Environment Department – Transportation & Engineering Services Appendix A
City and County of Swansea
Local Flood Risk Management Strategy
Final Version
June 12 Appendix A
Document Control Sheet
Document Author: Mike Sweeney Project Manager: Geoff Sheel
Revision History
Date Version No. Summary of Changes Nov 12 LFRMS Draft Feb 13 1.0 Final Version
Approvals
Approved by Signature Date Version
Distribution
Name Title Date Version
© 2011 City and County of Swansea. All Rights Reserved.
Appendix A
Table of Contents
1.0 Introduction…………………………………………………………………………… 4
2.0 Legislation…………………………………………………………………………….. 6
3.0 Flood Risk Management Authorities…………………………………………….. 9
3.1 Responsibility for Flooding…………………………………………………………… 10 3.2 Responsibility for Flood Risk Management………………………………………… 10 3.3 Powers and Duties of City and County of Swansea as Lead Local Flood Authority ………….... 11 3.4 Responsibilities under the Flood and Water Management Act 2010…………… 13 3.5 Responsibilities of other flood Risk Management Authorities and Stakeholders……………………. 21
4.0 The Assessment of local flood risk for the purpose of the strategy………. 26 4.1 Historical Flooding……………………………………………………………………. 26 4.2 Potential Flood Risk………………………………………………………………….. 30 4.3 Interaction between different sources……………………………………………... 36 4.4 Prioritisation of Resources 37 4.5 Local Plans…………………………………………………………………………… 39
5.0 Objectives for Managing Flood Risk……… …………………………….. ……… 41 5.1 Understanding Local Flood Risk…………………………………………………….. 43 5.2 Recording Flooding Incidents……………………………………………………….. 43 5.3 Developing a Collaborative Approach to Flood Risk Management…………….. 43 5.4 Involving Community Engagement……………………………………………….. 44 5.5 Ensure planning decisions are properly informed by flood risk 44 5.6 Adoption of an holistic approach………………………………………………….. 44 5.7 Encouraging ordinary watercourse maintenance…………………………………… 45 5.8 Best practice …………………………………………….. 45 5.9 Encouraging Businesses and Communities to take steps to prepare for flooding.. 45
6.0 Actions and Measures to Improve Flood Risk Management…………………. 46 6.1 Overview……………………………………………………………………………….. 46 6.2 High Level Themes……………………………………………………………………. 46 6.3 Measures………………………………………………………………………………... 47
7.0 Funding and Delivery Plan…………………………………………………………. 62 7.1 Existing Funding Mechanism………………………………………………………… 62 7.2 Summary of Existing Funding Mechanism…………………………………………… 63 7.3 Public Funding…………………………………………………………………………… 64 7.4 Other possible sources of funding……………………………………………………….. 64 7.5 Prioritisation of funding ……………………………………………………………….. 65
8.0 Environmental Benefits ………………………………………………………………… 66 9.0 Next Steps ………………………………………………………………………………. 68 10.0 Review of Strategy …………………………………………………………………….. 69
Glossary of Terms 69 References 70
Local Flood Risk Management Strategy Appendix A 1.0 Introduction
The Flood and Water Management Act 2010 implemented recommendations from Sir Michael Pitt’s Review of the 2007 floods in the UK. Under the Act the City and County of Swansea became a ‘Lead Local Flood Authority’ (LLFA) and was given a series of new responsibilities to coordinate the management of local flood risk from surface water, ground water and ordinary watercourses.
This has involved close working with partners who have similar responsibilities for managing flood risk from other forms of flooding. The Environment Agency has responsibility for managing flood risk from main rivers, reservoirs (and the sea).
As LLFA the City and County of Swansea needs to ‘develop, maintain, apply and monitor’ a Local Flood Risk Management Strategy. The Strategy will focus on local flood risk due to flooding from surface water, groundwater and ordinary watercourses. However, it has to consider significant interactions with main rivers, sea and main sewer systems.
The Strategy will be the primary method through which the LLFA discharges its role to provide leadership and co-ordinate flood risk management on a day to day basis. It will act as a focal point for integrating a range of flood risk related outcomes across the county. The council’s strategy must be consistent with the Environment Agency’s National Flood Risk Management Strategy.
This strategy is the first of its kind covering the whole of City and County of Swansea. With ever improving knowledge, additional legislation and budgetary constraints it will be necessary to update and review the strategy and its associated action plan on a six yearly cycle. This review will be overseen by the City and County Flood Risk Management Partnership and will be available for scrutiny by City and County of Swansea Councillors.
The minimum statutory content of Local Strategies is set out in Section 10 of the Flood and Water Management Act 2010. Local Strategies must set out the objectives and measures for managing local flood risks along with the timescales and costs of implementation.
The main aim of the strategy is to reduce the risk of flooding within the City and County of Swansea and to comply with the National Objectives as set out by Welsh Government. The Strategy outlines the legislation concerning flood risk, the nature of flood risk, the objectives of managing flood risk and the range of actions that can be undertaken. It also provides information on available funding streams and recognises the need to apply flood risk management approaches to manage existing and future flood risks within the administrative boundary. There has been a shift from the traditional approach of constructing defences to a risk based management of flood risk. Simply constructing bigger and
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Local Flood Risk Management Strategy ______better defences is not always a sustainable option; the location of defences can have a detrimental affect on the wider environment and they are becoming more expensive to construct and maintain, restricting the number of interventions that are possible.
Although, this Strategy does not identify specific projects to commence in the future, it sets strategic actions and principles to aid decision making for flood alleviation schemes in the future. In the coming years there will be significant changes to the planning system and the flood insurance sector and there will be developments in funding and design of flood alleviation schemes. LLFAs will become responsible for both approving the design of the Sustainable Drainage Systems (SuDS) and adopting and maintaining the finished systems. The consenting of works in ordinary watercourses has also transferred to LLFAs from the Environment Agency. In addition to this, it is likely that there will be improvements in flood warning, prediction and knowledge of areas most at risk. Revisions or supplements to this Strategy may be required prior to the next scheduled as a result.
In summary, this Strategy adopts a holistic approach to flood risk management, taking into account the geographical, socio-economic and political factors. It enables effective management of local flooding by improving collaboration and co-operation between key stakeholders. It will improve communication and present information to the public in regards to the risk of flooding and what can be done, regardless of its cause (from main rivers or local flooding).
In combination with the National Strategy, the Local Strategies will encourage more effective risk management by enabling people, communities, business and the public sector to work together to:
• ensure a clear understanding of the risks of flooding and erosion, nationally and locally, so that investment in risk management can be prioritised more effectively; • set out clear and consistent plans for risk management so that communities and businesses can make informed decisions about the management of residual risk; • encourage innovative land management of flood and coastal erosion risks, taking account of the needs of communities and the environment; • for links between the local flood risk management strategy and local spatial planning; • ensure that emergency plans and responses to flood incidents are effective and that communities are able to respond properly to flood warnings; and • to help communities to recover more quickly and effectively after incidents.
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Following the extreme floods of 2007, the Pitt Review identified the need for better legislation for the effective management of flooding, particularly from surface water. Many of the recommendations from the Pitt Review have been implemented through the Flood and Water Management Act 2010, which places a greater responsibility on upper tier local authorities (county and unitary councils) for surface water management issues, under their new role as a Lead Local Flood Authorities. The role of the Environment Agency in respect of river and tidal flooding remains. The Environment Agency is also given a strategic overview role for all flood and coastal erosion risk management.
The Flood Risk Regulations (2009) came into force in December 2009 and transpose the EU Floods Directive into law for England and Wales. The Flood Risk Regulations required a Preliminary Flood Risk Assessment to be produced which identifies areas where significant numbers of people are at risk of surface, ground and ordinary water course flooding. Where such areas exist the regulations also require the production of hazard and risk maps and flood management plans. Within the City and County of Swansea, there was one indicative flood risk area identified which requires further flood mapping assessment by 2013 in order to comply with the second stage of regulations.
The Preliminary Flood Risk Assessment for City and County of Swansea was completed in June 2011 and will be reviewed in 2016.
Under the Flood Risk Regulations 2009, the City and County of Swansea is required: to identify and assess the risk of flooding in the county borough; to prepare flood hazard and flood risk maps; to prepare flood risk management plans for each flood risk area, and to ensure these are all regularly updated to take into account climate change. The following table sets out the required timetable for the respective delivery. The first two elements of the work are covered by the completed Preliminary Flood Risk Assessment.
TARGET ACTIVITY OBJECTIVE
22nd June 2011 Prepare Preliminary The emphasis in the PFRA is Assessment Report. on local flood risk from surface water, groundwater, and ordinary watercourses
22nd June 2011 On the basis of the PFRA, Flood Risk Areas are areas of identify Flood Risk Areas. significant risk identified on the basis of the findings of the PFRA, national criteria set by the UK Government Secretary of State and guidance provided by the Environment Agency
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22nd June 2013 Prepare Flood Hazard Maps Used to identify the level of and Flood Risk Maps for each hazard and risk of flooding Flood Risk Area within each Flood Risk Area to inform Flood Risk Management Plans. 22nd June 2015 Prepare Flood Risk Plans setting out risk Management Plans for each management objectives and Flood Risk Area. strategies for each Flood Risk Area.
The Preliminary Flood Risk Assessment is a high level screening exercise that brings together, from a number of sources, easily available information on past and potential flooding to enable judgments to be made about local flood risk. The assessment of potential flood risk was derived from national datasets produced by Defra but also with the benefit of additional information from other Flood Risk Management Authorities. The details of past flooding were obtained from a number of sources, but the process of analysing past flooding revealed some inadequacies in the collection of data on flooding incidents which will be addressed through this strategy. Only a small number of locations were identified in the Preliminary Assessment Report as having ‘significant harmful consequences’.
The Flood and Water Management Act 2010 gained royal assent in April 2010 and provides legislation for the management of risks associated with flooding and coastal erosion. The Act reinforces the need to manage flooding holistically and in a sustainable manner. It places a number of new roles and responsibilities on City and County of Swansea, as 'Lead Local Flood Authority' (LLFA). The preparation of this Local Flood Risk Management Strategy is just one of the duties placed upon the Council.. Other responsibilities of the Council include:-
• Highways Authority • Emergency Planning Authority • SuDS Approval Body, when the appropriate legislation comes into force (expected April 2013) • Planning Authority • Historical and Natural environment responsibilities
As LLFA the City and County of Swansea was given a set of new responsibilities for coordinating the management of local flood risk including: -
• The preparation of local flood risk management strategies; • A duty to comply with the National Strategy; • To co-operate with other authorities, including sharing data; • A duty to investigate all flooding within its area, insofar as a LLFA consider it necessary or appropriate; • A duty to issue consents for works on ordinary watercourses in accordance with new legislation from 6 th April 2012
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• A duty to maintain a register of structures and features likely to affect flood risk; and • A duty to contribute to sustainable development.
Along with these duties, each LLFA has a number of permissive powers, including: - • Powers to request information; • Powers to designate certain structures or features that affect flood or coastal erosion risk; • Increased powers to undertake works to include broader risk management actions; and • The ability to cause flooding or coastal erosion under certain conditions.
Flood Risk Management is affected by a range of guidance and legislation. Some of these include: • The Climate Change Act (2008) • The Conservation of Habitats and Species Regulations (2010) • The Civil Contingencies Act (2004) • Strategic Environmental Assessment (SEA) Directive (2001/42/EC) • The Land Drainage Act (1991) • The Water Framework Directive (2007) • The Wildlife and Countryside Act (1981) • Countryside and Rights of Way (CROW) Act (2000) • The Public Health Act (1936)
A national Flood and Coastal Erosion Risk Management strategy has been produced by the Environment Agency which sets out the principles that will guide local strategies and the activity of all flood authorities.
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3.0 Flood Risk Management Authorities
The Act states that the LFRMS must specify risk management authorities. ‘Risk Management Authorities’ are certain organisations which have responsibilities around flooding, both new ones from the Flood and Water Management Act and longstanding ones from previous legislation.
City and County of Swansea, as the Lead Local Flood Authority (LLFA), is responsible for leading the management of flood risk from local sources. This includes ordinary watercourses, surface water, ground water and situations where there is an interaction between these sources and main rivers or the sea. This is important in City and County of Swansea’s case as it is a coastal authority. The Council also has a role in emergency planning and road drainage
There are a number of key organisations which are classified as Flood Risk Authorities and have an active role in managing flood and coastal erosion risks in Swansea.
The Environment Agency Wales (EAW) is responsible for managing flood risk from main rivers, reservoirs and the sea. The EAW also has a strategic overview role over all flood and coastal erosion risk management. It also has a key role in providing flood warnings to the public, protecting and improving the environment and promoting sustainable development .
Dŵr Cymru/Welsh Water is a water and sewerage company, responsible for the provision of foul and surface water sewerage across the County .
As Highways Authority the City and County of Swansea is responsible for managing flood risk on roads and highways within the County. Trunk roads including motorways however are maintained by the Trunk Roads Agency
Other Key stakeholders
Network Rail are riparian landowners of culverts crossing and serving the rail network and information relating to flood risk from these assets need to be shared with the Lead Local Flood Authority
The Rivers and Canal Trust are now responsible for the canal network located in the Authority’s area and for protecting its own structures, some of which are flood defences .
The South Wales Trunk Road Agent (SWTRA ) is an Agency working on behalf of the Transport and Strategic Regeneration division of the Welsh Government (WAG). It is responsible for Managing, Maintaining and Improving the strategic road network in South Wales
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The City and County of Swansea, in conjunction with Neath Port Talbot County Borough Council, has formed the Joint Resilience Unit (JRU) to help discharge its responsibilities in respect of emergency planning. This includes ensuring that there is adequate preparation for flooding emergencies. In addition, as a Planning Authority, the Council must consider the effects of new developments, particularly on flood plains and where there may be issues in respect of flooding to highways.
3.1 Responsibility for flooding
As mentioned previously, flooding can come from various sources and under recent legislation the responsibility for managing the risk from these different sources falls to different Risk Management Authorities.
Overview of responsibility for flood risk management within Swansea
City and County of Swansea Environment Agency
• Surface water • Main Rivers • Groundwater • Sea • Ordinary watercourse • Reservoirs • Highway Flooding
DCWW – Welsh Water Other Key Stakeholders Network Rail/ British • Sewer Flooding Waterways/Trunk Road • Burst water mains Agency
• Culverts • Canals • Motorways
3.2 Responsibilities for Flood Risk Management
The Flood and Water Management Act 2010 identified certain organisations as ‘risk management authorities’ which have responsibilities relating to flooding under the Act and those responsibilities from earlier legislation
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These organisations have all the following duties and powers:-
1. Duty to co-operate with other risk management authorities in the exercise of their flood and coastal erosion risk management functions, including sharing flood risk management data
2. Power to take on flood and coastal erosion functions from other risk management authorities when agreed by both sides.
3. Duty to comply with environmental legislation.
Co-operation between flood risk management authorities will take place through the City and County of Swansea Risk Management Partnership. Collaboration will be necessary on recording flood assets, assisting with flood investigations, and providing local knowledge to Sustainable Drainage System [SuDS] approval officers, regarding drainage applications for new development in the area, and sharing data and information to ensure public enquiries are answered quickly by the appropriate organisation.
3.3 Powers and Duties of City and County of Swansea as Lead Local Flood Authority
Under the terms of the Flood and Water Management Act 2010, the City and County of Swansea is responsible for what are termed ‘local flood risks’. These include the risks of flooding from ordinary watercourses, surface runoff and ground water.
Local Authorities have always had certain responsibilities in relation to ordinary watercourses, and in practice most Local Authorities took the lead in dealing with surface water flooding incidents prior to the changes contained within the Flood and Water Management Act 2010. This is, however, the first time responsibility for the risks of flooding from surface runoff has been allocated to any body in law.
The Flood and Water Management Act 2010 places a number of statutory duties on The City and County of Swansea in their new role as LLFA including:
• the preparation of local flood risk management strategies • a duty to comply with the National Strategy; • to co-operate with other authorities, including sharing data; • a duty to investigate all flooding within its area, insofar as a LLFA consider it necessary or appropriate • a duty to maintain a register of structures and features likely to affect flood risk; and • a duty to contribute to sustainable development.
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In addition to these each LLFA has a number of what are called permissive powers. These are powers that allow them to do something, but do not compel them to and include:
• powers to request information; • powers to designate certain structures or features that affect flood or coastal erosion risk; • the expansion of powers to undertake works to include broader risk management actions; and • the ability to cause flooding or coastal erosion under certain conditions.
LLFA in Wales will also take on the role of the SuDS Adopting and Approving Body in relation to sustainable drainage systems. In this role they will be responsible for both approving the original design of the SuDS and adopting and maintaining the finished system.
To enable the City and County of Swansea to implement its new roles and responsibilities in respect of local flood risk, certain functions previously held by the Environment Agency have been transferred. This included taking on the responsibility for consenting works on ordinary watercourses in April 2012. The table below outlines the Council’s key new duties to comply with the Flood and Water Management Act.
Outlined below are the flood risk management roles and responsibilities of Lead Local Flood Authorities. The key areas where they have responsibilities can be identified as follows:
• Responsibilities under the Flood and Water Management Act 2010 • Responsibilities under the Land Drainage Act 1991 • Responsibilities as a Planning Authority • Responsibilities for maintenance of public spaces • Responsibilities as a coastal erosion risk management authority • Responsibilities for emergency planning
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3.4 Responsibilities under the Flood and Water Management Act 2010 are summarised in the Table below:-
Responsibility Details
Lead Local Flood Authorities (LLFAs) have a duty to maintain a register of structures or features which are considered to have an effect on flood risk, Preparation of an Asset including details on ownership and condition as a minimum. The register must be Register available for inspection and the Secretary of State will be able to make regulations about the content of the register and records. LLFAs, as well as other flood management authorities have powers to Power to designate flood risk designate structures and features that affect flooding or coastal erosion in order to management structures safeguard assets that are relied upon for flood or coastal erosion risk management.
LLFAs have a duty to co-ordinate the investigation and recording of significant flood events within their area. This duty includes identifying which authorities have Investigation of flood incidents flood risk management functions and what they have done or intend to do with respect to the incident, notifying risk management authorities where necessary and publishing the results of any investigations carried out.
LLFAs are required to develop, maintain, apply and monitor a local strategy for Prepare a Local Strategy for flood risk management in its area. The local strategy will build upon information Flood Risk Management such as national risk assessments and will use consistent risk based approaches across different local authority areas and catchments.
LLFAs are designated the SuDS Approving Body (SAB) for any new drainage SuDS Approval Body system, and therefore must approve, adopt and maintain any new sustainable drainage systems (SuDS) within their area.
LLFAs have powers to undertake works to manage flood risk from surface runoff Works powers under Land and groundwater, consistent with the local flood risk management strategy for the Drainage Act area.
Consenting changes to If riparian owners wish to culvert an ordinary water course or insert any Ordinary Watercourses obstructions, consent is required from the LLFA.This duty commenced 6th April
2012.
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3.4.1 Responsibilities for the preparation of Asset Register
The City and County of Swansea has a duty to maintain an Asset Register which identifies those assets which are important to Flood Risk Management and are considered to have an effect on flood risk.
Examples are a headwall on a watercourse which needs regular maintenance to prevent debris on the protection grids from blocking the watercourse, or an undersized culvert in a residential area, which may increase flood risk during high rainfall.
The Authority is required to ensure there are records of all significant assets available for use by risk management authorities and for inspection by the public at all reasonable times. It will take many years before this register is sufficiently comprehensive to be of real value in flood risk management. Progress is however being made to develop the Asset register initially by including all council owned assets.
The process will be developed over a number of years as more information is gathered and as the Authority investigates floods and the sources of flooding.
The Asset Register will identify responsibility of flood risk structures, which will assist in providing readily available information to the residents of the City and County of Swansea and will enable the Authority to contact the assets’ owners when there are problems.
There are no set criteria for an asset to be classed as significant but the most important consideration is its location. Flood risk mapping and flood history at a site will be used to analyse the ‘significance’ of each flood risk asset. The vulnerability of the asset’s surroundings will also be used to determine the consequences of its failure.
New sustainable drainage assets will be recorded via the SuDS approval process and asset data may also be captured through local studies, such as Surface Water Management Plans and flood investigations.
3.4.2 Power to designate flood risk management structures
The City and County of Swansea may designate features or structures that are privately owned and maintained but which make a contribution to the flood and coastal risk management of people and property at particular locations. There are four conditions that must be satisfied to enable a structure or feature (natural or manmade) to be designated. These are:
Condition Condition 1 that the designating authority thinks the existence of the structure or feature affects a flood or coastal erosion (or both) risk Condition 2 that the designating authority has flood or coastal erosion risk . management functions in respect of the risk being affected
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Condition 3 that the structure or feature is not already designated by another designating authority.
Condition 4 that the owner of the structure or feature is not a designating authority .
If an asset becomes ‘designated’ the owner cannot alter or remove it without first consulting and obtain an agreement from the Lead Local Flood Authority. The designation of structures will depend upon the critical importance of such structure with regard to flood risk management and will be undertaken at the discretion of this Authority. . 3.4.3 Responsibility to investigate and record flood incidents
The City and County of Swansea will record flooding incidents which will provide an overall assessment on the areas prone to flooding. The decision to investigate flooding incidents will depend on the seriousness of the consequences of such flooding with the understanding that not all flooding incidents will be investigated. The criteria for investigation:-
• Risk to life as a result of flooding • Internal flooding to property and business • Where critical infrastructure (schools, hospitals, power stations etc) is affected • When Major transport routes are flooded which could affect local communities
The aim of the flood investigation report is to provide essential information on the source of the flooding, ownership details on the assets which have caused the flooding and will lead into the development of solutions for future planning. The investigation will not guarantee that the flooding can be solved and cannot force the provision of a solution.
However the process will inform flood plans by 2015, so that clear objectives and targets can be set for the delivery of flood risk management schemes in a transparent way.
3.4.4 Responsibility to prepare a Local Strategy for Flood Risk Management
The Local Flood Risk Management Strategy will be a statutory document; which will affect the activities of all flood risk management authorities – i.e. local authorities, the Environmental Agency, highways authorities and Welsh Water and other risk management authorities.
The Flood and Water Management Act requires that City and County of Swansea to take a leading role in managing local flood risks, working in partnership with other relevant authorities and the public.
The City and County of Swansea Flood Risk Management Partnership is made up of key management authorities, is fundamental to the delivery of a
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3.4.5 In performing the SuDS Approval Body (SAB) role
The Flood and Water Management Act 2010 assigns City and County of Swansea the role of a SuDS Approval Body (SAB) which must approve all Sustainable Drainage Schemes for developments prior to granting of planning permission. The Authority will effectively be required to adopt all SuDS Schemes which serve more than one property.
