quick win” opportunities or other explanation. Infrastructure Plans Noted. Agree. Action plan timescale to be updated. It is important that both the West Northamptonshire and North Remove priority column. High level Northamptonshire Infrastructure Development Plans (IDP), cycles for timescales – every 6 years.
Communication, Engagement and Consultation Strategy, September 2013 64 referred to page 140 onward, are informed by the latest information/studies and updated accordingly. The LFRMS correctly states that analysis of the WN IDP suggests that funding is in place for the majority of items required. However, the WN IDP does not currently identify all of these infrastructure requirements to deliver development, and therefore cannot assess the extent to which this infrastructure may impact on the delivery of development. A recent lit review of flood risk studies which included the Nene Flood Storage Study has identified a number of schemes that could be contributed to through new development e.g. increase of storage in the Northampton Washlands. Where the costs (including whole life maintenance costs) of these schemes are known they should be included in the relevant IDP. Where the costs are not known Partners should gather evidence of future infrastructure costs at the earliest opportunity. In order to seek developer funding where considered appropriate and necessary, the LFRMS could include an ongoing action under Objective 6 – Economically Sustainable Approach to ensure that Noted. Agree. Add action to Objective 6 – when information/studies become available, any schemes, Economically Sustainable Approach including their costs, are identified and added to the IDP or to action plan ‘when Community Infrastructure Strategy. information/studies become available, any schemes, including their costs, are identified and added to the IDP or Community Infrastructure Levy list. Page 20 - transfer of historic records now complete Noted. Agree to amend. Table 4-1, Page 20 – Amend wording to ‘records now complete’. 4.37 page 27 - formerly rather than formally. Noted. Agree to amend. 4.37 amend formally to formerly 7.2.27 page 58 - Where SuDS are identified as an asset it would Noted. be useful if the information recorded also included the area served and the location of the details of the design of the system. 7.3.26 page 63 - speech marks included at end of para are not Noted. Agree to amend. 7.2.26 – remove speech marks. required. 7.5.28 page 72 - Policy should probably sit after 7.5.29 rather Noted. The intention is to keep all policies than 7.5.28. together in one section. 7.5.48 page 77 - missing space before Assessment of Flood Noted. Agree to amend. 7.5.48 add space before Assessment Risk Impacts Upstream and Downstream. of Flood Risk Impacts Upstream and
Communication, Engagement and Consultation Strategy, September 2013 65 Downstream. Action plan page 99 - Nene Lock Reversal - Partners should Noted. Agree to amend. Page 99. Amend partner to ENC read ENC rather than SNC. rather than SNC. Canal and River We have the no specific comments in relation to the Noted. Amend Table A4 in line with the new Trust Northamptonshire Local FRM Strategy Consultation. roles and responsibilities of the Canal 32 and River Trust. British Waterways in England and Wales became the Canal & Noted. River Trust (the Trust) on 2 July 2012. By way of background to our roles and responsibilities in relation to flood risk management: 1. The Trust is a navigation authority. It inspects, maintains and Noted. operates the water control structures within its ownership primarily to meet its statutory obligation to maintain navigation. 2. The Trust is not a Risk Management Authority (RMA) as Noted. defined by Section 6 (13) of the Flood & Water Management Act 2010. 3. The Trust is not a Category 1 or 2 responder as defined by Noted. the Civil Contingencies Act 2004, and is not therefore required to undertake any specific civil protection duties under the Act. By local agreement, the Trust may provide specific assistance in the event of a flood incident. Typically this would be in consultation with Silver Command and/or the Environment Agency. 4. In terms of managing flood risk, the primary responsibility for Noted. land drainage and flood prevention rests with private parties. The Trust does not have any specific statutory responsibilities in relation to flooding and, therefore, its responsibilities are those of an owner and operator of its canals and other waterways. Councillor for Details of flooding provided for: (1) Gainsborough Road, near Noted. These locations have all been Corby Lowry Close and the western entrance to Blake Road in Corby, recorded on the flooding hotspot database. 33 and (2) Oakley Road, near the entrance to Gainsborough Road in Corby. South Northants Table 6.1 lists the highest priority Wards across the County Noted. NCC’s prioritisation assessment District Council affected by surface water flooding, as assessed by NCC. Of the calculates the number of receptors (for 34 37 highest priority Wards SN has 4: example homes, hospitals, main roads, • Blakesley and Cote sewage treatment works) that are at risk of
Communication, Engagement and Consultation Strategy, September 2013 66 • Harpole and Grange flooding. A number of different flood risk • Washington scenarios are assessed to include each • Silverstone source of flood risk (surface water, We have concerns about the criteria used to prioritise the wards groundwater and river flooding) and a range listed above. A list of the wards that were identified by South of flood severities. The assessment is based Northamptonshire in 2009 were based on number of properties on the calculated risk of flooding. This is a flooded, historical intelligence and number of incidents. For much more proactive approach, than simply example, we note that Kings Sutton and Chacombe are absent reviewing the number of properties which from the Table. have been flooded, which is considered rather reactive.