The implementation of Sustainable Drainage Systems (SuDS) will be an effective tool in limiting surface water from developed areas and will ensure that drainage discharge rates will be similar to ‘greenfield run-off’ rates for post development sites. This will be a fundamental mechanism in controlling flows so that downstream areas are not affected by increased flood risk as the result of those new developments. They also provide an opportunity to ensure that water quality and amenity are considered with the same importance as managing volumes of water. In this respect, sustainability and consideration of biodiversity and natural habitat issues can become an integral part of the design and development process.
The anticipated commencement date for this part of the Act is April 2013 at which time Lead Local Flood Authorities will commence the SAB role. LLFAs will use national guidelines and processes to approve and to adopt sustainable drainage systems and will be an integrated part of the Planning Process.
3.4.6 Responsibility under the Land Drainage Act
The City and County of Swansea have discretionary powers under the Land Drainage Act. These powers are permissive powers, which can be employed if considered necessary, though there is no obligation to use them. These powers include:
• Permissive powers to maintain or improve existing works or to construct new works in order to help mitigate the effects of flooding.
• Permissive powers to serve notice requiring the undertaking of necessary works. Failure to comply with such a notice may result in the Council undertaking the work and recharging the owner the costs of so doing
• Power to require works to maintain flow of watercourses. Under section 26, before exercising this power, the local authority shall, according to whether or not the watercourse or part of it is in an internal drainage district, notify the Environment Agency.
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3.4.7 Consenting and Enforcement of works undertaken on Ordinary Watercourses
From 6 April 2012 the City and County became responsible for the issuing of Ordinary Watercourse consents for works to ordinary watercourses (streams and ditches both natural and man made and culverts etc) or taking enforcement action for any breaches. Any works which are deemed to affect the natural flow will need to be consented by the Authority.
City and County of Swansea will take a risk-based approach to enforcement where unconsented works have been carried out on ordinary watercourses. The purpose of ordinary watercourse regulation is to control certain activities that might have an adverse flooding impact
3.4.8 Responsibility to Emergency Planning
Emergency planning in City and County of Swansea is undertaken by the Joint Resilience Unit (JRU), involving the City & County of Swansea and Neath Port Talbot County Borough Council. The JRU works closely with the emergency services and other relevant bodies in the event of flood emergencies, assisting as appropriate in evacuation, rescue and recovery after a flood. It supports the efficient delivery of civil preparedness and business continuity services. The unit, with staff based in the Quays, Neath Port Talbot County Borough Council, provides subject matter expertise to enable both councils to meet their statutory responsibilities:
• Assess risks in each administrative boundary in accordance with lead responsibility and coordinate local authority input to Community Risk Register. • Develop Emergency Plans in accordance with lead responsibility. • Develop local authority Business Continuity Management arrangements. • Develop arrangements for Civil Preparedness information available for public use. • Maintain system for warning, informing and advising public in event of an emergency. • Share information with other responders . • Co-operate with other emergency responders to enhance co-operation and efficiency. • Provide advice and assistance to businesses and voluntary organisations about business continuity management .
The Joint Resilience Unit will co-ordinate the cross-cutting Local Authority response in the first instance and liaise with partner agencies. Responsibilities will be implemented as described in City & County of Swansea’s Major Incident Plan and controlled and co-ordinated through the Emergency Control Centre Arrangements, The City and County of Swansea will provide:-
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• Representatives to support Police arrangements for control and co- ordination of the response, ie, to multi-agency Bronze, Silver & Gold controls. • Rest centres and emergency care for those who have been evacuated from their homes, including provision of temporary accommodation their feeding and welfare. • Traffic management – closure of roads affected by flooding or damaged by flooding. Erection of warning and diversion signs as appropriate. • Information services for liaison with the media regarding the local authority response and for information to the public and relatives/friends of evacuees. • Control and co-ordination of the various elements of Local Authority services response to the flood incident, including offers of assistance from the voluntary sector, through the Joint Resilience Unit or activation of CCS’s Emergency Control Centre at the Civic Centre, if required. • In the event that roads not managed by the South Wales Trunk Roads Agency are flooded, arrange to release the floodwater if it is possible and safe to do so. Where this is not possible warning signs will be erected.
3.4.9 Responsibility as Highways Authority
Under the Highways Act 1980, the Highways Authority has a duty to maintain the highway. This includes ensuring that highway drainage systems are clear and that blockages on the highway are cleared, where reasonably practicable. As part of this duty, roads are regularly inspected and maintained .
Highway Authorities have certain powers to deliver works
• Highways Authorities are able to adopt SuDS that serve the highways. • The highway authority can deliver works that they consider necessary to protect the highway from flooding. These can be on the highway or on land which has been acquired by the highway authority in the exercise of highway land acquisition powers for that purpose . • Highway Authorities may divert parts of a watercourse or carry out any other works on any form of watercourse if it is necessary for the construction, improvement or alteration of the highway or provides a new means of access to any premises from a highway .
In the event of an emergency or major flooding incident the City and County of Swansea will aim to provide assistance in management of the transportation network to restore the flow of traffic in the event of an evacuation or away from the area of an incident. This includes providing equipment such as barriers, cones and signs and setting up and marking route diversions (service provided by Contractors in conjunction with the Police) and changing traffic signal controls to improve the flow of traffic
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The City and County of Swansea will use established media contacts to keep staff and the public across the County informed on travel related matters.
The City and County of Swansea will inspect, repair or clear the highway network through the provision of staff, materials and equipment sourced through contractors.
3.4.10 Responsibilities as Planning Authority
The Authority’s Planning function affects Flood Risk Management in three key ways:
• Considering flooding concerns in developing the Local Development Plan(LDP) • Working alongside developers and the SuDS Approval Body in ensuring that planning applications and drainage applications are complementary • Considering flood risk assessments submitted in support of applications on which the Environment Agency do not require to be consulted
The Planning and Compulsory Purchase Act 2004 requires Local Planning Authorities (LPAs) to produce a Local Development Plan (LDPs) that will replace the Unitary Development Plan. The Act requires all LDPs to undergo a Sustainability Appraisal, which assists LPAs in ensuring that their policies fulfil the principles of sustainability. Strategic Flood Consequence Assessments should be used to inform the Sustainability Appraisal and the LDP process, to ensure that proposed developments are steered towards the lowest flood risk zones and will not create a legacy of problems for future generations.
LDPs must consider flood and coastal erosion risks. Planning Policy Wales (PPW) provides national planning guidance , including on minimising and managing flood risk.PPW is supplemented with Technical Advice Notes(Tans), of which TAN15: Development and Flood Risk provides guidance in relation to flooding.LPAs should take into account the guidance provided in PPW and TAN15 when preparing their LDPs and when assessing individual planning applications. A precautionary approach is advocated. TAN15 utilises Development Advice Maps (DAMS) to identify where and when flood risk issues should be taken into account within the development planning process. The DAMS take into account of fluvial and tidal flooding within the City and County of Swansea. ithin the precautionary framework
Local Planning Authorities should develop a Local Development Plan that carefully considers flood and coastal erosion risks. This is a statutory planning document which planners can then use to identify inappropriate development in the floodplain. Consequently the LDP should embed the Strategic Flood Consequence Assessment (SFCA), the Preliminary Flood Risk Assessment and Surface Water Management Plan (where applicable). This should allow the LDF to assess and record the flood risks for new developments and steer development to areas of lowest flood risk. Equally in maritime districts, there is
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The Planning Authority has a key role in encouraging the use of Sustainable Drainage Systems, such as rainwater harvesting systems, and will be required to work closely with the SuDS Approving Body to ensure that planning applications and drainage application are received, processed and approved in accordance with the new regulations.
3.4.11 Responsibility with Public Open Spaces
City and County of Swansea is responsible for maintenance of some parks and public spaces and has responsibility for street cleaning. Good maintenance practices can help to reduce flood risk, for instance by ensuring that drainage channels are kept clear and that rubbish and leaves are not tidied into watercourses. For new public spaces which are under the control of a management company, these maintenance activities and practices should be included in the management contract.
The Authority may also be riparian owners of both ordinary and main watercourses and as such should carry out the duties imposed on riparian owners by the Land Drainage Act. They should maintain all assets in their ownership .
3.4.12 Responsibility as Coastal Erosion Risk Management Authority
The City and County of Swansea are one of the coastal erosion risk management authorities. Responsibilities include:- :-
• Shoreline Management Planning in conjunction with the Environment Agency. • Delivery of coastal erosion risk management activities. • Working alongside the Environment Agency to develop and maintain coastal flood and erosion risk information. • Maintaining a register of assets and other features that help to manage coastal risks. • Implementing, managing, maintaining and monitoring shoreline management plans to understand and manage coastal flood and erosion risks. • Assisting communities in planning for the future and taking appropriate steps to adapt to changing coastal erosion risks.
3.4.13 Contribution to Sustainable Development
In exercising a flood or coastal erosion risk management function, the Authority will aim to make a contribution towards the achievement of sustainable development. Sustainable development is about making the best
Drainage and Coastal Management Section February 2013 20 Local Flood Risk Management Strategy ______use of resources to improve our quality of life without damaging the resources or quality of life for future generations.
This requirement is provided under Section 27 of the Act, which also provides that Welsh Ministers must issue guidance providing a definition of what ‘sustainable development’ means and how LLFA should discharge this duty.
This guidance will be issued directly to LLFA within Wales and is also available from the Welsh Government website. The Welsh Government is one of only a few governments to have a legal duty to secure sustainable development and so have made this their central organising principle. The Welsh Government aims to move towards sustainable development by:
• improving the economy, and social and environmental wellbeing of people and communities - achieving a better quality of life now and for future generations; • promoting fair and safe communities and equal opportunities; and • supporting natural and cultural environments and respecting their limits - by using only a fair share of resources and sustaining the cultural legacy.
3.5 Responsibilities of other Flood Risk Management Authorities
Powers and Responsibilities of the Environment Agency
Historically the Environment Agency has led on the management of the risks of flooding from main rivers and the sea. However, as a consequence of the Flood and Water Management Act 2010 certain changes have been made to the role and remit of the Environment Agency. In addition to flooding from rivers, sea and reservoirs, the Environment Agency has new operational responsibilities in relation to coastal erosion and a wider oversight role for all flood and coastal erosion risk management in Wales.
This change means that the Environment Agency has a dual role:
• operational responsibilities for flooding from main rivers, the sea and coastal erosion; • oversight responsibilities in relation to all flood and coastal erosion risk management in Wales. • National Strategic Role The Environment Agency provides a national framework for all forms of flood and coastal erosion risk management. It aims to deliver a risk-based approach whilst allowing local responsibility and decision-making where appropriate. Like the local strategy, it looks to define and understand the roles and responsibilities of risk management authorities and to provide information to communities at risk.
The National Strategy identifies the following strategic actions for the Environment Agency:
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• Use strategic plans like the Catchment Flood Management Plan and the Shoreline Management Plans to set the direction for Flood and Coastal Erosion Risk Management • Support the creation of Flood Risk Regulations reports by collating and reviewing the assessments, plans and maps that Lead Local Flood Authorities produce. • Providing the data, information and tools to inform government policy and aid risk management authorities in delivering their responsibilities • Support collaboration, knowledge-building and sharing of good practice including provision of capacity-building schemes such as trainee schemes and officer training. • Manage the Regional Flood and Coastal Committees (RFCCs) and support their decisions in allocating funding for flood defence and flood resilience schemes. • Report and monitor on flood and coastal erosion risk management. • Provide grants to risk management authorities to support the implementation of their incidental flooding and environmental powers.
Local Operational Role
The Environment Agency’s Local Operational Role includes having a role in incident planning and managing flooding from main rivers, reservoirs and the sea.
Main Rivers
Main Rivers are watercourses shown on the Environment Agency's statutory Main River map. The Environment Agency has permissive powers to carry out works of maintenance and improvement on Main Rivers. This can include any structure or appliance for controlling or regulating flow of water into or out of the channel. The overall responsibility for maintenance of Main Rivers, however, lies with the riparian owner. The Environment Agency can also bring forward flood defence schemes through the Regional Flood and Coastal Committees, and it will work with lead local flood authorities and local communities to shape schemes which respond to local priorities.
Coastal Flooding
The Environment Agency is the lead organisation responsible for all flood and erosion risk management around the coastline of Wales, including tidal flood risk. The Environment Agency contribute in the development of Shoreline Management Plans and works with partner organisations, including local authorities to put them into practical action. The Environment Agency supports this by giving grant funding for coastal defence schemes and overseeing the work carried out.
Reservoirs
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The Environment Agency enforces the Reservoirs Act 1975, which is the safety legislation for reservoirs in the United Kingdom. As Enforcement Authority the Environment Agency must ensure flood plans are produced for specified reservoirs. However responsibility for carrying out work to manage reservoir safety lies with the reservoir owner/operator who should produce the flood plans. The Environment Agency is also responsible for establishing and maintaining a register of reservoirs, and making this information available to the public.
Coastal Erosion Risk Management Authority
The Environment Agency is a coastal erosion risk management authority with the power to protect land against coastal erosion and to control third party activities on the coast. This includes the construction of private defences and the removal of beach material.
Emergency Planning The Environment Agency contributes to the development of multi-agency flood plans, which are developed by local resilience forums to help the organisations involved in responding to a flood to work better together. It works with the Met Office to provide forecasts and warnings of flooding from rivers and the sea in England and Wales. The Environment Agency and other asset operating authorities also have a role in proactive operational management of their assets and systems to reduce risk during a flood incident.
Planning process
The Environment Agency has an active role in being a statutory consultee throughout the planning process to ensure new developments have due regard to flood risk and do not cause unnecessary environmental damage.
It is also responsible for providing advice to planning authorities in development and flood risk; providing fluvial and coastal flood warnings; monitoring flood and coastal erosion risks and supporting emergency responders when floods occur.
Natural Resources Wales
The Welsh Government is currently reviewing the role of the environmental public bodies operating in Wales; primarily the Environment Agency , the Countryside Council for Wales and the Forestry Commission. It is proposed that these bodies, insofar as they operate in Wales, are merged and that a Natural Resources for Wales is established.
This Single Body would take on the functions of these three organisations, including all of the responsibilities of the Environment Agency in relation to flood and coastal erosion risk management in Wales, and it would undertake all of the functions described within the National Strategy.
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Responsibilities of Water and Sewerage Companies
Dwr Cymru / Welsh Water are responsible not only for the provision of water, but also for making appropriate arrangements for the drainage of foul water, the treatment of waste, surface water sewers and combined sewers. They have primary responsibility for floods from water and sewerage systems, which can include sewer flooding, burst pipes or water mains or floods caused by system failures.
No changes have been made to the operational arrangements for water and sewerage companies in respect of flood risk. The majority of flooding is reported into 24 hour operational call centre on 0800 0853968. The call centre agent will check that the flooding incident involves their asset.
The Flood and Water Management Act 2010 places a number of statutory duties on Water and sewerage companies including:
• a duty to act consistently with the National Strategy; • a duty to have regard to the content of the relevant Local Strategy; and • co-operation with other Authorities, including sharing data.
Water and sewerage companies often hold valuable information which could greatly aid the understanding of flood risks faced by communities across Wales. Water and sewerage companies will also need to contribute to the preparation of the Local Strategies prepared by LLFAs.
All water and sewerage companies maintain a register of properties at risk of flooding due to a hydraulic overload in the sewerage network, known as the (DG2 – DG9) used to monitor company performance .
As part of their obligation to Ofwat, water and sewage companies are required to undertake capacity improvements to alleviate sewer flooding problems on the DG5 register during the current Asset Management Period (2010-15) with priority being given to more frequent internal flooding problems. It is important to identify solutions that are robust and cost beneficial.
Under current legislation, foul and surface water drainage from new developments can be connected to public sewers and a water company has no powers to prevent new connections to its network, even if it could cause flooding to customers. Welsh Water does comment on planning applications but they are not considered a statutory consultee.
This will change once the relevant section of the Flood and Water Management Act is commenced, when a connection to a public sewer will be permitted only after the drainage strategy associated with a new development is approved by the Suds Approving Body to which Welsh Water will be a Statutory Consultee. This will only apply to surface water connections to their
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Other Key Stakeholders
Responsibilities of Mid Wales Fire and Rescue Service
The primary response:- • Life saving through search and rescue. • Rendering humanitarian services. • Safety management within the inner cordon (rescue zone).
May also assist with:-
• Salvage and damage control. • The provision and use of specialist equipment and personnel, e.g. high velocity pumps, rescue equipment, inshore boats and lighting
Responsibility of Riparian Ownership
Landowners, householders and businesses whose property is adjacent to a river or stream or ditch are likely to be riparian owners with responsibilities. If a property backs out onto a river or stream then the property owner is likely to be a riparian owner, owning the land up to the centre of the watercourse. The Land Registry details should confirm this.
Riparian owners have a right to protect their property from flooding and erosion but in most case will need to discuss the method of doing this with the Environment Agency or the Lead Local Flood Authority. They also have responsibility for maintaining the bed and banks of the watercourse and ensuring there is no obstruction, diversion or pollution to the flow of the watercourse. Full details can be found in the EA document ‘Living on the edge’.
Responsibilities of Communities
Flooding events can affect whole communities, with households not suffering from internal flooding still potentially being trapped as roads are blocked. They may also offer support or provide shelter to neighbours who have suffered from flooding.
Communities know better than anyone the level of flood risk that they face and can make important contributions to helping manage the levels of flood risk. Local Councillors and Community Councillors have a key role in helping the community councils and communities understand their role and ensuring affected communities are properly represented in discussions about local activities
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Property Owners and Residents
It is the responsibility of householders and businesses to look after their property, including protecting it from flooding. While in some circumstances other organisations or property owners may be liable due to neglect of their own responsibilities, there will be many occasions when flooding occurs despite all parties meeting their responsibilities. Consequently it is important that householders, whose homes are at risk of flooding, take steps to ensure that their house is protected. These steps include:
• checking whether their household is at risk from flooding from the river, coast or local flood sources • ensuring that preparations have been made in the event of a flood • taking measures to ensure that their house is protected from flooding, either through permanent measures such as sealants in the wall or temporary measures such as flood guards • taking measures to make sure the house is resilient to flooding so that if it does occur it does not cause too much damage • where possible, taking out flood insurance.
Information on whether households are at risk is provided by the Environment Agency.
4.0 Assessment of Local Flood Risk
Unlike areas of the United Kingdom which have experienced significant flooding events such as the Gloucestershire 2007 Summer Floods, there have been few recent major flooding events caused by fluvial or surface water. This does not mean severe incidents will never occur. Localised floods will continue to occur in many areas of the county under severe weather conditions and climate change is likely to make them more frequent and more severe. The aim is to try to predict and reduce the risks where possible and have emergency plans in place to deal with the exceptionally severe event. Unlike a tidal surge, flooding caused by localised rainfall is much harder to predict.
An early task will be to review the historic flooding information held to identify locations where flood mitigation measures could be implemented. Property flood protection such as flood doors and air brick covers can, in appropriate situations, provide very effective resistance to flooding at minimal cost
4.1 Historical Flooding
The history of flooding in the City and County of Swansea indicates the following sources:-
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a) Surface water flooding b) Groundwater Flooding c) Sewer Flooding d) Ordinary Watercourse flooding e) Interaction with Main Rivers and Sea
While there is good data on past river and sea floods, the information on historical surface water is limited. Available information was collected as part the Authority’s Preliminary Flood Risk Assessment process. Records of flooding from these sources provide the following:- a) Surface Water Flooding
Surface water flooding (also known as pluvial flooding), occurs when heavy rainfall exceeds the capacity of local drainage networks and water flows across the ground. It is usually associated with flash flooding when high intensity rainfall causes insufficient capacity in the local drainage networks and cannot cope with the resultant high flows. This can be exacerbated if ground conditions are worsened by continuous rainfall and resulting in saturated ground conditions. Information on surface water flooding was captured through the day to day recording system held by the Streetscene service. b) Groundwater Flooding
Groundwater flooding occurs when the level of groundwater increases and rises above the level of the ground causing flooding. It is dependant on the underlying geology of an area and occurs following heavy rainfall. c) Sewer Flooding
Modern sewer systems are typically designed to accommodate storm events with a 3.3% annual probability (1 in 30 year return period) and are normally separated into foul and surface water systems. Older sewer systems were designed to convey both foul and surface water flows in combination and these systems were generally designed to a lesser standard. Consequently, it is expected that sewer flooding will occur in some areas of the City and County of Swansea during a storm event which is less severe than a 1 in 30 year event.
Excess surface water entering the drainage network can result in significant harmful consequences and DCWW, the managing operator for the public sewers in the area, was approached in order to provide information on significant flooding events. Registers which record internal flooding to properties (DG5 registers) and details of sewers which have contributed to serious external flooding have been provided and assessed accordingly. There were a total 317 of sewer flooding events which have been recorded by DCWW over the past decade.
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Much of Swansea is serviced by a combined foul/storm drainage system except rural areas of Gower and Mawr, which are serviced in the main by septic tanks.
DCWW has declined to accept storm water from new developments and redevelopment areas in the recent past because the combined sewer networks are close to capacity. The Council, following national planning guidance and technical advice, wishes to encourage the use of Sustainable Drainage Systems (SuDs) in all new developments where suitable.
Interaction with Main Rivers and the Sea
There is insufficient historical flooding data available to draw definitive conclusions at this stage. The main areas where there is possibility of interaction with ordinary watercourses are on the low lying areas around the Swansea Bay area on the Southern Boundary, and Crofty to Pontardulais on the Northern boundary.
Relevant information on past flooding within the County has been obtained from the following:- • Environment Agency • Mid Wales and Fire Rescue Services • Police • Joint Resilience Unit • Community Councils • Welsh Government • Preliminary Flood Risk assessment
Flood records for the whole City and County of Swansea area were collected from the data sources detailed above. The Environment Agency provided information showing locations of historic flooding across the study area. This data, combined with that from highway drainage records of historical flood events and flooding ‘hotspots’, was collated and a summary map produced. The locations of the past flood events is illustrated on the map provided as Figure 1.
The flooding events have been categorised into high, medium or low depending on the level of impact to the local community and frequency of events. The flood incidents can be attributed to a range of sources, and in many cases the source of flooding was unknown or not recorded.
Drainage and Coastal Management Section February 2013 28 Local Flood Risk Management Strategy Appendix A Figure 1 – Map to show Past Flooding Events
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Local Flood Risk Management Strategy Appendix A 4.2 Potential Flood Risk
The objectives of this local strategy are to predict and reduce the risks where possible and to have emergency plans in place to deal with exceptionally severe flooding events. Unlike a tidal surge, flooding caused by localised rainfall is much harder to predict and as yet there are no adequate warnings available to allow evacuation of an area at risk from this sort of event.
It will be important to be able to consider the relative significance of incidents of flooding on a county-wide basis and, alongside this strategy, a flood incident reporting process is being set up. This should permit a better understanding of the main problems and influence the focus of future interventions.
The Preliminary Flood Risk Assessment (PFRA) was carried out by City and County of Swansea Council in accordance with its duties and obligations under the Flood Risk Regulations 2009. The PFRA identified key areas in Swansea where the potential risk of surface water flooding is thought to be greatest.
In terms of predicted flooding, the Authority has accepted the National Surface Water Datasets provided by Environment Agency Wales (EAW) to be the most representative surface water information available to the Authority. The Flood Maps for Surface Water correlate well with local information, indicating that it is suitable to use.
The EAW published a map indicating the Areas Susceptible to Surface Water Flooding (ASTSWF) in 2009, showing flooding typically associated with areas of lower ground, which coincides in many areas with the larger watercourses. There are significant areas potentially susceptible to surface water flooding in the Tawe corridor, such as Morriston and Llansamlet.
Other areas susceptible to flooding are the areas adjacent to the River Loughor and the River Lliw/Llan in and around Pontarddulais, Gowerton and Gorseinon, areas in the southern part of Swansea, such as Blackpill, Sketty, Brynmill, St Helens and the dock areas as well the Crymlyn Bog nature reserve to the north of the docks.
The perceived flood risk is defined as any flood that could potentially occur in the future, which includes predicted floods extrapolated from current conditions, in addition to those with an allowance from climatic change where appropriate. The assessment takes into account the following factors:-
• Topography • Location of Ordinary Watercourse • Location of Flood Plains • Characteristics of Watercourse
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• Effectiveness of previous Flood Alleviation schemes • Location of population areas • Areas where economic activity exists • The current and predicted impact of long term developments that might affect the occurrence or significance of flooding such as proposals for future development.
Future Flooding
Based on current information which was supplied from national datasets the Authority has nearly 4589 properties predicted to be affected from surface water flooding during extreme rainfall events matching a 1 in 200 year rainfall event or a rainfall event with a 0.5percent chance of happening in any given year. This risk is spread across the City and County of Swansea (see Figure 2 below).
The Preliminary Flood Risk Assessment (PFRA) was prepared to satisfy obligations under the Flood Risk Regulations 2009. This work identified key areas in Swansea where the potential risk of surface water flooding.
Extract from the City and County of Swansea PFRA :-
‘Potential flood risk has been identified primarily from national sources. The national sources include a number of different datasets which have been used in the past but the most up to date information to hand is contained in the Flood Map for Surface Water, the second generation in national surface water flood mapping. The Flood Map for Surface Water Fig.2 gives an indication of the areas where surface water would be expected to flow or pond during two different rainfall events 1 in 200 annual chance of occurring and includes a national allowance for drainage capacity in urban areas. The urban underground drainage system would be expected to be removing a proportion of rain falling thus reducing flood volumes apparent on the ground surface. This dataset has been used as the ‘locally agreed surface water information’ defined in the PFRA guidance document.
Drainage and Coastal Management Section February 2013 31 Local Flood Risk Management Strategy Appendix A Figure 2 Surface water Flood Map for Swansea
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Local Flood Risk Management Strategy Appendix A
In order to help prioritise areas where the consequences of flooding are greatest the Environment Agency provided a Flood Map for Surface Water Flooding, which identified individual 1km squares where there is a risk of flooding and where flooding would affect:
• More than 200 people; or • More than 1 Critical Service; or • More than 20 Non-Residential Properties
This exercise identifies 1km squares where there is a risk of flooding (30cm deep water at a 1 in 200 annual probability rainfall) and where the criteria above are met. This provides data which can be used to determine priority and guide resource allocation. Within Swansea where a cluster of the blue grid squares forms an area where flood risk is most concentrated and over 5000 people are affected the area is defined as an Indicative Flood Risk Area Effectively, the City and County of Swansea is one of the eight Authorities in Wales which has been designated has having a Flood Risk Area which requires further assessment.
It is intended that flood risk and hazards maps will be produced for these areas by 2013. These will inform local actions and plans to mitigate the consequences of flooding in these areas.
Potential for Groundwater Flooding
The risk of groundwater flooding within much of South Wales is greatest in areas with significant coal mining. However, the majority of the former coal mining areas within the City and County of Swansea are understood to be fully recovered and therefore are not considered to present a significant risk of flooding.
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Local Flood Risk Management Strategy Appendix A Fig 3 City and County of Swansea Surface Water Risk Map
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Local Flood Risk Management Strategy Appendix A Fig. 4 Potential of Groundwater Flooding
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Local Flood Risk Management Strategy Appendix A 4.3 Interaction actions between different sources of flooding
Whilst the primary focus of this strategy is local flooding (surface, ground and small water courses such as ditches and streams), flooding in the City and County of Swansea can arise from a number of different sources. To members of the public suffering from flooding, the source of the water may seem irrelevant, but for each source there may be a different responsible organisation.
Where the source can be clearly identified, the responsible organisation will be the main point of contact. However, as is often the case, where it is not easy to ascertain the source or where multiple sources are involved, the Lead Local Flood Authority will take the lead and work with partners to investigate and deal with the issue in a manner appropriate to the level of risk.
The flood incident reporting process will have provision within it for the collection of information to enable, where at all possible, the responsible organisation for flooding to be identified. Where the flooding satisfies the criteria for carrying out a full investigation and it has not been possible, based on information obtained through a flood incident report, to establish the source, this would need to be done as part of the full investigation.
The full investigation will take into account of all elements of information such as stakeholders’ historic records, hydraulic model output and information obtained from members of the public at the time of the flooding incident. Community Councils, landowners and the public will be crucial to helping increase knowledge and understanding of localised flooding.
Potential flooding sources and responsible organisations
Flooding Type Description Responsible Authority
Coastal flooding Coastal flooding – Tidal Waters Environment Agency Wales
Ordinary watercourses Local, generally smaller e.g. streams and ditches watercourses Riparian owners
Main rivers Principal watercourses and Environment Agency Wales strategic smaller watercourses
Reservoirs Large water pounds represent a Environment Agency Wales potential flood risk
Surface water flooding High intensity rainfall gives rise City and County of Swansea (Also known as pluvial flooding) to overland flow of surface water which can pond in low lying areas giving rise to flooding.
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The public sewer system has a Dwr Cymru Sewer flooding finite capacity and at times of e.g. public and previously heavy rainfall surface water classified private sewer systems entering designated surface water sewers, combined sewers (ones which receive foul and surface water).
4.4 Prioritisation of Areas across the Authority where Resources will be focused
Each flood risk management authority has resources to manage the flood risk. These resources are limited so it is essential that all possible resources and their locations are recorded and the availability monitored .
The knowledge of potential and known flood risk areas is essential in the prioritisation of resources, as well as the logistical difficulties afforded by flooded areas.
Planned responses have been developed for lesser flooding events. In the event of a major incident all resources will be managed by the Joint Resilience Unit.
Areas where flooding is life threatening will receive the greater priority. Taken into account will be the availability of resources from flood risk management partners who are aware of their responsibilities and the level of risk they face .
Each flooding incident is to be entered into the Incident Database based on the ECINSPIRE Directive 2007/2/EC. To ensure adherence to the principles contained in this Directive of a co-ordinated approach to sharing information, the LLFA will take the lead role with the flood risk management partners. The Directive sets out a common approach to recording and disseminating such information. The information will include listings on a geographical basis (this may be Community Council or Ward-based) and categorised against flooding sources together with all relevant information on the chronology, causes, consequences, costs, the existence of extenuating circumstances and options to resolve the problem together with associated costs.
As it is not feasible to look in detail at every potential flooding location straight away, a preliminary sift of information on each incident should be undertaken and those thought worthy of further consideration should be subject to a Preliminary Flood Study. In addition to the information required for flood incident reporting, an outline cost benefit analysis (COBA) on each likely solution would enable a list of priorities to be established and decisions made on projects to proceed to Project Appraisal Report Stage, or retention within a listing of non-priority projects.
A study of potential projects may reveal geographic clusters of projects, where interventions will derive the maximum benefit in terms of overall flood risk reduction. In this case, and in order to help prioritise areas where the consequences of flooding are greatest, the information from the Flood Map for Surface Water can be applied.
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A programme of works can then be developed in line with available financial and manpower resources.
The resources to manage flood risk are limited and it is therefore necessary to prioritise. Locations exhibiting flooding clusters in the Surface Water Flood Risk Map (Figure 3) provide one indication of priority, though there are other key factors which will have influence resource allocation:-
Population concentration - the main aim of the strategy is to reduce flood risk for the greatest number of CCS residents and to also take into consideration the impacts it has to the most vulnerable.
Proposed development activity - this will give rise to the consideration of drainage arrangements/opportunities in particular areas which might offer a way of reducing existing flood risks.
Locations for capital investment - any capital project might offer opportunities for flood risk reduction through modification of construction proposals. Conversely, where specific flood defence investment is being made there maybe opportunities to modify the project to provide wider benefits to other stakeholders thus encouraging additional investment.
The location of static and touring caravan sites (because of their particular vulnerability).
Historic surface water flooding - whilst the current information is limited and doesn’t provide much insight into significance this aspect will become increasingly relevant following the implementation of the flood incident reporting process. Groundwater flooding . Main River flooding - Information on Main River flooding is derived from the Environment Agency ‘Flood Map’ and is considered in detail in the Catchment Flood Management Plans covering City and County of Swansea. Tidal flooding - Information on tidal flooding is derived from the Environment Agency ‘Flood Map’ and is considered in detail in the Shoreline Management Plans. Ordinary watercourse flooding - There is currently limited data available on this and, like surface water flooding, will benefit from future records of local flooding incidents. Dŵr Cymru Welsh Water records of sewer flooding – Water Companies provide information to Ofwat on flooding experienced on the public sewerage network, referred to as DG 5 information. D ŵr Cymru Welsh Water's investment in reducing flooding from the public sewerage network is focussed on historic flooding locations. Environmentally protected sites, historic buildings and monuments - National datasets are available which provide the location of structures and sites which are vulnerable to flood damage. It is worth noting that flooding is not always detrimental to environmental sites.
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The next stage is to undertake more detailed surface water management plans for these areas. These will provide the means of investigating in more detail the locations at risk within these areas, the reasons why they are at risk and whether there is a sustainable, cost-effective means of reducing the risk – either in the short or longer term. The level of investigation will be appropriate to the perceived risk and will follow the national guidelines for undertaking flood risk management plans.
Factors Increasing Flood Risk
Flood risk can be defined as a combination of probability and consequence: as there are a number of factors which lead to higher probability of flooding in the future and more serious potential consequences , this will result in an increase in flood risk across Swansea as stated below:-
• Climate Change – It is generally accepted that climate change will lead to more frequent and more extreme weather patterns, together with increases in sea levels which will increase the level of all types of flooding. • Deterioration of existing assets in terms of condition and hydraulic performance will inevitably lead to increased flood risk. • The need to control surface water run-off from new developments will need to be continued. However, there are instances where an increase in the amount of impermeable surfaces and increased run-off will be inevitable and this will result in an increase in peak flows during heavy rainfall events.
Long term developments It is possible that long term developments might affect the occurrence and significance of flooding. However, current planning policy aims to prevent new development from increasing flood risk.
In Wales, Technical Advice Note 15 (TAN15) on development and flood risk sets out a precautionary framework to guide planning decisions. The overarching aim of the precautionary framework is “to direct new developments away from those areas which are at high risk of flooding”. Adherence to Government policy ensures that new development does not increase local flood risk. However, in exceptional circumstances the Local Planning Authority may accept that flood risk can be increased contrary to Government policy, usually because of the wider benefits of a new or proposed major development. Any exceptions would not be expected to increase risk to levels which are “significant” (using the Government’s criteria).
4.5 Local Plans
Catchment Flood Management Plans
There are a number of plans which contain useful information relating to local flood risk and were used in the production of the report. Catchment Flood Management Plans (CFMPs) are non statutory plans produced by the Environment Agency to provide an overview of flood risk across each river catchment. These also recommend ways of managing risk from all types of inland flooding now and over the next 50-100 years.
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There are two catchments plans covering the river catchments across the City and County of Swansea :-
• Ogmore to Tawe • Loughor to Taf
The plans identify flood risk from fluvial and tidal-influenced river flooding from past flooding events and potential risk in the future, although localised flooding problems from surface water flooding, sewer flooding etc have been identified albeit to a lesser degree. Full details of these risks can be found in the plans but a summary of collated data over both catchments which affect people is illustrated in the table below:-
Catchment Flood Management Plans covering Swansea showing probability of flooding - 1% Annual Equivalent Probability Fluvial Event or 0.5%AEP Tidal Event
Area at Risk Number of Number of CFMP Plan People at Risk People at Risk - Predicted in 2100 Pontarddulais 49 129 Loughor to Taf Gorseinon 2 93 Loughor to Taf Gower 81 160 Loughor to Taf Swansea Vale 465 768 Ogmore to Tawe Swansea Central 5527 5693 Ogmore to Tawe
Catchment Flood Management Plans identify flood risk management policies to assist all key decision makers in the catchment, to ensure sustainable flood risk management for the long term.
Shoreline Management Plan 2 --– identifies policy areas affecting CCS
Shoreline Management Plans are strategic plans for the long term management of the coast. The City and County of Swansea section of shoreline forms part of the SMP2 that considers the South Wales shoreline from Penarth in The Vale of Glamorgan to St Anne’s Head in Pembrokeshire. This Plan identifies areas at risk of flooding directly from the sea. The CCS coastline falls within Policy Scenario 9 of SMP2 and the following policies are proposed:-
• Hold the line of the shoreline through the maintenance and upgrading of existing defences.
• Allow the sand dune systems to continue to evolve naturally by managed realignment.
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Some frontages are currently undefended and the coast will evolve and retreat through no active intervention
• 5.0 Objectives for managing flood risks and options to achieve them
This Chapter sets out the primary objectives and actions which will be taken forward to make progress in the reduction of risk associated with flooding. The overarching aim is to work with the population of City and County of Swansea to reduce the risk to residents and businesses of suffering the misery and economic devastation that flooding can bring.
The ways of achieving this are summarised in the following table and developed in the following sections.
No Objective Actions to achieve the Objective 1 To commit to the • To provide a clear explanation of the specific statutory understanding of Flood and duties of other flood risk management Authorities with Coastal risks and to ensure the administrative area of the City and County of that all stakeholders Swansea. understand their roles and • To involve property owners and communities who are responsibilities in relation to affected by flooding incidents and allowing them to Flood and Coastal risk take on responsibilities which will assist in the management protection of the affected community. • To increase flood risk awareness and provide a clear steer on roles and responsibilities by increasing access to public websites and production of flood leaflets and other available means. • To record flooding related incidents and to investigate flooding incidents if considered significant. • To develop a consistent approach to designation of structures important to flood risk management • Promote local resilience groups and provide support to ensure proper guidance. • To ensure joint working partnership with other flood risk management authorities and to share information for the benefit of all parties. • To work with Joint Resilience Unit
2 To work together with other • To continue with partnership working. flood risk management • Develop investment plans for flood risk schemes Authorities to reduce flood which could be jointly funded. risk, using all available • Ensure that consideration is given to achieving short resources and funds in an term flood risk improvements where local partners integrated way and in so wish to contribute, alongside a commitment to doing derive overall benefit. understanding future risks • Promote cost effective flood protection measures such as individual property protection and local action groups. • Carry out a review of resources and skills available and tasks that are required by the different organisations to identify the best model for delivery of the new responsibilities alongside existing flood and
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coastal risk management activities. 3 Develop policies for effective • Ensure that the Planning process is properly informed land use and management by considering relevant plans and policies such as and enhance development Catchment Flood Management Plans and Shoreline control procedures. Management Plans. Avoidance of development in • To work closely with Suds Approval Body when flood risk areas. To prevent formed and to encourage the use of Sustainable an increase in flood risk as a Drainage Systems result of development by • Planning Policy to take into account TAN15 which preventing additional flow relates to flood risk areas. entering existing drainage • To prepare and maintain a database of historic and systems and watercourses predicted local flood risk to provide data for the whenever possible Planning Authority. • Consult with Environment Agency(Natural Resources Wales), Welsh Water and other key stakeholders.
4 Established regular • Develop and promote clear process for consenting of maintenance schedules for new structures to safeguard future maintenance of flood and coastal erosion risk privately owned structures management assets • To regulate ordinary watercourses and to enforce powers to maintain a free passage of flow. • Ensure riparian owners are aware of their duties for watercourse and culverts on privately owned land. • To improve the database on all assets which are important to flood risk management and to collect data on such assets when possible. 5 Raising awareness of and • Implement a raising awareness action plan to flood engaging people in response affected communities to flood and coastal erosion • Actively engage communities risk • Actively communicate current and future risk to local communities 6 Enhance property and • Increasing flood resilience will reduce damages community level of resilience caused by any water that gets into a property. This measure will attempt to raise awareness of the techniques that could be utilised when repairing properties subject to repeated flooding in order to reduce future damages. Initial awareness campaigns will be targeted at areas identified as being at high risk of surface water flooding from surface water flood modelling • Ensure that emergency plans are prepared at local levels as required and that response to and recovery from flooding incidents is effective 7 Take a sustainable and • To consider the wider environmental benefits in the holistic approach to flood and design and construction of projects coastal management, seeking • Reduce impacts on protected environments. to deliver wider environmental • Promote the concept of water cycle management and and social benefits. blue corridors/green infrastructure. • Consideration to given relevant plans and policies e.g WFD, SMPs, SFRA and CFMPs • Maintain or where possible improve the status of SSSI’s, SACs, SPAs, Ramsar sites and other sites of importance for nature and conservation • Maintain and enhance the natural heritage. 8 Prioritising investment in the • To consider the balance of the frequency of flooding most at risk communities incidents and the extent of damage against the consequence of flooding looking at cost/benefit ratios for the promotion of flood alleviation schemes
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• To investigate and implement quick fix solutions if considered economically sound • To provide a transparent priority system which can inform allocation of funding • To build up community resilience if considered an appropriate alterative measure.
5.1 Understanding Local Flood Risk
One of the key findings of the Pitt Report into the causes of the 2007 floods was that there was insufficient understanding about the nature of flooding in most parts of the country. This broadly applies within the City and County of Swansea where there is sometimes uncertainty as to the causes of flooding and a lack of clarity in the responsibility for dealing with such incidents .
This report has outlined the roles and responsibilities of the various flood risk management authorities and other stakeholders, as well defining what riparian owners, the public and businesses can do to contribute. Stakeholders can be defined as anyone who may be affected by the problem or solution or will be interested in the problem or solution. They can be individuals or organisations and include the public and communities.
It is only through a better understanding of where the greatest local flood risks are, what their causes are and who will need to be involved in the solution that it will be possible to accurately identify and assess feasible measures that could be implemented to reduce the risk of flooding in locally important flood risk areas .
5.2 To Record Flooding Incidents
Historically, data collection of flooding incidents for recording local flood incidents within Swansea contained anecdotal information and lacked the detail required to assess the causes of a flooding incident. As a consequence of the new duties imposed on LLFAs to record flooding incidents, a new database has been created to collect data specifically about flood incidents. This will provide an overall picture of the extent and frequency of flooding incidents and will be used to inform the Flood Risk Management Plan. This approach will be effective only if all risk management authorities commit to reporting all incidents of local flooding.
5.3 To develop a Collaborative and integrated Approach to Flood Risk Management .
The City and County of Swansea, working with the Neath Port Talbot Flood Group, identifies and reacts to ‘significant’ flooding. At a local level collaborative work with other flood risk management authorities will identify relevant schemes which may, in some instances, identify possibilities of sharing funding.
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5.4 To involve Community Engagement
The aims of this should tie in with the aims and objectives of City and County of Swansea Communications Strategy, but the overarching objective would be increasing knowledge and understanding of flooding and flood risk and informing residents how they can contribute to the effective management of flood risk. This follows one of the overall objectives of the local strategy of ensuring communities are aware of the level of risk that they face and the steps they need to take to manage the risk and also ties in with the objectives of the national strategy.
The allocation of responsibility for local flood risks is replicated in the Flood Risk Regulations 2009. These Regulations make the LLFA responsible for conducting assessments in relation to and mapping and planning (for flood risk areas identified in the assessment) for the risks of flooding from everything other than main rivers, the sea and reservoirs. A number of Local Authorities in Wales are also designated coastal erosion risk management authorities under the Coast Protection Act 1949, providing them with certain responsibilities in respect of coastal erosion and coastal protection.
Formally referred to as Coastal Protection Authorities they may also be referred to as Coastal Local Authorities or Maritime Authorities and they retain their current permissive powers in relation to coastal erosion risk management.
5.5 Ensure planning decisions are properly informed by flood risk and that there is a consistent approach to flood risk management in new development
It is necessary that the evidence base used to inform planning decisions is consistent and kept up-to-date. The LLFA is required to develop a system for reporting and recording local flood events and the asset register, and ensuring this is readily available to all who need to see it.
The Environment Agency continues to develop and publish flood and coastal erosion maps http://maps.environment-agency.gov.uk/wiyby/wiybyController?ep=maptopics&lang=_e
5.6 The adoption of a holistic approach to flood and coastal risk management
Owing to climate change, on occasion there is less water than is necessary for human consumption, food production and to maintain flow in rivers. However on occasion the opposite is true, with more water for watercourses can contain, leading to flooding.
The partnership with other Risk Management Authorities will consider issues associated with water supply, land irrigations and flooding.
A holistic approach will also be used in the context of new development and investment, leading to multiple benefits and using multiple funding sources.
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5.7 Encourage ordinary watercourse maintenance and minimise unnecessary constrictions
It is likely that efficiency in maintenance of assets relating to ordinary watercourses will be variable over the City and County of Swansea area. Before embarking on plans for capital spending it will be necessary to undertake a review of how maintenance is being carried out, by whom, and what actions need to be taken to ensure that assets are capable of operating at their full capacity.
5.8 To obtain as much information as possible on the latest best practice initiatives with the industry as a whole
The Pitt Recommendations, and related strategies such as the implementation of the Flood and Water Management Act, have led to a profound change in the way that surface water management is carried out in England and Wales. County and Unitary Councils, which previously had no significant role, now have the main responsibility for reducing the local risk of flooding from surface water, ground water and ordinary watercourses. It is important that officers understand best practice initiatives and that they work closely with Welsh Government and other key stakeholders to ensure that this achieved. A consistent approach with other Lead Local Flood Authorities will also help with sharing of ‘best practice’.