Historic flooding is taken into account as part of the hotspot data, which records historic flooding. This assessment is undertaken on a ward-by-ward basis, so that the wards with the highest number of receptors at risk of flooding can be prioritised. As you will be aware the requirement for major flood alleviation Based on the Flood Map for Surface Water schemes has been identified in Kings Sutton and Chacombe and assessment, Kings Sutton ward features in we therefore find that we are odds with the lead local flood 103rd place out of 144 for a 1 in 200 authority’s prioritisation. We would therefore question why and probability (more extreme) flood event. The how the wards listed in the document have been prioritised and ward is still considered ‘high’ priority, on a why others with known issues are absent. scale of ‘very high’ to ‘low’. Comparatively, for fluvial flood risk (flooding from rivers) Kings Sutton features in 27th position for a 1 in 100 probability flood event. Sections 7.2.8 to 7.2.14 set out NCC's proposed policies Noted. The legislation requires NCC to regarding the S.19 Flood and Water Management Act (FWMA) investigate flood incidents to the extent it duty to investigate flooding where it considers it is "necessary or considers necessary or appropriate. This appropriate." It states that investigations will only be carried out threshold is considered appropriate and this where: has been confirmed by the recent flooding • Critical infrastructure is affected incidents experienced in Northamptonshire • A property has experienced repeat flooding (so no from July 2012 – Feb 2013. The majority of investigation after first time flooding) cases include one or two properties that • 5 or more properties are affected in a single incident. have been flooded on more than one We are extremely concerned that these criteria are very narrow occasion. This therefore excludes the one-off and will not satisfy the public and those elected members that flooding incidents which are usually related represent then. There will understandably be an expectation to Riparian maintenance issues. There has from owners of affected properties that flooding incidents will be been a great deal of support from the
Communication, Engagement and Consultation Strategy, September 2013 67 investigated and that there will be an outcome from that consultation process relating to this protocol. investigation In addition by only investigating internal flooding of The LFRMS is a living document and the property, “near misses” will not be considered. This raises processes, procedures, policies and actions concerns both from the public’s expectation but also when will be regularly reviewed and updated or considering long term risk management. We therefore consider amended if considered necessary. However that NCCs duty to investigate is not adequately met in the draft NCC consider that this threshold is effective. strategy. Daventry District No comment. Noted. Council 35 East Northants No comment. Noted. Council 36 North Action Plan: Noted. Priority was based on a number of Remove priority column in Action Plan Northamptonshir Not sure how the priority level is identified, and what the basis different methodologies as ascribed by the e Joint Planning for the levels are? lead authority. Unit Pg 92 3rd action: No, the scheme identified here relates to the 37 Is this also known as Slade Brook SFSR? It says to investigate – existing disused reservoirs at Cransley and if the above project then this is in the KBC SFRA level 2? And Thorpe Malsor, which are on tributaries of has an estimated cost of £2.3m, so assuming this further the Slade Brook – the Thorpe Malsor Arm. investigation has been done. This is what has gone into the SEMLEP form. Also the priority is ‘low’ – could this change to medium or high, as it will help release land for development as identified in the KTC AAP. Pg 93 2nd action: Noted. In LPAs other than NBC, this action is Assume this has come from further work that NBC have done, likely to arise once the SWMPs have been but the action would be good to happen in each LPA. completed. Pg 93 3rd action: Noted. Action needs to incorporate all other Description will be updated to include To add in Northampton to the description? SWMPs once completed. all SWMPs once completed. Pg 94 3rd action: The guidance will be adopted by NCC as Add to description that the guidance Who will adopt this – NCC or the LPAs? SAB, in agreement with all partners, will be adopted by NCC as SAB, in including LPAs. agreement with all partners including LPAs. Pg 95 3rd action: Multi Agency Flood Plan – this is noted at the What does MAFP stand for? top of the page and in the table of Abbreviations in Appendix 2.