5.9 Encourage businesses and communities to take steps to prepare for flooding
Communities and businesses need a better understanding of flood management and what they can do to help to reduce risk to their properties,. For a significant reduction in flood risk to be achieved; each individual must contribute to the cause and help in the practical implementation of the strategy, including securing funding. Some flood protection/prevention measures can be subject to planning law and therefore communication between the relevant authorities and the community will be necessary. Information regarding water management should be made widely available and distributed throughout the affected community via websites and pamphlets. . Simply protecting property could give rise to increased flows in surface water systems.The main aim of communication is to inform individual property owners of opportunities to reduce flood risk by (for example) reducing impermeable surfaces in gardens.
This increased awareness will help involve communities in the reporting of flooding incidents, such as culverts overflowing and the blocking up of watercourse screens.
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6.1 Overview
The detailed objectives outlined in 5.0 will be delivered through the implementation of a wide range of measures which will be considered in the short (0-20 years) medium (20-50 years) and long term (50-100 years). Both structural and non- structural measures are included.
6.2 Themes
Measures will be categorised under the following seven high level themes:-
• development planning and adaptation (encompassing both new and adaptations to existing developments/landscapes); • flood forecasting, warning and response; • land, cultural and environmental management; • asset management and maintenance; • studies, assessments and plans; • high level awareness and engagement (to increase individual and community resilience); and • monitoring (of the local flood risk).
The following sections outline the proposed measures, categorising them according to the high level theme under which they sit.
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6.3 Measures
Development Planning and Adaptation
Establish SuDS Approval Body Timescale –Short Term Delivery and Benefits The legislation governing this measure Surface water discharge rates from The Flood and Water Management Act 2010 assigns CCS the has not yet been enacted, but is likely to new developments to be restricted to MEASURE 1 role of a Sustainable Drainage System (SuDS) Approval Body be so during the lifetime of the LFRMS. best practice guidelines in order to Statutory (SAB). A SAB will be responsible for: mitigate flood risk post development Requirement · assessing and approving the drainage design for all Encourage Groundwater recharge by construction work which infiltration techniques has drainage implications, and Enhancement of amenity, water · adoption and maintenance of SuDS schemes which connect quality and environmental more than one property improvements Financial implications New function with some cost recovery through fees– potential revenue implication
City and County of Swansea Local Development Timescale – Short Term Delivery and Benefits Plan with a Strategic Flood Consequences Currently ongoing with no financial To allow allocated sites to be free of MEASURE 2 implication flooding constraints Statutory Assessment as part of evidence base The LDP aims to ensure that existing Requirement development is protected from Strategic Flood Risk Assessment (SFCA) undertaken to support flooding that may be created from the LDP. The primary focus was to assess flood risk for key new development development sites at strategic level. The LDP plan includes specific policies which set out how development proposals should be considered in relation to flood risk
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Planning Policy Wales and TAN 15 Timescale –Short Term Delivery and Benefits Current Legislation and working practice. To ensure that all new development Key policy objectives as identified in section 4.4 of PPW include is located away from land that is MEASURE 3 the need to minimise the risks posed by, or to, development on, subject to flood risk; Statutory or adjacent to, land liable to flooding. Section 9 requires local To provide an identification process Requirement planning authorities to promote sustainable residential of where further consideration and environments, giving regard for biodiversity, nature conservation assessment is required before and flood risk. Chapter 13 sets out the broader objectives for development can take place. planning and environmental management. This is to control where development can take place and what operations may be carried out, to ensure the avoidance of, or minimising, the Financial Implication adverse effects of any environmental risks associated with No implication flooding on present or future land use. Land use planning policies are supplemented by a series of Technical Advice Notes (TANs).
TAN 15 provides technical guidance which supplements the policy set out in Planning Policy Wales. It advises on development and flood risk and provides a framework within which risks arising from both river and coastal flooding, and from additional run-off from development in any location, can be assessed. Water Cycle Strategy Timescale –Short Term Delivery and Benefits To support the preparation of Water Cycle Strategy which will Currently ongoing with no financial The Study is a partnership document MEASURE 4 form part of the evidence base for the LDP. This would include:- implication involving the planning authority, water Best Practice company, Environment Agency and • water supply to meet current and future demands,· Countryside Council for Wales The • water management within existing developments, latter two will be part of the new • water management in new developments, single body from April 2013. Joint
• waste water treatment and disposal and the impact of all working ensures that the study of these on the movement of water through the provides benefits to all stakeholders. catchment (including flood risk), water quality, natural · For Welsh Water benefits include
hydrological processes and ecology. timely input to water infrastructure planning regarding future development, strategic needs,
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environmental constraints, Water Framework Directive management MEASURE 4 requirements, reduced flood risk and enhanced water quality.
For the EAW/CCW benefits include a framework for water and nature conservation policy compliance, for detailed development control observations and Local Development Plan consideration. Developers benefit from clear guidance regarding water efficiency targets, SuDS, infrastructure timescales and costs, and environmental constraints. The public will benefit from reliable infrastructure for supply and water treatment, good planning for climate change and flood risk management and potential savings from a strategic approach. For the Planning Authority evidence is provided for the Local Development Plan for site allocation and infrastructure planning and for implementation through development control, Community Infrastructure levy / S106 etc.
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Flood Forecasting, Warning and Response
Flood Awareness Timescale –Short Term Delivery and Benefits The Council has a duty under the Civil Contingencies Act 2004 CCS Website is reviewed annually to The Government believes a well- to warn and inform its residents of the risks and implications of provide information to residents on roles informed public is better able to MEASURE 5 those risks before, during and after any incidents. As part of this and responsibility of the Local Authority in respond to an emergency and to Statutory the Council’s web site holds information and links to further flood related matters minimise the impact of flooding Requirement sources of information in relation to flooding incidents. On consequences on the community. occasion, when significant flooding does occur staff from the Informing the public as best we can Council attend areas / properties to provide advice to the will build their trust and involve them affected residents. in flood mitigation solutions. It will also help minimise disruption and This can be extended further under the general requirements of Financial implications improve / ease the response to any the FWMA 2010 . Existing function with no new flooding incidents. implications Officers to inform affected communities with best practice measures for property resilience against flooding
Flood Warning Timescale – Short Term Delivery and Benefits The Council has a duty under the Civil Contingencies Act 2004 As appropriate to scale of Flood Risk To allow and inform communities to MEASURE 6 to warn and inform its residents of the risks and implications of Flood warning to local sources of flooding access to warning systems i.e. EA Statutory those risks including during and after significant flooding to be developed. flood alerts or other media means. Requirement incidents Preparation against the consequences of flooding will reduce impact and costs.
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Emergency Response Plans including Multi - Timescale –Short Term Delivery and Benefits Agency Plans The legislation governing this measure Provides clear explanation on the has not yet been enacted, but is likely to roles and responsibilities of Key MEASURE 7 Emergency planning should aim where possible to prevent be so during the lifetime of the LFRMS. stakeholders in an event of an Statutory emergencies occurring and when they do occur, good planning This measure will be updated once the emergency. Requirement should reduce, control or mitigate the effects of the emergency. relevant legislation has been commenced. It is a systematic and ongoing process which should Preparation of flood evacuation evolve as lessons are learnt and circumstances change. procedures in the Multi Agency Plans provides for a planned response to Multi agency plans have been developed which concentrate on act in a co-ordinated reactive manner different agencies responsibilities as well as command and Financial Implication control. This has been produced by the Joint Resilence Unit of No implication CCS/NPT . Community Flood Plans Timescale –Short Term Delivery and Benefits This area needs to be developed to take Communities to take on some MEASURE 8 Community flood plan provide a Non- Structural solution to into account local flooding issues. additional responsibility for flood Best Practice mitigate the effects of flooding. The Environment Agency have The Flood Hazard mapping to be related matters in their communties taken the lead on this to date. Lead Local Authorities to develop produced by 2013 will provide further and enables them to become more their own plans with the aim to develop resilient communities information on surface water flood risk resilent. when faced with serious flooding incidents. throughout CCS when community flood plans can be developed further. Collaborative working between LLFA and Communities is essential in order to improve communication in the Financial Implication response to flooding.
Potential Revenue Costs
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Land Cultural and Environmental Management
Land Management Timescale –Short Term Delivery and Benefits The extent to which CCS can use land Through the provision of sustainable Good Land Management Techniques can reduce the extent of management techniques to develop flood solutions for new schemes. MEASURE 9 surface water run-off and this will be explored whenever risk management solutions will be possible. considered as part of the requirements to Through consultation with developers Best Practice completed Flood Risk Management Plans as part of the new SAB role for by 2015. approving surface water strategies for new sites
Advising landowners of the Financial Implication advantages of land management techniques to mitigate against the risk Potential for higher revenue costs but a of flooding balanced approach will consider costs and benefits, To promote wider environmental Schemes with external funding may benefits of using ‘softer’ engineering facilitate this approach. approaches to land management in order to reduce surface water run-off Environmental Enhancement Timescale- Short Term (5year +) Delivery and Benefits
MEASURE 10 Measures contained with this strategy to support opportunities Consultation with EAW/CCW to Best Practice to develop enhancement to the environment whenever ensure compliance to the objectives possible. and directives set out in the SEA • Protection to SACs,SPAs,Ramsar sites and SSSI’S which supports this strategy. through water level management Financial Implication • Enhancement and compensatory creation of Habitats Creation of habitats whether Potential higher capital and revenue compensatory or enhancement of costs existing habitats to be considered for the wider benefit of the environment.
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Asset Management and Maintenance
Asset Register and Records Timescale –Short Term Delivery and Benefits Ongoing scheme of work CCS is required to keep both asset registers (for public use) To update records following flood risk MEASURE 11 and asset records (for use by risk management authorities) for incident as part of the investigation structures and features which are considered to have a process. Statutory significant effect on flood risk. There is no formal definition of To collect continually information on Function when an asset has a ‘significant effect’ but will largely be assets significant to flood risk and to determined on the flood history of the site and the vulnerability record ownership and responsibility of of any infrastructure likely to be affected by a failure of the those assets. asset. To establish assets prone to flooding CCS will continually update the asset register through the Financial Implication in order to inform future improvement information received via the planning process and works watercourse consenting duty. Revenue To ensure adequate maintenance regimes and proper condition of those structures. Power to request information Timescale Short Term Delivery
MEASURE 12 In certain circumstances the Authority will request information CCS has new powers to request Best Practice from other risk management Authorities or private landowners Ongoing scheme of work – on demand information which will improve the regarding their assets. availability of flood risk data held by The new powers contained within the FWMA 2010 provides Authority. CCS with the powers to request this information. Failure to do Financial Implication so can lead to legal action being served. No implication
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Designation of Structures Timescale –Short Term Delivery and Benefits
The Flood and Water Management Act establishes CCS as Ongoing To ensure no alterations are made to MEASURE 13 the ‘Designating Authority’ with the power to designate a a designated structure without structure (whether man-made or a natural feature) if CCS approval from the Authority. Statutory believes that the structure or feature is significant to flood risk. Function A person can not make alteration to the structure unless Ensures that a register of structures Discretionary permission is granted by the Authority is maintained by the Authority. powers Designated Structures will be Financial Implication registered with the Land Registry
Potential revenue Implication
Creation of SuDS Approving Body (SAB) Timescale –Short Term Delivery and Benefits
MEASURE 14 The Flood and Water Management Act places a duty on the Ensures future maintenance of SuDS Best Practice City and County of Swansea to adopt sustainable drainage April 2013 Schemes by the LLFA. systems. This part of the Act has not been implemented yet, Surface Water Strategies to be but is expected to be enacted April 2013. approved prior to Planning Consent, Financial Implication either through the Planning process The process will involve application approval, inspection and or separate application. adoption of sustainable drainage systems which will serve Cost recovery via the application process new developments which will comply to National Standards.
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Asset Management and Maintenance –cont’d
Consenting to Works on Ordinary Watercourses Timescale Delivery Ongoing scheme of work CCS will determine a consent MEASURE 15 From 6 April 2012 CCS became responsible for issuing application with the 2month standard Ordinary Watercourse consents for works to ordinary period. Statutory watercourses (streams and ditches both natural and man Consultation with other stakeholders Requirement made and culverts etc) or taking enforcement action for any with applications which possibly could breaches. In future all land drainage consents for works within have an adverse affect on the City and County of Swansea will be issued by Authority’s Environment. Drainage and Coastal Management Section . Compliance to WFD Directive Financial Implication CCS to adopt EAW policies on non- culverting of watercourses. This is
because :- City and County of Swansea will take a risk-based approach Cost Recovery £50 per application • The ecology of the to enforcement where unconsented works have been carried watercourse is likely to be out on ordinary watercourses. The purpose of ordinary degraded by culverting; watercourse regulation is to control certain activities that might • Culverting introduces an have an adverse flooding impact . increased risk of blockage (with consequent increase in flood risk); Culverting can complicate maintenance because access into the culvert is restricted (in some cases being classified as a confined space and requiring trained operatives and specialist equipment) Enforcement to maintain flow in watercourses Timescale –Short Term Delivery
MEASURE 16 Acting as the Land Drainage body CCS has permissive CCS has new powers to reduce the Statutory powers to serve notice on riparian landowners in order to Ongoing scheme of work – on demand likelihood of flood risk due to a Function remove any obstruction which is impeding the flows in a restricted flow in a watercourse watercourse. caused by an obstruction.
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Financial Implication Existing Duties – revenue based
Asset Management and Maintenance-cont’
Construction of Flood Defences Timescale –Short Term Delivery
Potential schemes will be developed through the Project Flood Risk Management Plans to be The Authority is expected to deliver a MEASURE 17 Appraisal route where they will be scrutinised against produced by June 2015 Flood Risk Management Plan by technical and economic appraisal. 2015.
The Flood Risk Management Plan will identify capital schemes, allowing potential funding streams to be explored. Financial Implication The Authority will use cost/benefit Revenue and Capital Expenditure analysis for potential schemes Potential External Funding through the Project Appraisal Route
Cause incidental flooding for purposes of flood Delivery and Benefits risk management Timescale Measure 18 Options to be explored in the production To provide impounded water of the Flood Risk Management Plans solutions for the benefits of both flood CCS has powers to manage flooding and water levels in the 2015 risk and the wider environmental interest of wider flood risk management, nature conservation, objectives the preservation of cultural heritage or people’s enjoyment of Financial Implication the environment Revenue and Capital costs
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Studies, Assessment and Plans
Duty to Investigate Flooding Incidents Timescale –Medium to long term Delivery
The FWMA has placed a new duty of LLFAS to investigate Ongoing function undertaken by the To undertake investigative studies to MEASURE 19 and record significant flooding incidents. The investigation Authority areas which are subjected to must identify ownership of the asset which has caused the ‘significant flooding’ in order to Statutory flooding and the respective risk management Authority provide a clear understanding of Function involved. ownership of the cause of flooding.
Flood Investigations will be reported using the flowing criteria:- To provide solutions for consideration • Where there is internal flooding to one or more property on more than one occasion Financial Implication To increase the level of flood data • When more than five properties have affected by held by the Authority which will inform flooding Potential Revenue costs future flood risk management plans • When a commercial premises has been affected • Critical Services has been affected • Critical Infrastructure has been affected • When a community have been ‘cut off’ by a flooding event MEASURE 20 Resilience measures Timescale –Short Term Delivery
Best Practice Initial awareness campaigns will be developed to those The Authority is expected to develop communities with highest risk of flooding and those who have To provide non-structural solutions to a transparent system to prioritise experienced flooding incidents. This measure will attempt to areas at greatest risk of flooding and flood defence schemes by 2015. provide residents, businesses and other organisation affected timed to meet the requirements of Flood Non-Structural solutions to warn and by flooding with information to improve their awareness of Risk Management Plans to be produced inform communities affected flood risk good resilience techniques so that the consequences of by June 2015 will be promoted as a solution.
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flooding can be reduced. Financial Implication The proposed Flood Risk Management Plans for CCS will Revenue and Capital costs identify resilience schemes as an alternative to structure solution if considered appropriate
Flood Risk and Hazard Maps Timescale –Short Term Delivery
The Flood Risk Regulations (2009) require all Local Lead To be published by 2013 Flood Hazards Maps will be MEASURE 21 Flood Authorities with indicative Flood Risk Areas to produce produced by all Local Lead Flood Flood Risk and Hazard Maps by 2013. These maps will be Authorities by 2013 in order to Statutory used to identify the level of hazard and risk of flooding within provide a greater understanding of Requirement CCS. These maps will subsequently indicate in detail the the probability and consequences of areas which are most at risk from surface water flooding and surface water flooding in the Flood will be used to inform the content of Flood Risk Management Risk Areas;The benefits will include:- Plans. • Better understanding on the level of flood risk to affected communities Financial Implications • Help prepare and inform the
Flood Risk Plans to be Flood Hazard Maps – Externally funded produced by the Authority by 2015
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Flood Risk Management Plans Timescale –Medium to long term Delivery
The Flood Risk Regulations (2009) require Lead Local Flood Ongoing function undertaken by the The Flood Risk Management plan will MEASURE 22 Authorities to prepare and publish Flood Risk Management Authority provide a clear steer on how CCS will Plans by June 2015 where the risk of flooding from local flood deal with Flood Risk Areas and will Statutory risk is significant as identified in the Preliminary Flood Risk recommend measures for managing Requirement Assessment (PFRA). flood risk within its area The statutory requirement is only to produce a Flood Risk The plan will help raise awareness Management Plan for the flood risk area identified as part of and improve knowledge of local flood the PFRA. However, the PFRA assessment identified other risk. areas which had high risk of flooding and these areas will be The Plan will be used to inform other included in plan also, so that all high risk areas within Flood Risk Management Authorities Financial Implications Swansea can be managed accordingly. with the Authority’s intentions to
manage flood risk and will help Potentially Externally funded explore the possibilities of collaborative working for joint benefits.
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High Level Awareness and Engagement
Community Engagement Timescale – Short Term Delivery and benefits
Raising community awareness and communicating effectively Working with communities will help: MEASURE 23 with local communities will enable CCS to set realistic Current ongoing • Understand the need of expectations and achievable outcomes for local flood risk individuals, communities and Best Practice management. CCS proposes to inform those that are at risk of businesses local flooding and advise them on what steps to take . • Make better informed plans decisions and policies • Communities to understand what flood risk means to Financial Implications them • Meet goals Potential • Increase local support
Collaborative Working Timescale – Short Term Delivery and benefits
Working with other flood risk The City and County Swansea will work collaboratively with Current ongoing management Authorities will help: other flood risk management Authorities and to share • Understand collectively the MEASURE 24 information to inform flood risk management aims and range of Flood Risks within objectives. Swansea Best Practice • To explore possibilities of joint funding
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Financial Implications • To work in Partnership for common goals Ongoing function • To participate in working groups for the benefit of Flood Risk Management • To ensure best practice and a consistent approach with other Authorities
Drainage and Coastal Management Section February 2013 61 Local Flood Risk Management Strategy Appendix A 7.0 Funding and Delivery Plan
It is important that the local strategy sets out how the proposed actions and measures will be funded and resourced within City and County of Swansea. It is also important to identify what funding mechanisms are available to City and County of Swansea to pay for the flood risk management measures that are set out in the strategy. Effective implementation of flood policy objectives requires adequate resources both for the management and response activities of the lead local authorities as well as for the capital projects
Costs and Benefits of Proposed Measures One of the stated requirements of what should be included in a Local Flood Risk Management Strategy is the provision of the costs and benefits of any proposed measures. At this stage in the Strategy process, it is difficult to ascertain and quantify costs and benefits as it is difficult to ascertain the precise cost of any measures without knowing the exact scope of any required works. Secondly, quantification of benefits is difficult without an accurate assessment of the extent to which measures are able to reduce flood risk. Costs and benefits of detailed measures will be included within the Flood Risk Management Plans and future LFRMS reviews.
7.1 Existing Funding Mechanisms The majority of funding for flood and coastal erosion risk management in Wales comes from the Welsh Government.
As the level and nature of risk changes in the future, Welsh Risk Management Authorities will need to find other sources of funding to ensure that communities across Wales receive the levels of funding they need to manage the risks they face (Welsh Government, 2011).
Owing to increasing funding constraints the Welsh Government has proposed a number of actions within its NFRMS to enable more efficient and effective spending on flood and coastal erosion risk management in Wales, namely:- • Prioritisation of investment and the funding of projects set out in a long term investment plan; • Joint funding for multiple benefits (particularly with regards to regeneration and transport investment) will be maximised; • Beyond 2015, other sources of European funding will be sought; • Contributions from the private sector will be expected to contribute to project costs where private assets are being protected; • The levy raising powers of Flood Risk Management Wales (the Environment Agency Regional Flood and Coastal Committee for Wales) may need to be exercised; and • When setting future budgets, Local Authorities may need to factor in additional expenditure on flood risk management within their area.
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7.2 Summary of existing Funding Mechanisms
Funding from Funding from Other Local Agriculture Welsh Authority Government Income
Including Council Funding from Funding from CLG tax and third party contributions Defra
Environment Local Authorities Agency
Regional Flood and Coastal Defence
Investment in Managing risk from main rivers and sea Internal Drainage Board Local Flood risk management
Land drainage management of risk from ordinary Flood and Coastal erosion risk management watercourses in schemes and activities ‘areas of special drainage need’
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7.3 Public funding
With less direct government funding available, it is clear that changes are needed to the traditional approaches to funding flood risk management. The current situation of government flood risk management funding is summarised below:
• In 2011/2012 the Welsh Government committed £36.6 million to flood and coastal erosion risk management in Wales. That funding is a mixture of capital used mainly for the construction of existing defences, and revenue funding which is used for maintenance of existing defences and for a range of other flood awareness initiatives. . • The Welsh Government allocates the majority of its budget to for flood and coastal erosion risk management to the Environment Agency, with some funding retained for grants to local Authorities.
• Indicative allocation of budgets in future years will be £35.7million and £37 million for the years 212/13 to 2013/14 respectively.
• In recognition of the increasing funding constraints Welsh Government will seek to maximise the effectiveness of its core funding for flood and coastal erosion risk management.
7.4 Other Possible Sources of Funding
Section 106 funding – Developer Contributions
The City and County of Swansea can enter into legal agreements with landowners or developers covering planning obligations associated with planning consent. These agreements can secure delivery of measures necessary to make a development acceptable in planning terms.
One of the recommendations of ‘Making Space for Water’ was that the local planning authorities should use section 106 agreements to help manage flood risk. Any flood risk which is caused by, new development should be resolved, and the resolution funded, by the developer.
Community Infrastructure Levy(CIL) Regulations came into force in April 2010 and set out a new system of regulations that allows the Council to raise contributions from developments to fund wide range of ‘relevant infrastructure’ which could include flood defences. The Levy is intended to work alongside the Planning Obligations process. From 2014 regulations will be introduced which will reduce the extent to which infrastructure can be funded through planning obligations.
Drainage and Coastal Management Section February 2013 64 Local Flood Risk Management Strategy ______
European Funding
Funding from the European Union is designed to align the economic prosperity of the various regions of Europe. Of particular relevance to City and County of Swansea is the Development Fund (ERDF). This fund has/will, in the period 2007-2013 provide/d nearly £50m to support a flood and coastal erosion risk management programme of just over £100m. This includes funding of the Lower Swansea Valley flood alleviation scheme in City and County of Swansea. Wales may benefit from another round of funding from European funding. It is currently unclear whether there will be a mechanism for use of such funds for Flood Risk Management activities.
Private Fund Raising
Partnership funding between public and private sectors and local communities could be adopted as a means of funding projects which are mutually beneficial to all groups.
Partnership working/funding between Risk Management Authorities will also be considered as a way of achieving flood risk management objectives which are of mutual interest to parties. Opportunities to explore joint funding will be promoted to ascertain maximum benefits for future flood alleviation schemes.
7.5 Prioritisation of funding
The Welsh Government has indicated that, in future years, investment in flood risk management will need to be rigorously prioritised. A range of factors will need to be taken into consideration when determining the extent to which the Welsh Government is likely to invest in flood risk management schemes:-
• Risk to life; • Longer term sustainability of the community, the approach taken and the wider environment; • Economic impacts, costs and benefits; • Impacts of flooding on the operational capacity of critical infrastructure; • Social impacts, costs and benefits; • Frequency of flooding; • Environmental costs and benefits derived from the work; • Availability of appropriate compensation sites where work impacts designated habitats; • Impacts on the wider cultural heritage; and • Multiple benefits in relation to human health and wellbeing.
The Welsh Government is currently in the process of establishing a clearer funding prioritisation methodology for Wales, which may lead to a single Welsh Government funding scheme for flood and coastal erosion risk management projects in Wales. It is intended that the prioritisation of flood risk
Drainage and Coastal Management Section February 2013 65 Local Flood Risk Management Strategy ______management projects within CCS will adhere to any guidance issued by the Welsh Government in the future. The Council intends to work with the Welsh Government to secure a fair prioritisation system which takes into account local factors.
8.0 The Environmental Benefits
The primary purpose of this report is to set out the strategy for reducing flood risk in City and County of Swansea but if this is done with sensitivity, good design and planning it is possible also to derive significant benefit in respect to countywide aspirations in the wider context of sustainability, environmental and social improvement.
The environmental benefits that can be achieved in relation specifically to flood risk reduction need to be considered in the wider context of sustainability
The strategy will contribute to the achievement of wider environmental objectives by :-
• Ensuring that, as far as is reasonably practical, actions taken will maximise opportunities to ensure that CCS’s countryside, coastline and towns become richer in biodiversity and waterways achieve good ecological status.
• Ensuring that in all decision making, adaption to mitigate the likely effects of climate change will be taken into account, community engagement will be encouraged and the ethos of ‘making space for water’ will be followed.
• Ensuring that in addition to Water Framework Directive and biodiversity improvements, other benefits will be sought as appropriate, such as changes to more sustainable water management practices like sustainable drainage systems, diverting floodwaters into areas where it can achieve positive environmental benefits, and improvements to public access.
8.1 Water Cycle Management Opportunities
Improvements to overall water management are likely to be enhanced by certain measures contained within the LFRMS. For instance, implementing source control measures (via, for example, the implementation of SuDS or land management techniques) will enhance the infiltration of rainwater into the ground. This will have a positive effect by reducing the load placed on surface water sewers, enhance the recharging of groundwater aquifers and improve the retention of water in the catchment which will reduce flood peaks and provide secondary biodiversity and recreational enhancement.
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8.2 Potential Enhancement of the Natural Environment
Water availability is a critical component in maintaining and enhancing certain water dependent habitats/biodiversity. Certain measures outlined within the LFRMS have the potential to incorporate habitat enhancement or work with other environmental strategies in order to create or improve the natural environment.
8.3 Reduction in Carbon Use
It is likely that the implementation of the LFRMS will bring about reductions in carbon footprint. This can be brought about in a number of ways: • by implementing objectives that encourage schemes to be constructed in a sustainable manner, and indeed the possible promotion of non-structural schemes, there will be a reduction in embedded carbon in soft engineered flood risk reduction measures as opposed to more traditional measures which use reinforced concrete, quarried raw materials etc. • the reduced energy requirement needed for water treatment by reducing the amount of surface water runoff entering foul/combined sewer systems; • water storage areas and wetlands used for flood storage areas also act as natural areas of carbon capture; • potential innovative land management techniques, such as the restoration of degraded peat bogs, will additionally create natural carbon sinks.
8.4 Water Framework Directive
The Western Wales Management Plan outlines the pressures facing the water environment in the wider south-west Wales region and the actions required to address them. The objectives which are relevant to this strategy are: • to prevent deterioration in the status of aquatic ecosystems, protect them and improve the ecological condition of waters; • aim to achieve at least good status for all water bodies by 2015, where this is not possible and subject to criteria set out in the Directive, aim to achieve good status by 2021 or 2027; • meet the requirements of Water Framework Protected Areas; • promote sustainable use of water as a natural resource; • conserve habitats and species that depend directly on water; • progressively reduce or phase out the release of individual pollutants or groups of pollutants that present a significant threat to the aquatic environment; • progressively reduce the pollution of groundwater and prevent or limit the entry of pollutants; • contribute to mitigating the effects of floods and droughts.
Certain flood risk management activities have the potential to assist in meeting the objectives listed above. For instance:
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Pollution prevention – The use of SuDS and the correct regulation of water courses can assist in the prevention of contamination of watercourses from industrial and domestic pollution. Reduction of sediment in water courses – this can be achieved via implementing best-practice land management techniques and the use of SuDS particularly where soils are prone to erosion. Protection and enhancement of wildlife – measures to protect and enhance wildlife and their habitat can be embedded within potential flood risk management schemes. This is particularly the case where flood risk management measures are implemented in synergy with complimentary environmental strategies. Preservation of water resources – by looking at flood risk management in a holistic manner, the whole water cycle will be considered as a key element of scheme appraisal.
8.5 The wider Environmental Benefits
CCS has undertaken a Strategic Environmental Assessment (SEA) in parallel with the development of this Local Flood Risk Management Strategy. The SEA appraisal identifies the key environmental issues and sets out how these provide opportunities/constraints in the context of the LFRMS.
9.0 Next steps
Under the LFRMS the City and County of Swansea will lead in directing a partnership response in: resolving flood problems in areas of known risk; dealing with potential flood risk sites, and the review of Indicative Flood Risk Areas.The Strategy has identified all risk areas and all the different sources of the flood problem. Any area may be at risk from not just one prime cause but a number of different sources of flooding.
Those organisations with a responsibility for managing flood risk are aware of their responsibilities, and are committed, as part of the Strategy, to participate in the joint ongoing management of risk. The City & County of Swansea is the Lead Local Authority.
The Authority will work with other Risk Management Authorities and other stakeholders, including local communities, to deliver the aims and objectives of this strategy. The most cost effective measures to improve local flood risk management can be delivered only through true partnership working. The City and County of Swansea will continue to work with partners to undertake the actions identified in this strategy and associated action plan, and will seek to ensure that the measures achieve maximum benefits for the community, the county and the environment.
Drainage and Coastal Management Section February 2013 68 Local Flood Risk Management Strategy ______10.0 How and when the strategy is to be reviewed
Reviews are planned to take place in 2013 to coincide with the ‘Flood Hazard and Flood Risk Maps’ and in 2015 to coincide with the ‘Flood Risk Management Plans’ required by the Flood Risk Regulations (2009).
In 2016 a further review will take place using new information from the updated Flood Risk Assessment. A formal review will take place in 2017 and every following six years to run alongside the production of the ‘National Strategy for Flood and Coastal Erosion Risk Management in Wales’, as recommended by the Welsh Government. The Strategy will also be reviewed whenever significant new information becomes available.
This LFRMS will be subject to continuous development will not be a one off exercise. The regular reviews described above will allow a robust approach to be adopted using all relevant data.
Glossary of Terms
ASTSWF Areas Susceptible to Surface Water Flooding CCS City and County of Swansea CCW Countryside Council for Wales CFMP Catchment Flood Management Plan DAMS Development Advice Maps DCWW Dwr Cymru Welsh Water EAW Environment Agency Wales FWMA Flood and Water Management Act JRU Joint Resilience Unit LLFA Lead Local Flood Authority LPA Local Planning Authority LDP Local Development Plan LFRMS Local Flood Risk Management Strategy NFRMS National Flood Risk Management Strategy PFRA Preliminary Flood Risk Assessment SAC Special Areas of Conservation SFCA Strategic Flood Consequence Assessment SINC Sites of Importance for Nature Conservation SMP Shoreline Management Plan SSSI Special site of Scientific Interest SuDS Sustainable Urban Drainage Systems TAN15 Technical Advice Note 15 WFD Water Framework Directive
Drainage and Coastal Management Section February 2013 69 Local Flood Risk Management Strategy ______References
National Strategy for Flood and Coastal Erosion Risk Management in Wales(November 2011) Welsh Government
Local Flood Risk Management Strategies , Local Strategy (November 2011) Welsh Government
Preliminary Flood Risk Assessment, City and County of Swansea
Strategic Flood Consequence Assessment , City and County of Swansea
Lavernock Point to St.Ann’s Head Shoreline Management Plan, Swansea and Carmarthen Bay Coastal Engineering Group
Loughor to Taf, Ogmore to Tawe, Catchment Flood Management Plans Environment Agency Wales
Drainage and Coastal Management Section February 2013 70 Appendix B
City & County of Swansea
Local Flood Risk Management Strategy
Draft SEA Environment Report
DRAFT NOVEMBER 2012
REF: ISSUE: AUTHOR: DATE: PAGE: ENV report draft PT/SP Nov 12 2 of 46 Appendix B CONTENTS
SECTION. PAGE 1 INTRODUCTION 1.1 Background 6 1.2 Strategic Environmental Assessment 6 1.3 Aim and Structure of this Report 7 1.4 Study Area 8
2 CONSULTATIONS 2.1 Previous Consultation 10 2.2 Consultation on this Report 10 2.3 How to Comment on this Report 11 STRATEGIC ENVIRONMENTAL ASSESSMENT PROCESS 3 AND STAGES 3.1 SEA Screening 11 3.2 SEA Guidance 11 3.3 SEA Stages 13
4 STRATEGIC ENVIRONMENTAL CONTEXT, BASELINE AND OBJECTIVES 4.1 Other Relevant Plans 14 4.2 Baseline Information 17 4.2.1 Population and Human Health 18 4.2.2 Biodiversity, Flora and Fauna 19 4.2.3 Soils, Geology and Landuse 21 4.2.4 Water 22 4.2.5 Flood Risk 23 4.2.6 Climatic Factors 25 4.2.7 Material Assets 26 4.2.8 Cultural Heritage 29 4.2.9 Landscape & Visual Amenity 30 4.2.10 Air Quality 31 4.3 Strategic Environmental Objectives and Assessment 31 Framework
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SECTION. PAGE
5 STRATEGIC ENVIRONMENTAL ASSESSMENT METHOD
5.1 . LFRMS/SEA Stages 36 5.2 Scenario 36 5.3 Assessment Methodology 37
6 LFRM STRATEGY OBJECTIVES 38
7 ASSESSMENT OF LFRMS OBJECTIVES 7.1 Assessment Objectives 39 7.2 Significant Secondary and Synergistic Effects 43 7.3 Proposed Monitoring 44
8 FUTURE SEA ACTIVITIES 46
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DATE PAGE NO. REASON FOR AMENDMENT CHANGED BY
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ABP Associated British Port AEP Annual Event Probability AONB Area of Outstanding Natural Beauty ASA Archaeologically Sensitive Areas ASTSWF Areas susceptible to surface Water Flooding BAP Bio-Diversity Action Plan CCS City & County of Swansea CCW Countryside Council for Wales CFMP Catchment Flood Management Plan CSO Combined Sewers Overflow EAW Environment Agency Wales EPR Environmental Permitting Regulations FRT Flood Risk Threshold LBAP Local Biodiversity Action Plan LFRMS Local Flood Risk Management Strategy LLFA Lead Local Flood Authority LNR Local Nature Reserve NNR National Nature Reserve PFRA Preliminary Flood Risk Assessment PPW Planning Policy Wales SAC Special Area of Conservation SEA Strategic Environmental Assessment SINC Candidate Sites of Importance for Nature Conservation SINCs Sites of Importance for Nature Conservation SMP Shoreline Management Plan SMR Sites and Monuments Record SPA Special Protection Area SSSI Special Site of Scientific Interest SuDS Sustainable Drainage Systems UKCIP UK CLIMATE IMPACTS PROGRAMME WFD Water Framework Directive WG Welsh Government
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1. INTRODUCTION
1.1. BACKGROUND
This report forms the SEA Environmental Report which presents an assessment on the potential environmental affects of City and County of Swansea’s Local Flood Risk Management Strategy.
The SEA Environmental Report forms part of the consultation (along with the Draft Local Flood Risk Management Strategy and Habitats Regulations Assessment) being undertaken as part of the development of the LFRMS.
The overarching aim of the LFRMS is to set out a framework for delivering an effective service to address the increasing risk from flooding, specifically from surface water runoff, groundwater and ordinary watercourses in City and County of Swansea.
The LFRMS will set out:-
The roles and responsibilities of the risk management authorities in the Lead Local Flood Authority (LLFA) area and the risk management functions that may be exercised by those authorities;
the approaches and objectives for managing local flood risk and the measures by which these objectives will be met;
timescales for the implementation of the above measures;
costs and benefits of these measures and the mechanisms to fund them;
an assessment of local flood risk for the purpose of the Strategy;
the method and timescales for review of the strategy;
how the LFRMS contributes to the achievement of wider environmental objectives.
1.2. STRATEGIC ENVIRONMENTAL ASSESSMENT
The aim of the SEA is to identify potentially significant environmental effects created as a result of the implementation of the LFRMS on issues such as “biodiversity, population, human health, fauna, flora, soil, water, air, climatic, material assets including architectural and archaeological heritage, landscape and the interrelationship between the above factors” (Annex 1(f)). The Directive was transposed into Welsh legislation by the Environmental Assessment of Plans and Programmes (Wales) Regulations 2004 (the ‘SEA Regulation’).
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This report aims to document the SEA process and:-
provides a description of the SEA process and the decisions taken during this process; considers, and takes into consideration other strategies, plans and policies deemed relevant; identifies key environmental issues and trends and provides an environmental context for the Local Flood Risk Management Strategy; assesses the potential effects of the Strategy in addition to appropriate mitigation (if required) and enhancement measures; and sets out the proposed monitoring measures which will be used to review the Strategy in the future.
The following table presents the structure of this report with cross-references to the requirements of the SEA Directives .
Section in SEA Requirement this report
An outline of the contents and main objectives of the Strategy, and of its 4.1 & 6.0 relationship with other relevant plans and programmes
The relevant aspects of the current state of the environment and the likely 4.2 evolution thereof without implementation of the Strategy.
The environmental characteristics of areas likely to be significantly 4.3 affected.
Any existing environmental problems which are relevant to the plan or Ref. LFRMS programme including, in particular, those relating to any areas of a Habitats particular environmental importance, such as areas designated pursuant regulations to Council Directive 79/409/EEC on the conservation of wild birds and the Assessment Habitats Directive.
The Strategic Environmental Assessment Directive requires the assessment of synergistic and cumulative effects of a strategy – effects 7.2 which interact in such a way to form significant positive/negative environmental effects
The likely significant effects on the environment, including short, medium and long-term effects, permanent and temporary effects, positive and negative effects, and secondary, cumulative and synergistic effects, on issues such as biodiversity, flora & fauna, population and human health, 7.1 soils, geology and land use, water, climatic factors, material asserts, cultural heritage, landscape and visual amenity and the interrelationship between the above issues.
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Section in SEA Requirement cont. this report
The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing N/A the plan or programme.
An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any 5.2 difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information.
A description of the measures envisaged concerning monitoring. 7.3
An outline structure of the remainder of this report is provided below:-
Section 2 Consultation
Section 3 Strategic Environmental Assessment Processes and Stages
Section 4 Strategic Environmental Context, Baseline and Objectives
Section 5 SEA Assessment Method
Section 6 Local Flood Risk Management Strategy Objectives
Section 7 Assessment of Local Flood Risk Management Strategy Objectives
Section 8 Future SEA Activities
1.4. STUDY AREA
The Strategic Environmental Assessment will encompass the administrative boundary of City and County of Swansea as indicated below
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.
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2. CONSULTATIONS
2.1. PREVIOUS CONSULTATION
The initial step in the SEA process was to produce a SEA Scoping Report which outlined the proposed framework for the SEA assessment. This report was submitted by City and County of Swansea to the three statutory consultation bodies in Wales: Environment Agency Wales; Countryside Council for Wales; and CADW
on the 7th December 2012. The Public consultation period will run until the 31 st January 2013. Representations will be assessed and incorporated into further iterations of the SEA process where required .
2.2. CONSULTATION ON THIS REPORT
This Environmental Report will be subject to public consultation alongside the Draft Local Flood Risk Management Strategy and the SEA Scoping Document.
Wider comments on the above reports are welcomed, but an additional series of consultation questions have been developed in an attempt to assist members of the public in responding:-
Are there any other key issues or trends that you think should be considered in the SEA?
Are there additional environmental effects (including those on humans) that need to be taken into account when developing the LFRMS?
Is there any additional mitigation for adverse effects or enhancement opportunities that should be incorporated into the LFRMS?
Are there any key environmental indicators that should be incorporated into annual reporting on the LFRMS?
Please tell us if you have any overall views or comments on the SEA or our LFRMS that have not been covered by previous questions .
The consultation period will run until 31 st January 2013.
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Please address any comments relating to the SEA scoping Report and this Environmental Report to either:-
Flood Risk Management Strategic Projects & Performance City & County of Swansea Room 2.5.2 Civic Centre Swansea SA1 3SN or [email protected]
3. STRATEGIC ENVIRONMENTAL ASSESSMENT PROCESS AND STAGES
3.1. SEA SCREENING
3.1.1. Screening Assessment
Prior to commencement of the SEA process, a Strategy, Plan or Programme would ordinarily be ‘ screened’ to establish whether the plan is subject to the SEA Directive and requires an SEA.
In accordance with the requirements of Regulation 9 of the Environmental Assessment of Plans and Programmes (Wales) Regulations 2004 (herein referred to as the Regulations), City and County of Swansea has screened its Local Flood Risk Management Strategy to determine the likely significance of the effects of the strategy on the environment.
In doing so City and County of Swansea has taken into consideration the selection criteria in schedule 1(1) and (2) of the Regulations (see following table).
3.1.2. Summary Of The Screening Assessment
The assessment of the LFRMS is an integral part of the plan preparation and has five sequential stages. These main stages and the tasks for each stage are listed below.
3.2. STRATEGIC ENVIRONMENTAL ASSESSMENT GUIDANCE
This has been developed in accordance with the following guidance:-
A Practical Guide to the Strategic Environmental Assessment Directive (ODPM, August 2006). https://www.gov.uk/government/publications/strategic-environmental-assessment-directive-guidance
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Criteria (ref. Schedule 1 of the Regulations) Likely to have significant environmental effects? The characteristics of plans and programmes, having regard, in particular, to:-
1(a) The degree to which the plan or programme Uncertain . sets a framework for projects and other The potential scale of projects/policies associated activities, either with regard to the location, with the Strategy is unknown at this stage. However, nature, size and operating conditions or by there may be potential for project/policies to have a allocating resources; large spatial influence. No predicted significant effects . 1(b) the degree to which the plan or programme influences other plans and programmes However there are potential linkages with other land including those in a hierarchy; use, biodiversity and water based plans and strategies.
1(c) the relevance of the plan or programme for Potentially significant effects . the integration of environmental It is believed that the Strategy will make a significant considerations in particular with a view to positive contribution to sustainability in City and promoting sustainable development; County of Swansea. Potential significant effects 1(d) environmental problems relevant to the plan Potential to have positive effects through for instance, or programme; and land management polices and water quality enhancement. 1(e) the relevance of the plan or programme for the implementation of Community legislation No predicted significant effects . on the environment Characteristics of the effects and of the area likely to be affected, having regard, in particular, to the:-
2(a) the probability, duration, frequency and Uncertain . reversibility of the effects; Further assessment required. Uncertain . 2(b) cumulative nature of the effects; There may be potential for positive cumulative effects. No predicted significant effects . 2(c) trans-boundary nature of the effects; No trans-boundary issues. Potential for significant effects 2(d) risks to human health or the environment; via the increased provision of accessible open space or the reduction in intangible human health issues. Hence likely to have a positive effect. Uncertain . 2(e) magnitude and spatial extent of the effects Potential for significant effects. The spatial extent of (geographical area and size of the projects/plans associated with the Strategy are population likely to be affected); unknown at this time, but could encompass a large area.
2(f) value and vulnerability of the area likely to Uncertain . be affected due to:- special natural characteristics or cultural heritage, Potential for significant effects. There is a potential exceeded environmental quality standards that future plans or policies could increase or limit values, intensive land use; and disturbance to habitats and areas of cultural heritage. Uncertain . 2(g) effects on areas or landscapes which have a recognised national, Community or Potential for significant effects. There is potential for international protection status. increased disturbance of species and habitats (including those that form parts of SSSIs and SACs).
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The main stages and tasks for each stage of the SEA process are presented in the table below.
STAGES IN THE SEA PROCESS
STAGE TASK
Stage A: A1 : Identifying other relevant policies, plans and programmes, and environmental protection Setting the context objectives and objectives, establishing the A2 : Collecting baseline information baseline and A3 : Identifying environmental issues and problems deciding on the Scope A4 : Developing the SEA objectives and framework A5 : Consulting on the scope of the SEA B1: Testing the plan objectives against the SEA objectives. B2 : Developing strategic alternatives. Stage B: B3 : Predicting the effects of the plan, including Developing and alternatives. refining options and B4 : Evaluating the effects of the plan, including assessing effects alternatives. B5 : Mitigating adverse effects. B6 : Proposing measures to monitor the environmental effects of implementing the plan.
Stage C: Preparing the Preparing the Environmental Report Environmental Report
D1 : Consulting on the draft LFRMS and Stage D: Environmental Report with the public and Consultation Bodies. Consulting on the draft LFRMS and D2 : Assessing significant changes. the SEA Report D3 : Making decisions and providing information.
Stage E: E1: Developing aims and methods for monitoring. Monitoring the significant effects of implementing E2: Responding to adverse effects. the LFRMS
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3.3.1. STAGE A – SEA SCOPING
The initial step in the SEA process was to produce a SEA Scoping Report which outlined the proposed framework for the Strategic Environment Assessment.