Communication, Engagement and Consultation Strategy, September 2013 68 Pg 96 2nd action and pg 87 1st action: Noted. NNJPU to be removed from the Do the NNJPU need to be as a partner in the Corby and East maintenance actions for Corby and Northants maintenance action, we aren’t listed as a partner in East Northants. the Kettering or Wellingborough ones? Pg 98 1st action: Noted. Assuming this accords with the MWLDF as I seem to recall that previously they didn’t want to create any more open water? Pg 98 2nd action: We are not aware of any development being Is any development dependant on these two schemes being dependent on skew bridge/Raunds hog investigated and carried out? Might then increase the priority? dyke. Pg 99 2nd action: These are different schemes. Is this doubled up with pg 92 3rd action? Or am I getting confused with two different projects? Pg 100 1st action: The preferred option doesn’t require any Should the Weldon flood storage reservoir be added to the works to the Weldon flood storage reservoir. description? On page 140 re Sources of Funding: Noted. Remove reference to NN SPD The NN SPD on development contributions never got further than a draft, and work on CIL took over, so not sure if it is worth mentioning it or not, the playing field has changed a bit since then. Titchmarsh The overall themes and objectives of the strategy are supported. Noted. Parish Council The roles and responsibilities relating to flood risk management Noted. 38 are clear enough, although we suspect that the large number of bodies involved is a recipe for inefficiency, excessive bureaucracy and potential for buck-passing. The relationship between the LLFA [planning and management] Noted. and the district councils [action] in terms of watercourses particularly concerns us. It does not appear to improve greatly on the model that has failed us before. We agree with the Prioritisation Assessment, as long as it is Noted. Agree. recognised that flooding is a major catastrophe for the individual irrespective of the number of properties affected. Each area needs to be considered separately with the risk accurately assessed and possible solutions costed. Such reviews ought to be undertaken with the full involvement of the communities affected.
Communication, Engagement and Consultation Strategy, September 2013 69 We support Objective 1: Collaborative Approach, as long as Noted. there is genuine and meaningful collaboration. In the past we have experienced situations where a need has been recognised, a working party established including representatives from the county and district councils, and several meetings held only for the initiative to wither away because of the retirement of the lead officer. We support Objective 2: Local Flood Risk. It is important though Noted. that the roles outlined in table 7 have real substance and officers given meaningful powers to take action. We agree with the protocol for flood investigations. Noted. In general we support Objective 3: Enhance the Natural Noted. Environment, but: 1] By stemming excessive flow, culverts can sometimes limit flooding downstream. This can be a means of achieving flood control where there is adequate storage upstream of the culvert. 2] Farmers should be encouraged to take more steps to limit the run-off from their land. This winter, the amount of topsoil washed downstream has been worryingly high. 3] Recent experience has shown how trees flanking streams can greatly exacerbate a situation where their maintenance has been neglected. We have major concerns regarding riparian responsibilities. Noted. Active enforcement is covered by Whereas the county council has powers of enforcement, the Objective 4. Active Enforcement, policy talks merely of encouragement. Three episodes here Maintenance and Inspection. have shown that this simply does not work. People can be encouraged to do something ad nauseum but, without the threat of enforcement, little is achieved. We support Objective 5: Flood Risk and Development. It is Noted. crucial that planning authorities give full consideration to the full impact of any development – be it housing or commercial – anywhere in a catchment area and not just in the immediate locality. In our experience, flood risk is not given sufficient weight, particularly by the Environment Agency. In considering culverting, more priority needs to be given to their Noted. clearance. We have three culverts within 200 yards along one road in the village. None of them are wide enough for the flow of water in peak conditions. They are also too long with the
Communication, Engagement and Consultation Strategy, September 2013 70 consequence that keeping them clear is extremely difficult [and expensive]. As a result the road is frequently impassable and dangerous. We support Objective 6: Economically Sustainable Approach. Noted. We do not support Objective 7: Riparian Responsibilities. As Noted. Active enforcement is covered by explained above, we see this as a weakness. Riparian owners Objective 4. Active Enforcement, are always clearly identifiable and, where they are known, there Maintenance and Inspection. appear to be insufficient mechanisms available for their responsibilities to be enforced. A neglected watercourse can – and does – have a major impact on properties at a considerable distance upstream. A proposal for flood alleviation scheme or action which has not Noted. been considered: The road in the Polopit area of Titchmarsh is frequently blocked by floodwater, on two occasions recently upwards of 40cm deep. This leaves 30+ dwellings marooned, and twice in the past one of the newer houses inundated. In reference to proposals for the timescale of reviewing and Noted. updating the strategy: In order to have any validity, the targets set must be drawn up in consultation with the communities affected. They should be shared with those most likely to be impacted and have realisable objectives. It is also important that those communities are also involved in the monitoring and evaluation of any initiatives. Thus far, this has been very poorly done, leading to understandable disappointment and cynicism. It is a valuable document, but its merit can only be judged by the Noted. actions that flow from it. What communities want is for their concerns to be given credence; for any risks to be assessed objectively; and, most importantly, one officer or identifiable group to oversee any projects and to take responsibility for keeping the community informed.
Communication, Engagement and Consultation Strategy, September 2013 71