The Consultation period will run concurrently for the draft LFRMS, the SEA Scoping Report and Environment Report and will end on 31 st January 2013.
Representations received from all three of the consultation bodies will be assessed and amendments will be considered and incorporated into further iterations of the SEA process
3.3.2. STAGE B – DEVELOPING AND REFINING OPTIONS AND ASSESSING EFFECTS & STAGE C – PREPARING THE ENVIRONMENTAL REPORT
Assessment of the LFRMS objectives against the SEA objectives has been undertaken during their development to determine how wider environmental improvements could be incorporated into and considered in the development of the LFRMS. This process has then been documented in the form of this Environmental Report.
4. STRATEGIC ENVIRONMENTAL CONTEXT, BASELINE AND OBJECTIVES
4.1. CONTEXT - IDENTIFYING OTHER RELEVANT PLANS, PROGRAMMES AND STRATEGIES
The LFRMS must comply with existing higher level policies, plans and programmes at international, national and regional levels and endeavour to strengthen and support plans and strategies at the local level. It has therefore been important to identify and review those policies, plans and programmes which are particularly relevant to both the LFRMS and the SEA during the scoping stage. This has allowed any inconsistencies or constraints within the LFRMS to be addressed and also to help develop the SEA framework. The following table outlines the key identified documents
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KEY PLANS, POLICIES AND PROGRAMMES 1
Bathing Water Directive (2006/7/EC)
Bern Convention on the Conservation of European Wildlife and Natural Habitats (1979)
Bonn Convention on the Conservation of Migratory Species of Wild Animals (1979)
Biodiversity Action Plan for Swansea
Conservation of Habitat and Species Regulations 2010
Contaminated Land Strategy
Countryside Rights of Way Act (2000)
Drinking Water Directive (98/83/EC)
EC Freshwater Fish Directive (78/659/EEC)
EC Habitats and Birds Directive (92/43/EEC)
EC Shellfish Water Directive (79/923/EEC)
Environment Strategy for Wales, 2006 (WAG)
Environmental Permitting Regulations (EPR) 2010
EU Biodiversity Strategy (EU, 1998)
European Floods Directive (2007/60/EC)
European Landscape Convention
Flood and Water Management Act 2010
Future Biodiversity Action in Wales, The Wales Biodiversity Group (May 2002)
Groundwater Directive (2006/118/EC)
Health, Social Care and Wellbeing Strategy
Local Bio-Diversity Action Plan
Marine and Coastal Access Act, 2009
Marine Strategy Framework Directive (2008/56/EC)
1 Source:- Sustainability Appraisal And Strategic Environmental Assessment Draft Scoping Report City and County Of Swansea Local Development Plan.
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KEY PLANS, POLICIES AND PROGRAMMES cont. Neighbouring Authorities Local Flood Risk Management Strategies and Preliminary Flood Risk Assessments Ogmore to Tawe Catchment Flood Management Plan, Summary Report 2010, Environment Agency Plan (EAW) and the Loughor to Taf Catchment Flood Management Plan, Summary Report 2010 (EAW) 2010 One Wales: One Planet, 2009 (WAG) Ramsar Convention on Wetlands of International Importance especially as wildfowl habitat (1971) Regional Waste Plan
Regional-level plans, such as the South East Wales Regional Transport Plan, Waste Plan, etc
Register of Landscapes of Historic Interest
Revised Draft Water Resources Management Plan, 2011, (Dwr Cymru Welsh Water)
River Basin Management Plan: Western Wales River Basin District, 2009, (EAW) Strategic Environmental Assessment, Guidance for Practitioners, SEA Topic: Water, 2007 (CCW Swansea 2020 Economic Strategy Swansea Bay and Carmarthen Bay Shoreline Management Plan (SMP), 2001 (Swansea and Carmarthen Bay Coastal Engineering Group) Swansea Environmental Strategy
Swansea Housing Strategy
Swansea Local Development Plan 2
Swansea Unitary Development Plan, 2008 (CCS)
TAN 15 Development and Flood Risk, 2004 (WAG
The Bathing Water Regulations 2008
The Flood Risk Regulations 2009
The Private Water Supplies (Wales) Regulations 2010
The Strategic Policy Statement on Water 2009 (WAG)
The Surface Waters (shellfish) Classification Regulations 1997 The Tawe, Loughor and Gower Catchment Abstraction Management Strategy, 2007 and Update 2009 (EAW)
2 http://www.swansea.gov.uk/ldp
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KEY PLANS, POLICIES AND PROGRAMMES cont.
The Water Supply (Water Quality) Regulations 2001 Water for People and the Environment: Water Resources Strategy for Wales, 2009- 2050 (WAG) Water Framework Directive 2000/60/EC
Welsh Government Climate Change Strategy and associated Action Plan
Welsh Government’s emerging ‘Living Wales’ programme
Wales Community Flood Risk Register
South Wales Shoreline Management plan Environment Agency ‘Adapting to Climate Change’ guidance to assist Risk Management Authorities in Wales to adapt to climate change, available from: http://wales.gov.uk/topics/environmentcountryside/epq/waterflooding//flooding/nationalstrate gy/guidance/climateguide/?lang=en Bridgend County Council LDP
Brecon Beacons National Park Authority LDP
Carmarthenshire County Council LDP Community Engagement Toolkit: This provides best practice for community involvement in flood and coastal erosion risk management, available from http://wales.gov.uk/topics/environmentcountryside/epq/waterflooding//flooding/communities/t oolkit?lang=en Guidance on the transfer of Ordinary Watercourse Regulatory Powers for Lead Local Flood Authorities in Wales. Environment Agency Flood and Coastal Risk Management Strategies
Environment Agency Coastal Risk Management Plans
4.2. BASELINE INFORMATION
The baseline information identifies current environmental issues and problems in the area which should be addressed in the LFRMS/SEA and provides a basis for predicting and monitoring the effects of implementing the Strategy. The baseline has been updated during the SEA process as new information has emerged and/or as additional issues come to light, primarily as a result of consultation undertaken on the SEA Scoping Report.
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4.2.1. Population And Human Health
a) Summary
In 2011, City and County of Swansea had an estimated population of 239,000 having increased by 6.9% since the 2001 census figure. This rate of increase is lower than both the equivalent regional and national figure.
The age distribution and population structure in City and County of Swansea generally mirrors of Wales at large. The principle features being:
a greater number of females than males in the elderly population;
higher ‘middle age’ populations relative to younger generations - a general indication that the population is getting older as the large numbers of people born in the post-war ‘baby boom’ near retirement age.
b) Influence of the LFRMS on the population and human health Population increase within City and County of Swansea will inevitably put pressure on, and demand the expansion of, the provision of accommodation and associated infrastructure to meet the needs of the local population. This has proved a significant constraint upon the potential objectives and measures considered as part of the LFRMS. Policy options have attempted to complement local development plans and ensure the needs of the population are met in a sustainable manner.
The LFRMS will have a positive impact upon human health. Through the tangible benefits of reduced injuries/deaths from flooding incidents to the more intangible aspects of stress and anxiety reduction for those living with the threat of flooding.
Where possible, the LFRMS has attempted to create policies/measures that assist in increasing the accessibility of green space to local residents.
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4.2.2. Biodiversity, Flora And Fauna
a) Summary
There are currently 2 RAMSAR sites in the City and County of Swansea. They are:- Crymlyn Bog, and the Burry Inlet. Neither are currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourses.
Special Areas of Conservation (SAC) are identified on the basis of scientific criteria as set out in the European Commission Birds and Habitats Directives and the subsequent Conservation (Natural Habitats) Regulations 1994. They may be designated on any area of land of special interest for its flora, fauna, geological, or physiographic features and are notified by the Countryside Council for Wales (CCW) as part of a European series of important sites.
Within City and County of Swansea) there are five SACs. They are:- Crymlyn Bog Gower Ash Woods Carmarthen Bay Dunes Gower Common, and Limestone Coast of South West Wales
Rhossili and Parkmill are currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourses.
Sites of Special Scientific Interest (SSSI) are identified on the basis of scientific criteria as set out in Section 28 of the Wildlife and Countryside ACT 1981 and may be designated on any area of land of special interest for its flora, fauna, geological or physiographic features. SSSIs are notified by the Countryside Council for Wales (CCW), as part of a British set of important sites. There are 32 SSSIs in City and County of Swansea. Rhossili, Parkmill and Swansea Bay (not Crymlyn Bog) are currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourses.
Z:\Committees\A Agenda Pack\Cabinet\2012-13\11 - 13 March 28\05 g.2 - LFRMS - Appendix B - LINK ONLY.doc REF: ISSUE: AUTHOR: DATE: PAGE: ENV report draft PT/SP Nov 12 20 of 46 Appendix B The Gower is recognised as an Area of Natural Outstanding Beauty (ANOB ) where Rhossili and Parkmill are currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourse.
The Burry Inlet is designated as a Special Protection Area and is not currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourse.
Local Nature Reserves (LNR) are owned or managed by City and County of Swansea. There are currently six LNRs in City and County of Swansea, at:-
Cadle Heath Killay Marsh Cwmllwyd Wood Mumbles Hill Bishops Wood, and Pwlldu cliffs
Wildlife Trust for South and West Wales Nature Reserves are owned or leased by the Trust and managed for nature conservation. At present there are 24 Trust reserves in City and County of Swansea.
Sites of Importance for Nature Conservation (SINC ) are a local authority planning designation relating to Policy AW8 of City and County of Swansea’s Local Development Plan (see also the Nature Conservation Supplementary Planning Guidance for the LDP) and identified against adopted selection criteria. 100 SINCs have been formally defined in City and County of Swansea. Action for Nature : Swansea’s Local Biodiversity Action Plan provides an important biodiversity context for the City and County Council.
b) Influence of the LFRMS on biodiversity, flora and fauna
The LFRMS has adopted a multitude of policy options in order to manage flood risk. These range from the potential for adopting innovative land management techniques through to the construction of physical defences. It could be argued that any option, which affects the landscape or alters the hydrological regime within that landscape, has the potential to have both positive and detrimental effects upon biodiversity.
Z:\Committees\A Agenda Pack\Cabinet\2012-13\11 - 13 March 28\05 g.2 - LFRMS - Appendix B - LINK ONLY.doc REF: ISSUE: AUTHOR: DATE: PAGE: ENV report draft PT/SP Nov 12 21 of 46 Appendix B When developing LFRMS options, due regard has been given to the likely sensitivity of biodiversity to the potential changes being proposed, or indeed likely opportunities for ecosystem enhancement should be sought in support of the Local Biodiversity Action Plan.
4.2.3. SOILS, GEOLOGY AND LAND USE
a) Summary
Soils play a critical role in the quality of water within a catchment and the degree of surface/sub-surface runoff. Fundamentally, shallow, compacted soils will not retain and hence slow the response of rainfall events the degree that a deep, loosely compacted soil would. Thus, the permeability of a catchment soil has an influence on the overall rainfall runoff catchment response.
The soils within Swansea range from peats in the upland areas to lime rich loamy soils on the coastal plains, with the majority of the county underlain by brown soils and surface water gleys. The brown soils are typically well- drained loamy soils. The surface water gleys are found in low ground such as valley bottoms and are seasonally wet due to slowly permeable subsoil. In addition to these predominant soils, some of the coastal areas such as the Loughor Estuary are underlain by groundwater gleys, which experience seasonal water logging on account of high groundwater levels.
b) Influence of the LFRMS on soils, geology and land use
The LFRMS will seek to maintain and where possible enhance soil quality within the City and County Council area. This process may develop as a by-product of specific techniques which additionally enhance flood risk management. Certain policies may have a degrading affect upon soil quality, for instance through construction activities to implement flood defence measures, but these are anticipated to be short term in nature.
The LFRMS should be mindful of the constraints resulting from the presence of the many potentially contaminated brownfield sites within City and County of Swansea. LFRMS options will, where possible, seek opportunities to enhance flood risk measures when redevelopment of brownfield sites is being considered.
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4.2.4. WATER
a) Summary
Water resources are primarily extracted from the major river systems, small minor reservoirs and groundwater resources. Many of the river catchments have or are recovering from historical degradation caused by the coal, iron and other industries. Given that historical industrial development largely occurred close to the river banks there has subsequently been extensive anthropogenic modifications made to the riparian zones with subsequent loss of habitat. Since the demise of heavy industry within City and County of Swansea, there have been general improvements in water quality, in some instances allowing the return of salmon and the provision of spawning and nursery areas. However, rivers remain vulnerable to both diffuse and point source pollution from various catchment sources.
Water quality issues attributable to the local sewer network (principally the issues resultant from the discharge of Combined Sewer Overflows [CSOs] and water quality issues downstream of water treatment works) are significant at some locations.
b) Influence of the LFRMS on water
The LFRMS is unlikely to have a profound affect on water resources within City and County of Swansea. However, potential options to promote the use of SuDS that mimic natural drainage processes may enhance the availability of groundwater and prevent pollution reaching watercourses and aquifers.
Reduction in the amount of sediment entering watercourses is also likely to be a by-product of implementing best-practice land management techniques and the greater use of SuDS.
Additionally, changes in flood frequency attributable to LFRMS objectives may assist in waterbodies attaining required WFD ‘good’ or ‘no deterioration’ status by, for example, reducing the amount of surface water entering combined sewer systems.
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a) Summary
Initial assessment of flood sources within the City and County of Swansea indicates that flooding is mainly fluvial or tidal. However, to a lesser extent, a flood risk from overland flow exists within the area and flood risk from groundwater is considered minimal.
There are localised sewer flooding issues within the area due to limited sewer capacity. However, this is not a significant issue for the County.
The City and County of Swansea’s Preliminary Flood Risk Assessment (PFRA) found that historical records, on past flooding events, indicated that flooding from local sources were not clearly defined, making it difficult to quantify past flooding with any degree of certainty. Areas within the County with the highest number of recorded incidents of historical flooding from surface water or overland flow are:- Oxwich Manselton Gorseinon Sketty Crofty, and Penllergaer. These incidents relate to isolated pinch points within the public sewerage system.
Some areas of the County are known to experience surface water flooding issues. The areas that have been subject to the most severe flooding are:- Blackpill Parkmill Cockett Llansamlet/Jersey Road Gorseinon
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In terms of predicted flooding, the Authority has agreed with the National Surface Water Datasets provided by Environment Agency Wales (EAW) to be the most representative surface water information available to the Authority. The Flood Maps for Surface Water correlates well to the local information indicated that it is suitable to use for assessment of the County.
There are currently 4,589 properties within the extreme outline for Swansea (3,939 residential and 650 commercial ). This represents 1 in 25 of all properties in Swansea. EAW has identified the high risk areas in Swansea to be:- Morriston, Hafod, and Gorseinon (at risk from River flooding) the City Centre (both from river and sea), and Blackpill on the Swansea Bay area (from sea).
The EAW published a map indicating the Areas Susceptible to Surface Water Flooding (ASTSWF) in 2009, showing flooding typically associated with areas of lower ground, which coincides in many areas with the larger watercourses. There are relatively significant areas potentially susceptible to surface water flooding in the Tawe corridor, such as Morriston and Llansamlet.
Also areas adjacent to the River Loughor and/or the River Lliw/Llan in and around Pontardulais, Gowerton and Gorseinon. There are relatively significant ASTSWF in the southern areas of Swansea, such as Blackpill, Sketty, Brynmill, St Helens and the dock areas as well the Crymlyn Bog nature reserve to the north of the docks.
EAW has also provided information on other potential areas which exceed the Flood Risk Thresholds (FRT). Number of people > 200 Critical Services > 1 Number of Non-Residential Properties > 20
Z:\Committees\A Agenda Pack\Cabinet\2012-13\11 - 13 March 28\05 g.2 - LFRMS - Appendix B - LINK ONLY.doc REF: ISSUE: AUTHOR: DATE: PAGE: ENV report draft PT/SP Nov 12 25 of 46 Appendix B Places above FRT provided by EAW have been identified based on the new Flood Map for Surface Water (30cm deep water at a 1 in 200 annual probability rainfall) and this information is contained within the Authority’s PFRA. EAW has identified one indicative area within the administrative boundary of the City and County of Swansea. This satisfies the national threshold of more than 5,000 people being considered at risk of flooding. The Indicative Flood Risk Area in the main represents surface water flooding in the most urbanised area of Swansea, with the consequences of flooding affecting 6962 population, equivalent to 2975 properties.
Within the County there are two main River Basin Catchments, namely the River Tawe and River Loughor. EAW have produced Catchment Flood Management Plans (CFMP) to examine flood risks from these two main rivers. The Ogmore to Tawe CFMP states that within Swansea more than 1000 properties are at risk from tidal flooding in central Swansea and between 100-500 properties from fluvial flooding in Swansea Vale from a 1% annual event probability (AEP) flood event (1% AEP flood event has a 0.01 probability of occurring in any one year). The Loughor to Taf CFMP estimates that currently there are 25-50 properties at risk from a 1% AEP flood event in Gower.
b) Influence of the LFRMS on flood risk
The LFRMS will, by definition, have a positive impact upon flooding in City and County of Swansea. However, when developed in more detail, potential project options may advocate’ no intervention’ policies whereby risk based decisions are made not to manage flood risk in particular areas. Indeed, options to increase flooding in areas where necessary to protect downstream regions could potentially be advocated.
4.2.6. CLIMATIC FACTORS
a) Summary
Globally there has been around a 1°C rise in averag e global temperature, but the latest climate change science indicates that unless emissions of greenhouse gases are quickly reduced, the world will probably be another 3°C hotter by 2060 and there will be much higher risks of catastrophic global climate changes. WGs Climate Change Strategy indicates that the impacts that can be expected from climate change are:-
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PPW states that the UK Climate Impacts Programme (UKCIP) has published a series of scenarios, which projects the climate in 2080 that Wales could experience:- Average temperature increase 1.5 - 4.5°C Hot summers (similar to 1995) up to 2 years in 3 Dry summers (similar to 1995) up to 1 year in 2 Milder winters Reduction of snowfall - down by 50 - 90 per cent Increase in winter rainfall by up to 20 per cent Frequency of winter intense rainfall events - doubling from 1.5 to 3 events per winter Decreasing annual soil moisture content by up to 20 per cent Increase in average length of thermal growing season by 40 - 100 days Sea level rise of 23 -36 cm. (Including vertical land movement, the net sea level rise likely to be 11 - 71 cm) b) Influence of the LFRMS on climatic factors
The LFRMS needs to consider and enable a wider adaptation to climate change.
4.2.7. MATERIAL ASSETS
a) Summary
Material assets relevant to the LFRMS include buildings and infrastructure in City and County of Swansea that could potentially be affected by flooding. The LFRMS should also consider whether its policies could lead to an increase in use of resources, such as mineral aggregates, or to increased waste production. Development of new infrastructure such as roads has flood risk management implications due to the potential for increased runoff. New developments are required to take account of flood risk management implications including provision of sustainable drainage.
Z:\Committees\A Agenda Pack\Cabinet\2012-13\11 - 13 March 28\05 g.2 - LFRMS - Appendix B - LINK ONLY.doc REF: ISSUE: AUTHOR: DATE: PAGE: ENV report draft PT/SP Nov 12 27 of 46 Appendix B The term 'green infrastructure' refers to strategically planned green spaces which deliver multiple functions, including flood alleviation, wildlife habitat and access to nature, local food production (allotments), space for recreation, environmental education and improved health and well-being. The LDP recognises a shortfall in open space in many parts of the county.
Infrastructure forms the physical basis for sustainable communities, comprising water supplies, sewerage and associated wastewater treatment facilities, waste management facilities, energy generation, distribution and supply, transport and distribution networks and telecommunications. One of the objectives of Planning Policy Wales (2011) is to ensure that the vulnerability of infrastructure to severe weather events is minimised and that infrastructure is designed to cope with higher average temperatures and increasing risk of storm surges, drought and flooding.
Roads Data for 2010 indicates that Swansea contains a total of 1085.8km of public highways which are managed by the Highways Authority. Swansea does not contain any trunk roads but has 102.1km of A-roads, 98.3km of B roads, 129.8 km of C roads and 755.6km of minor surfaced roads.
The majority of the roads are within built-up areas (781.6km). The M4 motorway passes through the county and has six motorway junctions, resulting in a direct link to Cardiff, London and major airports to the east of Swansea.
Major transport links currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourse are:- a) A483 - Fabian way b) A483 – Carmarthen Road c) A4067 - Oystermouth and Mumbles Road d) A4067 - Oystermouth and Mumbles road
Rail The South Wales main railway line terminates at Swansea and there are several train stations on this line that are key property assets to the region. The Line between Swansea and Llanelli is currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourses.
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Port
The port at Swansea is owned and operated by Associated British Ports (ABP) and has a trade base with north-west Europe, Ireland and the Mediterranean. The port caters for ships up to 30,000 tonnes and benefits from a sizeable tidal window. The port handles a variety of cargo, from agribulks and coal to timber and steel. It is equipped with a wide range of heavy-duty modern cargo handling equipment, quayside cranes, cargo- sheds, large open-storage areas, a dedicated container berth, two dry docks, and a roll-on roll-off Ferry port terminal able to cater for passengers, cars and freight traffic.
Housing
It is estimated that the total number of dwellings in Wales continues to grow steadily, with an estimated 1.35 million dwellings at the 31 March 2011, which represents an increase of 6 % since 2000-01.
In the City & County of Swansea, dwelling stock estimates by tenure at 31 st March 2011 were 106,024 . This figure is broken down as follows:
13,629 properties rented from the local authority; 6,824 properties rented from registered social landlords and 85,571 are owner occupied, privately rented, intermediate and other tenures
Utilities Infrastructure
Adequate utilities provision across the County is essential to enable the future delivery of services and development, including employment sites, housing, renewable energy projects and so forth
Public Rights of Way
The Countryside and Rights of Way Act, 2000, gave Highway Authorities the responsibility of producing a Rights of Way Improvement Plan by 2007. The Council fulfilled that duty by publishing a Rights of Way Improvement Plan entitled ‘Countryside Access Plan 2007-2011’ which addressed public access in the countryside in the broad sense. Public rights of way are available to the following users:
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The present registered path network within Swansea is 385 miles (617km long) and is mostly comprised of footpaths (78.9%). There are also 80 miles (128km) of bridleways (20.8% of the network) and one and a quarter miles of byways open to all traffic (0.3%). The Gower AONB contains approximately 66% of the overall path network. Approximately 5% of the path network is on land owned by and therefore wholly under the control of, the Council.
As well as having the right to use bridleways and byways Swansea has approximately 60km of cycle paths for cyclists, including the national bike routes 4 (the Celtic trail west and east) and 43 (Celtic trail east) and proposed route 439.
b) Influence of the LFRMS on material assets
The LFRMS has attempted to manage the flood risk to material assets and it is therefore anticipated that the LFRMS will have a positive influence on infrastructure and assets. However, the protection of assets is likely to be prioritised differently and the extent of any positive effects may be variable.
4.2.8. CULTURAL HERITAGE
a) Summary
The management of City and County of Swansea’s historic landscape, which features Listed Buildings and Conservation Areas, is important to protect the setting in which people live. There are a large number of sites of cultural and historic importance across City and County of Swansea, these include:
516Listed Buildings are distributed across the whole of City and County of Swansea. 5 of these areas currently identified as being affected by flooding from surface water runoff, groundwater and ordinary watercourses. 40 buildings currently ‘at risk’ (‘at risk and ‘newly at risk’) according to the Buildings at Risk Register. This accounts for 8% of the total 500 surveyed Listed Buildings.
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b) Influence of the LFRMS on cultural heritage
The LFRMS will endeavour to maintain, or where possible enhance the status of City and County of Swansea’s cultural heritage.
4.2.9. LANDSCAPE AND VISUAL AMENITY
a) Summary
City and County of Swansea LANDMAP Landscape Assessment confirms that the region contains significant areas of landscape that are of local and potentially regional importance.
The assessment identifies all the open and green spaces across Swansea in accordance with the TAN guidelines. These include all publically accessible naturally green space that people have access to. These will include:- Parks Beaches nature reserves commons amenity areas sports complexes, and environmental education centres.
The LFRMS should aim to maintain or enhance landscape character of the City and County of Swansea.
b) Influence of the LFRMS on landscape and visual amenity
The LFRMS has the potential to have both positive and negative impacts on landscape features.
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4.2.10. AIR QUALITY
The Strategic Environmental Assessment undertaken in parallel with the Welsh Governments National Flood Risk Management Strategy stated that detrimental impacts on air quality attributable to the National Flood Risk Management Strategy were unlikely and it was subsequently scoped out of the assessment. Similarly, having undertaken the baseline assessment, it has been concluded that affects on air quality from the LFRMS are unlikely, and it is proposed to scope this theme out of the SEA assessment.
4.3. STRATEGIC ENVIRONMENTAL OBJECTIVES AND ASSESSMENT FRAMEWORK
Key environmental issues have been identified and used correspondingly with the review of other relevant plans, policies and programmes to develop a set of SEA objectives. The following tables summarises how the assessment of key plans, programmes and policies together with baseline information has been used to develop the SEA objectives.
The SEA framework has been developed based on the information gathered so far and shows the relationship between the following:
Each of the identified SEA objectives;
The key questions that have to be asked of each LFRMS policy to assess its relationship with the SEA objectives; and
The indicators to be used to monitor the success of the LFRMS.
.
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Proposed SEA Objectives, Indicator Questions and Potential Indicators
SEA Topic Key Messages from Plans and Environmental Baseline Key Proposed SEA Objective Indicator Questions Potential Indicators Area Programmes Issues
An ageing population SEA Objective 1 : Ensure that • Will the measure help to maintain creates challenges in access to support and facilities or enhance access to facilities for • Average travel time to key services, eg, • Promote access to countryside relation to providing is maintained particularly for the elderly and other vulnerable public services, health services, etc. and coast, amenity, leisure support, appropriate more vulnerable sectors of groups? and sports facilities and open accommodation and community and green space so as to accessible services. improve the quality of life and • Number of properties at risk of flooding Population growth and well being, particularly through now and in the future reduction in household size public transport. is creating a significant • Number of business at risk of flooding now • Ensure sustainable need for additional and in the future development and economic accommodation. • Will the measure help avoid or • Number of new developments permitted in growth for all communities with SEA Objective 2 : Ensure that Key health issues for the mitigate the impact of coastal, river flood zones the need for coordinated new development is directed to and sewer flooding on new population need to be • Population action at national, regional and considered ie., Mental reasonably available sites at the developments? Number of new developments permitted and local levels. lowest probability of flooding, contrary to EA Wales advice health, disabilities, • Will the measure promote Human • and that development promotes • Promote fair and safe equalities deprivation and sustainable development Number of properties and business offered Health sustainable water management communities and equal poverty, etc., as these practices? increased flood risk protection as a result opportunities addressing local groups may be more of new flood defences in the City & County needs and priorities, reflecting disadvantaged than others of Swansea and the effectiveness of flood the opportunities available and during and after a flood warning systems. the aspirations of local citizens event. • Number of permitted developments and future citizens. Public Health issues from incorporating SUDS • Reduce the impacts on water borne diseases as a individuals, communities and consequence of a flood • Participation in any activity businesses from flooding and event. • Physical activity rates coastal erosion and ensure a SEA Objective 3 : Protect and • Provision of recreational • Will the measure protect or sustained response to flood enhance human health and • Maintenance, improvement and perceived facilities, including open enhance recreational facilities? and coastal erosion events. spaces and cycle/walking wellbeing. quality of recreational/leisure facilities rotes, to encourage • Area/number of recreational and amenity physical activity facilities affected by flooding
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SEA Topic Key Messages from Plans and Environmental Baseline Key Proposed SEA Objective Indicator Questions Potential Indicators Area Programmes Issues
• Protection and enhancement of biodiversity, particularly internationally • Changes in conditions of designated and nationally designated sites. • Will the measure help to protect sites / BAP habitats designated and BAP habitats? • To achieve favourable condition for • Number of opportunities to create or priority habitats and species. • The need to prevent habitat • Will the measure improve restore habitat sites fragmentation and enhance conditions for priority species? • Avoidance of activities likely to cause • Area of designated sites / BAP habitats habitat connectivity. Bio- irreversible damage to natural heritage. • Will the measure enhance in areas at risk of flooding (noting that diversity, • The need to protect and SEA Objective 4 : Protect and habitats, for example through some habitats prefer areas of flood • Support well-functioning ecosystems, Flora & enhance biodiversity and enhance biodiversity reducing habitat fragmentation? risk) respect environmental limits and Fauna habitats, particularly capacities, and maintain/enhance • Will the measure function • Achievement of Local BAP targets designated habitats and BAP coherent ecological networks, including alongside and within habitats. • Waterbody status (ecological, chemical provision for fish passage and environmental limits and and biological) connectivity for migratory/mobile species. capacities, enabling ecosystem services provision? • Area of ecological enhancement as a • Promote approaches to flood and erosion result of the LFRMS measures management which conserve the natural environment and improve biodiversity.
• Maintain the quality and diversity of geology and soils, which can be lost or damaged by insensitive development. • Ensure that soils will be protected and managed to optimise the varied functions • that soils perform for society (e.g. Changes in conditions of designated • supporting agriculture and forestry, Will the measure protect or sites • The need to minimise the protecting cultural heritage, supporting enhance designated geodiversity • continued loss of soils and the Area of designated sites in areas at biodiversity, as a platform for sites? habitats they sustain. risk of flooding (noting that some construction), in keeping with the • Will the measure result in loss of habitats prefer areas of flood risk). principles of sustainable development. • The need to protect and good agricultural land or greenfield • Number of opportunities to create or enhance geological diversity. land? • Promote settlement patterns that SEA Objective 5 : Maintain and restore geodiversity sites. Soils, minimise land-take (especially extensions • The need to prevent / or enhance geodiversity and • Will the measure maintain low Geology • Area of grade 1, 2 or 3 soil lost dues to to the area of impermeable surfaces) and sterilisation or otherwise where possible protect best quality soil where it is enabling and Land introduction of flood management urban sprawl, especially through prevent the use and quality soil and natural mineral important habitats? Use measures preference for the re-use of suitable exploitation of natural resources. • Will the measure sterilise the previously developed land and buildings, resource. • Changes in area of BAP habitats wherever possible avoiding development availability of any natural • The need to avoid adverse on greenfield sites. resources? • Number of extraction permits declined impacts on habitat due to flood risk management • • Will the measure allow a holistic Effective soil management can help enhancement/creation at measures. manage flood risk through reduced disused sites. approach to catchment compaction reducing runoff rates and management? • Number of developments with Soil encouraging infiltration. Management Plans in place. • Promote catchment-wide approach to land management by relevant stakeholders, in order to benefit natural resources, reduce pollution, develop resilience to climate change
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SEA Topic Key Messages from Plans and Environmental Baseline Key Proposed SEA Objective Indicator Questions Potential Indicators Area Programmes Issues
• Maintain and improve water quality • Number of properties at risk of flooding (surface waters and groundwater). now and in the future • Will the measure reduce the risk of • Enhance the status and prevent further SEA Objective 6: Manage • Number of business at risk of flooding • flooding in coordination with other deterioration of aquatic ecosystems and The need to support the surface water flood risk now and in the future flood strategies? associated wetlands, which depend on objectives and strategies of alongside strategies to • Number of new developments the aquatic ecosystems. the CFMPs and SMP. manage coastal and fluvial • Will the measure promote permitted in flood zones • flood risk, taking a whole awareness of flood risk and • Promote the sustainable use of water (for The need to avoid creating catchment approach to risk potential actions to manage flood • Number of new developments example by promoting increased uptake barriers to fish migration. and awareness risk and surface water runoff? permitted contrary to EA Wales advice of and better standards for sustainable • The need to avoid placing drainage systems (SuDS)). increased pressure on water • Number of permitted developments • available for abstraction (and incorporating SUDS Water Identify existing flood regulating services provided by the water environment and if possible, help to reduce promote integration into flood risk existing pressures). management approaches (e.g. • The need to improve or • WFD Water body status parameters catchment approaches to water and flood prevent deterioration in the Will the measure affect water (contributory elements of chemical and risk management). status of WFD waterbodies SEA Objective 7 : Improve or quality, quantity, hydromorphology ecological status) as monitored by • within the catchment. Provide a comprehensive, sustainable prevent deterioration in WFD or biology, taking into account Environment Agency Wales. approach to flood management that is • Consider the Bathing Water waterbody status Bathing potential impacts of improved • Bathing Water Directive status resilient to climate change and based on Directive. Water Directive status. drainage on water quality in surface the principles of risk management. waters and bathing waters? parameters as monitored by Environment Agency Wales. • Raise awareness of and engage people in the response to flood and coastal erosion risk. • Mitigate impacts on climate change by • reducing emissions and supporting the Area of floodplains now and in the use of sustainable/ renewable energy future (cut greenhouse gas emissions by 3% • Number of properties at risk of flooding per year in areas of devolved now and in the future competence). Will the measure enable or promote • Number of business at risk of flooding Climatic • Mitigate and adapt to the consequences The need to enable wider SEA Objective 8 : Enable adaptation to climate change, for now and in the future Factors of climate change by building resilience adaptation to climate change. adaptation to the impacts of example through provision of • Number of new developments into future planning of the natural and climate change improved drainage? built environment and consider the level permitted in flood zones of urgency of associated risks • Number of new developments accordingly (e.g. managing increased permitted contrary to EA Wales advice flood risk on key assets such as schools, hospitals, housing stock, businesses, • Number of permitted developments land management). incorporating SUDS
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SEA Topic Environmental Baseline Key Messages from Plans and Programmes Proposed SEA Objective Indicator Questions Potential Indicators Area Key Issues
• Will the measure reduce flood risk to • Length of key transport key transport infrastructure? • Promote sustainable production and consumption infrastructure in areas of flood risk • whilst seeking to reduce the amount of waste Will the measure reduce flood risk to now and in the future key infrastructure assets such as generated by using materials (including SEA Objective 9 : Ensure the • Number of key infrastructure assets potential impact of flooding on water, electricity and gas plant? aggregates, minerals and soils), energy and • Protection of key in areas of flood risk now and in the existing and future water more efficiently. infrastructure assets from • Does the measure manage surface future infrastructure is minimised increased risk of flooding. water flood risk? • Minimise the production of waste, ensure waste • Number and severity of flood Material management is in line with the ‘waste hierarchy’, • Impacts of new infrastructure • Does the measure encourage the incidents leading to disruption of Assets eliminate waste sent to landfill, promote good and development on runoff. implementation of SUDS for existing service provision environmental management and best and new infrastructure assets? environmental practice. • A shortfall in open space for recreation and play. • Maximise the use of renewable resources, SEA Objective 10: Use including sustainable materials (recycled and • • renewable materials and those with a lower materials efficiently, minimise Will the measure incorporate use of Volume of waste embodied energy). waste production and recycled/reused materials arising/recycled/reused materials maximise reuse and recycling
• Ensure the conservation of the historic environment, historic landscapes and cultural • The need to support ongoing heritage, acknowledging and fostering local schemes to preserve and enhance the cultural heritage diversity. • Will the measure have an adverse of the City & County of • Changes in condition of designated • SEA Objective 11 : Protect impact on designated and non- Built development in the vicinity of historic Swansea sites directly or indirectly related to cultural heritage including designated heritage and landscape Cultural buildings could have implications for the setting flood incidents Heritage and/or built fabric. • The need to minimise designated and non- assets, e.g. through excavation? adverse impacts on known designated, known and • Number of designated sites in areas • • Will the measure affect the setting of Reduce and manage the risks that floods pose and potential (such as unknown assets of flood risk, now and in the future cultural heritage assets? to, cultural heritage. archaeological deposits) • Ensure effects resulting from changes to water cultural heritage now and in flow/level (surface or sub-surface) on all historical the future. and cultural assets are avoided.
• Protection and enhancement of landscape (including designated landscapes, townscapes, landscape character, distinctiveness and the countryside) • Take account of the different roles and character of different areas, promoting the vitality of main The need to maintain or Landscape SEA Objective 12: Maintain Will the measure affect the visual Perceived changes to landscape urban areas, protecting the Green Belts around enhance the landscape and and Visual and / or enhance the quality characteristics of notable landscapes quality, for example through them, recognising the intrinsic character and visual amenity of the City & Amenity and character of landscape in in the City & County of Swansea? landscape character assessment beauty of the countryside and supporting thriving County of Swansea. the City & County of Swansea rural communities within it. • Promote access/awareness and perceived value/understanding of areas of landscape character and open/green spaces landscapes in sustainable ways to enhance its enjoyment and value by visitors and stakeholders.
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5. SEA ASSESSMENT METHOD
5.1. LFRMS/SEA STAGES
The development of the draft LFRMS was undertaken in parallel with the SEA process. The following table presents the various stages undertaken in the LFRMS and how the SEA has inputted into this development process.
PRINCIPLE STAGES IN THE LFRMS DEVELOPMENT PROCESS AND SEA ACTIVITIES
Strategic environmental LFRMS Stage Description assessment (SEA) Activities
Characterisation of flooding The Scoping work for the Developing an and wider environmental SEA process was understanding of the local issues within City and undertaken alongside the flood risk within City and County of Swansea and at data gathering phase of the County of Swansea. a wider catchment scale. LFRMS.
Developing a set of Main stage (this report) of objectives to manage flood Objective setting for the SEA process was risk and achieve, where managing flood risk. undertaken alongside the possible, improvements to objective setting for the wider environment.
5.2. SCENARIO
Given the high-level nature of the LFRMS, which sets out objectives undefined in terms of their spatial and geographical extent, it is difficult at this point in time to develop a set of “reasonable alternatives” or scenarios to the objectives presented in the LFRMS.
Rather than undertake an SEA assessment which incorporates an alternative scenario, City and County of Swansea proposed to undertake the SEA assessment by comparing the preferred approach against the ‘do nothing; scenario. The ‘do nothing’ scenario essentially represents the future state of the environment without implementation of the LFRMS. Given that the LFRMS is likely to generate further, more detailed plans and projects, it would be anticipated that assessment of alternative scenarios would be undertaken during any SEA process carried out at the appropriate point in the future.
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5.3. ASSESSMENT METHODOLOGY
The SEA will assess the likely environmental effects of LFRMS objectives against the SEA objectives selected in the SEA Framework. An additional assessment of the likely state of the environment under the ‘do nothing’ scenario will be undertaken.
It is proposed that each assessment will be presented in a tabular format as shown below. Impacts will be colour coded as indicated below:
++ Major Positive
+ Positive
/ Uncertain
- Negative
# Major negative
0 No Impact
EXAMPLES OF SEA ASSESSMENT MATRIX
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short 0 0 0 0 0 0 0 0 0 0 0 0
Do nothing Medium - 0 - 0 0 - 0 - - 0 0 0
Long - # - - # # - - # # - -
Short 0 + 0 + 0 + 0 0 0 + ++ 0 Implement LFRMS Medium / / ++ + + + 0 + + + + + Objective Long + ++ + + + + + + + + / /
Summary A brief summary of the primary positive and negative effects of each objective will be provided here.
The SEA will reflect the timescale over the policies, objective and strategies of the LFRMS will be implemented. It is intended that three time periods will be used to reflect this in the assessment of the LRFMS. These time periods are indicated as S, M and L in the matrix above which represent:-
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S – Short term – present to 2018
M – medium term – 2018 to 2033
L – Long term – 2033 and beyond.
6. LOCAL FLOOD RISK MANAGEMENT STRATEGY OBJECTIVES
The City and County of Swansea Local Flood Risk Management Strategy presents eight detailed objectives which outline how the Authority intends to manage flood risk within this LFRMS cycle. These objectives adhere to the high level objectives set out in the Welsh Government’s National Strategy for Flood and Coastal Erosion Risk Management and the ambitions of City and County of Swansea Community Strategy. The following table show the eight detailed objectives.
CITY AND COUNTY OF SWANSEA LFRMS STRATEGIC OBJECTIVES
To improve the understanding of Flood and Coastal risks and to ensure that 1 all stakeholders understand their roles and responsibilities in relation to Flood and Coastal risk management.
To work together with other flood risk management Authorities to reduce flood 2 risk, using all available resources and funds in an integrated way and in so doing derive overall benefit.
Develop policies for effective land use and management and enhance development control procedures. To prevent an increase in flood risk as a 3 result of development by preventing additional flow entering existing drainage systems and watercourses whenever possible.
Established regular maintenance schedules for flood and coastal erosion risk 4 management assets.
Raising awareness of and engaging people in response to flood and coastal 5 erosion risk.
6 Enhance property and community level of resilience.
Take a sustainable and holistic approach to flood and coastal management, 7 seeking to deliver wider environmental and social benefits.
8 Prioritising investment in the most at risk communities.
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7. ASSESSMENT OF LOCAL FLOOD RISK MANAGEMENT STRATEGY OBJECTIVES
7.1. ASSESSMENT OBJECTIVES
There are eight detailed objectives contained within City and County of Swansea’s Local Flood Risk Management Strategy. The following section assess the likely impact of each of the LFRMS objectives in accordance with the framework outline in 4.3
LFRMS Objective 1:- To improve the understanding of Flood and Coastal risks and to ensure that all stakeholders understand their roles and responsibilities in relation to Flood and Coastal risk management.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short / - / / 0 - - 0 - 0 / 0
Do nothing Medium - - / / / - - / - 0 - 0
Long - - - - / # - - # 0 - /
Short / + / + / + + 0 + / + 0 Implement LFRMS Medium + + + + + + + / + / + 0 Objective Long + ++ + + + ++ + + ++ / + /
Summary:- If all stakeholders understand their key roles and responsibilities in managing flood risk, the potential to minimise impact will significantly improve. Hence the positive impacts identified in SEA Objectives 2, 6 and 9.
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LFRMS Objective 2:- To work together with other flood risk management Authorities to reduce flood risk, using all available resources and funds in an integrated way and in so doing derive overall benefit.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short 0 - - 0 0 - - 0 - 0 0 0
Do nothing Medium 0 - - / / - - / - 0 - -
Long / # - / / # - - - / - -
Short 0 + + + 0 + + / + 0 + 0 Implement LFRMS Medium 0 ++ ++ + / ++ + + + / + + Objective Long / ++ ++ + / ++ + + ++ / + +
Summary:- The assessment and prioritisation of potential flood risk management solutions should enable schemes to maximise social and environmental benefits and enhance human health and wellbeing and the environment. The ‘do nothing’ scenario assumes that the status of a number of SEA objectives will deteriorate over a period of time.
LFRMS Objective 3:-. Develop policies for effective land use and management and enhance development control procedures. To prevent an increase in flood risk as a result of development by preventing additional flow entering existing drainage systems and watercourses whenever possible.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short 0 - - 0 0 - - 0 - 0 / /
Do nothing Medium 0 # - - / # - / - 0 - -
Long 0 # # - / # - / - 0 - -
Short 0 + + + 0 ++ + + + / / / Implement LFRMS Medium 0 ++ + + / ++ + + + + + + Objective Long 0 ++ ++ ++ / ++ + + + + + +
Summary:- As expected, strong positive impacts will occur to SEA Objectives 2, 3, 4 and 6. The ‘do nothing’ scenario assumes that the status of a number of SEA objectives will deteriorate over a period of time.
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LFRMS Objective 4:-. Established regular maintenance schedules for flood and coastal erosion risk management assets.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short - / - - 0 - - - - 0 - /
Do nothing Medium - - - - / - # - - 0 - /
Long - - # - / - # - # / - -
Short + / + + 0 + + + + 0 + + Implement LFRMS Medium + + + + / + ++ + + 0 + + Objective Long ++ + + + / + ++ + ++ / + +
Summary:- This has a positive impact across the majority of the SEA objectives. The ‘do nothing’ scenario is not an option.
LFRMS Objective 5:-. Raising awareness of and engaging people in response to flood and coastal erosion risk.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short 0 - - 0 0 - - 0 - 0 / /
Do nothing Medium 0 # - - / # - / - 0 - -
Long 0 # # - / # - / - 0 - -
Short 0 + + + 0 ++ + + + / / / Implement LFRMS Medium 0 ++ + + / ++ + + + + + + Objective Long 0 ++ ++ ++ / ++ + + + + + +
Summary:- The principle positive impacts results are the protection and enhancement of human health and well being, bio diversity, flora and fauna, protection of infrastructure and a community based understanding of the risks of flooding and their consequences.
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LFRMS Objective 6:- Enhance property and community level of resilience.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short - 0 # 0 0 - 0 0 0 0 0 0
Do nothing Medium - - # 0 0 - 0 - 0 0 0 0
Long - # # 0 0 - 0 - 0 0 0 0
Short ++ 0 ++ 0 0 + 0 0 0 0 0 0 Implement LFRMS Medium + ++ ++ 0 0 + 0 + 0 0 0 0 Objective Long + ++ ++ 0 0 + 0 + 0 0 0 0
Summary:- .As expected, positive impacts will occur to SEA Objectives 1,2,3,6 and 8
LFRMS Objective 7:- Take a sustainable and holistic approach to flood and coastal management, seeking to deliver wider environmental and social benefits.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short 0 - 0 0 0 - - 0 0 / / 0
Do nothing Medium - - / ------/ -
Long - - / ------#
Short + + / + 0 0 + 0 0 + / ++ Implement LFRMS Medium + ++ + + 0 / + + + + + ++ Objective Long + ++ + ++ 0 + + + + + + ++
Summary:- This has a positive impact across the majority of the SEA objectives. The ‘do nothing’ scenario is not an option.
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LFRMS Objective 8:- Prioritising investment in the most at risk communities.
SEA OBJECTIVES
Timeframe 1 2 3 4 5 6 7 8 9 10 11 12
Short / / / / / / / / / / / /
Do nothing Medium / / / / / / / / / / / //
Long / / / / / / / / / / / /
Short + 0 + / / + / / + + + + Implement LFRMS Medium + / + / / + / + + + + + Objective Long + / + / / + / + + + + +
Summary:- There is significant uncertainty as to what the benefits may or may not be from this LFRMS objective as the prioritisation of risk has yet to be undertaken. However, once this has been identified there will be significant benefits across a number of SEA objectives
7.2. Significant Secondary and Synergistic Effects
The Strategic Environmental Assessment Directive requires the assessment of synergistic and cumulative effects of a strategy – effects which interact in such a way to form significant positive/negative environmental effects. A summary of the additional cumulative/synergistic significant environmental effects likely to arise from implementation of the LFRMS is summarised below according to SEA theme.
SECONDARY/SIGNIFICANT ENVIRONMENTAL EFFECTS
Significant Synergistic/Secondary Environmental SEA Theme Effects
The LFRMS shows a high degree of synergy with City and County of Swansea’s Community Strategy, particularly with regards to ambitions to reduce health inequalities by: i) potentially increasing access/availability of open spaces Population & Human which in turn improve mental and physical well being; and Health ii) reducing stress and anxiety caused by the both the perceived threat and actual occurrence of flooding. The LFRMS will also contribute to ensuring that residents of City and County of Swansea are prepared for how climate change is likely to affect local communities
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SECONDARY/SIGNIFICANT ENVIRONMENTAL EFFECTS cont.
Significant Synergistic/Secondary Environmental SEA Theme Effects
Where potential exists, the LFRMS will compliment City and County of Swansea’s Local Biodiversity Action Plan. For Biodiversity, Flora & instance opportunities to incorporate habitat enhancements Fauna into flood risk management measures will be sought where possible. By implementing SuDS and innovative land management techniques there is likely to be a beneficial impact on soil quality and sustainable use of soil resources. Thus there is Soil likely to be a certain degree of synergy with the Environment Agency Strategy for Soil, a precious resource – our strategy for protecting, managing and restoring soil . There are obvious synergies with environmental and Water Framework Directive objectives contained within overarching Water &Flooding strategies, most notably the River Severn Catchment Flood Management Plan. The SEA did not identify any significant environmental effects Material Assets for this theme The SEA did not identify any significant environmental effects Cultural Heritage for this theme. The LFRMS has the potential to provide a high degree of Landscapes synergy with complimentary strategies whose primary focus is the enhancements of landscapes.
7.3. Proposed Monitoring
Upon finalisation and adoption of the draft Local Flood Risk Management Strategy, Article 10 (1) of the Strategic Environmental Assessment requires monitoring of significant environmental effects.
City and County of Swansea will attempt to utilise existing monitoring protocols to meet the monitoring requirements of the Strategic Environmental Assessment process. The following table presents the proposed monitoring measures. Whilst using existing monitoring measures will give an indication of wider environmental trends, it is unlikely that these measures will directly pick up the effects of LFRMS policies due to the impact of other influences.
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PROPOSED MONITORING
SEA Theme Proposed SEA Theme Proposed Monitoring Monitoring
Number of properties/businesses at risk of flooding
Number of developments permitted contrary to EAW advice Area/number of recreational and amenity facilities effected Population & by flooding incidents Human Health Change in area/number/quality of public open spaces, recreational and amenity facilities Population & Human Health Number of flood related injuries Changes in condition to designated sites
Achievement of biodiversity action plan targets Biodiversity, Flora Ecological potential assessments & Fauna Chemical and ecological condition of rivers. Requirements for habitat enhancement and/or compensation arising out of the LFRMS Area/number of incidences where Grade 1,2 or 3 soil lost Soil due to need for flood defence Resource availability status for surface water and groundwater in Catchment Abstraction Management Strategy Areas Maintenance or enhancement of existing surface water and Water groundwater regimes Resource availability status at low flows for units of surface water and/or surface water combined with groundwater in Catchment Abstraction Management Strategy Areas Condition of water bodies (Water Framework Directive) Number of properties/businesses at risk of flooding Number of flood defences developed Flooding Number of sustainable drainage systems implemented since the publication of the LFRMS
Number and severity of incidents leading to disruption or damage to transport infrastructure.
Material Assets Number and severity of incidents leading to disruption or damage to service provision
Number of days lost by industry due to access problems
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PROPOSED MONITORING cont.
SEA Theme Proposed SEA Theme Proposed Monitoring Monitoring
Number of listed buildings at risk of flooding events Number of flood defences/strategies implemented to protect listed buildings since the LFRMS was published Cultural Heritage Number and condition of conservation areas Number and condition of registered historic parks and gardens Number of proposed and actual flood mitigation Landscapes developments to be located within landscapes with a high sensitivity.
8. FUTURE SEA ACTIVITIES
This Environmental Report concludes the principal stage of the City and County of Swansea’s Local Flood Risk Management Strategy.
Additional assessment may be necessary if changes to the draft Strategy are required subject to the completion of the consultation period, as comments may result in additional/or considerably alter the significant environmental effects described in this report. An additional statement will be published upon adoption of the final Local Flood Risk Management Strategy highlighting how consultation responses have influenced the Final Strategy in addition to finalising the monitoring requirements.
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ADVICE TO CITY AND COUNTY OF SWANSEA COUNCIL
HABITATS REGULATIONS ASSESSMENT OF THE LOCAL FLOOD RISK MANAGEMENT STRATEGY
DRAFT FOR COMMENT
V1 (1st February 2013)
Doc. Ref. 1833 Swansea LFRMS HRA Date: 1st February 2013
DAVID TYLDESLEY AND ASSOCIATES PLANNING, LANDSCAPE AND ENVIRONMENTAL CONSULTANTS Appendix C
Contents
Section Page number
1 Introduction 2
2 The requirement to assess the LFRMS under the regulations 5
3 Screening for likely significant effects generally 6
4 Screening the LFRMS for likely significant effects 8
5 Appropriate Assessment 18
6 Recommendations and further work 20
Appendices
Appendix 1: Screening of section 5 objectives 23
Appendix 2: Screening of section 6 measures 26
Appendix 3: European sites and features 41
1
Appendix C
1. INTRODUCTION
Background
1.1 The City and County of Swansea is a ‘Lead Local Flood Authority’ (LLFA) under the Flood and Water Management Act 2010, which implements the recommendations of the Pitt Review of the 2007 floods. As a LLFA, the City and Council of Swansea needs to ‘develop, maintain, apply and monitor’ a Local Flood Risk Management Strategy (LFRMS).
1.2 The introduction to the LFRMS states that:
“The Strategy will be the primary method through which the LLFA discharges its role to provide leadership and co-ordinate flood risk management on a day to day basis. It will act as a focal point for integrating a range of flood risk related outcomes across the county. The council’s strategy must be consistent with the Environment Agency’s National Flood Risk Management Strategy”
Habitats Regulations Assessments of Plans generally
1.3 In the case of the EC v UK 1 the European Court of Justice (the ECJ) required the UK Government to secure the assessment of Britain’s land use plans under the provisions of the Habitats Directive. In that judgment the Advocate General and the Court itself recognised that although they considered Britain’s land use plans could potentially have significant effects on European sites, despite the subsequent need for planning permission at ‘project’ level stage, the assessment of plans had to be tailored to the stage in plan making. The same principle would apply to the cascade of plans and projects involved in the implementation of the National Flood and Coastal Erosion Risk Management Strategy for Wales.
1.4 The Advocate General’s opinion 2 which informed the judgment of the court acknowledged the difficulties associated with an assessment of the early stages of a plan (such as a Local Flood Risk Management Strategy paper informing the preparation of a Local Flood Risk Management Plan). In paragraph 49 of her opinion Advocate General Kokott stated that adverse effects:
“...must be assessed at every relevant stage of the procedure to the extent possible on the basis of the precision of the plan. This assessment is to be updated with increasing specificity in subsequent stages of the procedure”
Consistently, in the High Court case of Feeney 3 the judge said:
“Each appropriate assessment must be commensurate to the relative precision of the plans at any particular stage and no more. There does have to be an appropriate
1 Case C-6/04: Commission of the European Communities v United Kingdom of Great Britain and Northern Ireland judgment of the Court 20 October 2005. 2 Opinion of advocate general Kokott, 9 th June 2005, Case C-6/04. Commission of the European Communities v United Kingdom of Great Britain and Northern Ireland 3 Sean Feeney v Oxford City Council and the Secretary of State CLG para 92 of the judgment dated 24 October 2011 Case No CO/3797/2011, Neutral Citation [2011] EWHC 2699 Admin 2
Appendix C
assessment at the Core Strategy stage, but such an assessment cannot do more than the level of detail of the strategy at that stage permits”
1.5 In undertaking a Habitats Regulations Assessment (HRA) of the kind that is the subject of this report, it is therefore important to get the balance right. Too severe an approach whereby a HRA of all potential effects is undertaken at this stage may be excessive. It is important, even adopting a precautionary approach, not to assign a ‘likely significant effect’ to policies and proposals that could not, realistically, have such an effect, because of their general nature. It is important to apply the precautionary principle in the ‘likely significant effect test’ in the Regulations, but the European Commission in its own guidance on the application of the test 4, accepts that policies in a plan that are no more than general policy statements or which express the general political will of an authority cannot be likely to have a significant effect on a site.
1.6 To include such policies or general proposals in a formal ‘appropriate assessment’ is likely to generate a considerable amount of abortive or unnecessary work. It could even lead to the plan failing the ‘integrity test’. Not because, in practice, any policy or proposal might adversely affect the integrity of any European site, but because policies have been ‘screened in’ which generate no more than theoretical risks, or vague or hypothetical effects, and for which no meaningful assessment can be made at this stage, because no particular significant effect on any particular European site can actually be identified. Such an approach is not believed to be in the interests of the plan or the European sites. In the Boggis judgment 5, the Court of Appeal ruled that there should be “ credible evidence that there was a real, rather than a hypothetical, risk” . What the assessment needs to concentrate on are those aspects of the plan that could, realistically, be likely to have a significant effect.
1.7 Too lenient a view however can be equally problematic. For example, in respect of proposed mitigation measures, it would not be approrpiate to simply rely on a general European ‘site protection statement in the LFRMP, without any consideration of how the proposed measures might realistically be reliably mitigated.
1.8 Any tension in the Strategy must be resolved in favour of protecting the European sites from harm which may be caused by the effects of the proposals in the plan 6.
1.9 However, a specific protection statement in relation to a particular measure or objective of the LFRMS would be permissible, because it would refer to specific details of future particular measures and actions 7.
1.10 The elimination of the likelihood of significant effects at this early stage can be particularly important to the overall assessment. This can be done most effectively by removing any measures or objectives that may have such an effect or by introducing case-specific measures to mitigate them.
4 European Commission, 2000, Managing Natura 2000 Sites: The provisions of Article 6 of the Habitats Directive 92/43/EEC section 4.3.2 at http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/provision_of_art6_en.pdf 5 Peter Charles Boggis and Easton Bavants Conservation v Natural England and Waveney District Council, High Court of Justice Court of Appeal case C1/2009/0041/QBACF Citation No [2009] EWCA Civ. 1061 20th October 2009
6 Feeney paragraph 97 7 Feeney paragraphs 88, 90 and 92 3
Appendix C
Habitats Regulations Assessment of a ‘cascade’ of plans
1.11 It is important to keep in mind that the LFRMS is a plan which sits very clearly within a ‘cascade’ of plans and projects. In accordance with existing CCW guidance on plans and projects requiring multiple consents 8, a ‘cascade’ of plans and projects is ‘where one or more competent authorities develop a vertical hierarchy of multiple plans and projects, with each successive tier developing the proposals in more detail’ .
1.12 With such a vertical hierarchy, the FRMS sites ‘beneath’, and must be in accordance with, the National Flood and Coastal Erosion Risk Management Strategy for Wales which was published by the Welsh Government in November 2011. In contrast, the LFRMS sits ‘above’, and precedes, the Local Flood Risk Management Plan (LFRMP) which CSS need to prepare and publish by 2015. The level of detail within the LFRMS is therefore greater than that provided by the National Strategy but less than will be available within the anticipated LFRMP. The National Strategy was subject to its own HRA and the subsequent LFRMP will also be subject to HRA prior to its approval and implementation.
1.13 Of course, CCS must have regard to the requirements of the Habitats Directive in the exercise of any of their functions 9 and, with the forthcoming HRA of the LFRMP, and in light of the HRA of the National Strategy, it is good practice to ensure that the requirements of the Regulations, and the potential effects on European sites, are considered in an iterative process from the earliest stages of the plan making procedures.
1.14 At the LFRMS stage many of the issues and objectives are necessarily strategic in nature. Whilst the level of detail is more precise than in the National Strategy, there is still insufficient information in terms of the precise location and timing of potential measures that may be delivered through the LFRMS and the later LFRMP. Significant potential risk areas, which may need further information gathering, can be identified early so that such work can be undertaken in good time. In turn this will speed up the later stages of assessment and avoid any delays in the overall process.
8 CCW Guidance Note: Methodological approaches to the Habitats Regulations Assessment of plans and projects requiring multiple consents. David Tyldesley and Associates May 2011. 9 Regulation 9(3) 4
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2. THE REQUIREMENT TO ASSESS THE LFRMS UNDER THE REGULATIONS
Purpose of this assessment
2.1 This report is a Habitats Regulations Assessment (HRA) to inform the publication of the LFRMS. The assessment recorded herein has regard to the requirements of the Habitats Regulations, and the earlier HRA of the National Flood and Coastal Erosion Risk Management Strategy for Wales. The assessment is undertaken in accordance with the existing CCW guidance on the assessment of plans under the Habitats Regulations 10 .
2.2 The HRA will consider the LFRMS as an overall document, but with particular attention given to: a) The objectives for managing flood risks and options to achieve them (section 5) b) The actions and measures to improve flood risk management (section 6)
Is this a plan or project within the meaning of the Habitats Regulations?
2.3 Plans and projects are not defined in the Directive but regulation 61 clearly implies that they are something that requires consent, permission, or other authorisation, or something that a competent authority may themselves undertake. The LFRMS is a strategy which CCS, as a competent authority will implement. The objectives, actions and measures referred to within the Strategy, in particular the development of the more detailed Local Flood Risk Management Plan (LFRMP) have the potential to affect European sites.
2.4 It is the view of CCS that the LFRMS is a ‘plan’ within the context of Regulation 61.
Who is the competent authority ?
2.5 Regulation 7 defines competent authorities. CCS accepts that it is the competent authority because they are the authority responsible for the preparation of the Strategy.
Is the project directly connected with or necessary to the management of any of the European or Ramsar sites potentially affected?
2.6 No, the LFRMS will not be necessary to or connected with site management for nature conservation. EC Guidance 11 provides clear advice on this point at 4.3.3. It indicates that the whole plan would have to be so necessary or directly connected for it to be exempt.
10 CCW Guidance for plan making bodies in Wales: The appraisal of plans under the Habitats Directive. David Tyldesley & Associates (revised 2012) 11 European Commission, 2000, Managing Natura 2000 Sites: The provisions of Article 6 of the Habitats Directive 92/43/EEC 5
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3 SCREENING FOR LIKELY SIGNIFICANT EFFECTS GENERALLY
3.1 The test in regulation 61 is whether the plan is likely to have a significant effect on any European site, either alone or in combination with other plans or projects. This requires inter alia a preliminary examination 12 of any potential effects of the plan on each qualifying interest feature, of any European site potentially affected and whether any effects would be likely and significant, alone or if not alone, in combination with other plans or projects.
3.2 As the competent authority, CCS needs to be mindful of existing case law and relevant judgments from the European Court of Justice (ECJ) in relation to the application of the Habitats Regulations. The Council notes the ruling of the ECJ in Case C-127/02 (the Waddenzee judgment) which states at paragraph 45
“any plan or project not directly connected with or necessary to the management of the site is to be subject to an appropriate assessment of its implications for the site in view of the site’s conservation objectives if it cannot be excluded, on the basis of objective information, that it will have a significant effect on that site, either individually or in combination with other plans or projects” .
3.3 The Ruling also provides helpful clarification into the interpretation of the word ‘significant’; paragraph 47 states that:
“where such a plan or project has an effect on that site but is not likely to undermine its conservation objectives, it cannot be considered likely to have a significant effect on the site concerned”
3.4 The assessment is required to take account of the characteristics and specific environmental conditions of the site (see paragraph 49 of the judgment) and as such the decision needs to be made in the context of prevailing environmental conditions.
3.5 In light of the above authoritative ruling, CCS are mindful that in order to conclude no likely significant effect, it will be necessary to be confident that any ‘significant’ effects (ie: those which have the potential to undermine the conservation objectives) can be ‘excluded, on the basis of objective information’.
3.6 For the purposes of this assessment the “alone or in combination with other plans or projects” test is regarded as meaning the following.
3.7 Firstly, the test is only applied to plans or projects, that is, to proposals or incomplete plans or projects, not to completed developments which should be treated as part of the baseline and whose effects are already likely to be part of the existing environmental conditions in the area.
3.8 Secondly, that if a plan or project would be likely to have a significant effect alone, it is assessed alone (regulation 61(1)). If it would have some effect on the site, which on its own would not be significant, it must then be assessed with the effects of other plans or projects whose effects alone would not be significant, to see if their cumulative effects would be significant. Even where a plan or project is initially assessed alone, an in combination assessment may still be required before determining whether the proposal,
12 European Court of Justice in Case C-127/02 (the Waddenzee ruling) at paragraph 38 6
Appendix C
alone or in combination with other plans or projects, would not have an adverse effect on the integrity of the site (regulation 61(5)).
3.9 It is not possible to pre-determine all of the other plans or projects which would need to be assessed in combination until the effects of the subject plan are understood. This is because there may be a wide range of plans and projects potentially applicable, but if they would not add in some way to the effects of the subject plan, so as to make the subject plan’s effects either more likely and / or more significant, they are irrelevant to the in combination test.
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4 SCREENING THE LFRMS FOR LIKELY SIGNIFICANT EFFECTS
European sites potentially affected
4.1 The LFRMS is primarily concerned with flood management activities on ‘ordinary watercourses’. Flood management on main rivers and along the coast is principally the responsibility of the Environment Agency and is generally the subject of different plans and strategies developed and implemented by them.
4.2 In considering the sites that could potentially be affected by flood management activities on ‘ordinary watercourses’, whilst there will generally not be direct effects on coastal sites, there is the potential for indirect effects through the interaction of such activities with coastal processes, in particular where the effects of the LFRMS are considered in combination with the flood management plans and strategies being developed by the Environment Agency (such as shoreline management plans).
4.3 Section 1 of the LFRMS states that the strategy ‘has to consider significant interactions with main rivers, sea and main sewer systems’ . Section 4.1 of the LFRMS further considers the potential for interaction between activities on ordinary watercourses and main rivers and the sea. It states that ‘there is insufficient historical flooding data to draw definitive conclusions at this stage’ but goes on to highlight that the ‘ main areas where there is possibility of interaction with ordinary watercourses are on the low lying areas around the Swansea Bay on the Southern boundary and Crofty to Pontardulais on the Northern boundary’ .
4.4 At this stage therefore, the potential for indirect effects on coastal European sites through the interaction of flood management activities on ordinary watercourses with coastal processes cannot be excluded on the basis of objective information. Indirect effects upon coastal sites are therefore considered within this HRA.
4.5 Furthermore, whilst the LFRMS is primarily concerned with flood management activities on ordinary watercourses, it is clear that there is the potential for CCS to also be involved in coastal flood management activities. Section 2 refers to the permissive powers of CCS as a LLFA including the ‘ability to cause coastal erosion under certain conditions’ . Section 3.2 states that as a risk management authority, CCS has ‘ power to take on flood and coastal erosion functions from other risk management authorities when agreed by both sides’ . Section 3.4.1.2 sets out the responsibilities of CCS as Coastal Erosion Risk Management Authority including ‘shoreline management planning in conjunction with the Environment Agency’ and, importantly, the ‘ delivery of coastal erosion risk management activities ’.
4.6 On the basis of currently available information, the potential for the LFRMS to influence the implementation of flood management activities along the coast cannot be excluded on the basis of objective information. On a precautionary basis, the potential for direct effects from such activities within the boundaries of coastal European sites has been considered within the HRA.
4.7 The HRA of the National Flood and Coastal Erosion Risk Management Strategy for Wales states at section 2.2 that:
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‘There are a number of terrestrial SACs and SPAs located away from water bodies and flood zones, for which the influence of water is not an important factor in supporting the site’s interest features. These sites are unlikely to be affected by the National FCERM Strategy for Wales. In the majority of cases, lower tier spatially based strategies and projects are also unlikely to affect these sites. Although unlikely, it cannot be ruled out that these sites will be unaffected by lower tier strategies or projects. As a matter of best practice, the strategy developer, or proponent of a project, should in each case consult the relevant contact at the Countryside Council for Wales (CCW), to determine whether European designated sites may be affected by particular strategies or projects in proximity.
4.8 In light of the above, CCS have included all SACs and SPAs in the table below, even though some are largely terrestrial and might initially be regarded as unlikely to be affected by the LFRMS. These sites are considered further in paragraph 4.10 below.
CHECKLIST
SELECTING SITES THAT SHOULD BE CONSIDERED IN THE APPRAISAL
Criteria Sites to check Sites selected for consideration
• Crymlyn Bog SAC and Ramsar site For plans that Coastal and riverine sites, or those located adjacent • Carmarthen Bay and Dunes might lead to to water bodies and flood zones, which may be SAC activities within directly affected by the actions and measures • Limestone Coast of South (or adjacent to) associated with flood risk management. West Wales SAC • the boundary of a Gower Ash Woods SAC • Gower Commons SAC European site • Carmarthen Bay and Estuaries European Marine Site • Carmarthen Bay and Estuaries European Marine For plans that Sites upstream or downstream of the plan area Site • could affect the with relevant hydrological links to land within the Carmarthen Bay and Dunes hydrological SAC plan area, irrespective of distance from the plan • regime Crymlyn Bog SAC and area Ramsar site • Limestone Coast of South West Wales SAC
• Carmarthen Bay and Estuaries European Marine For plans that Sites in the same coastal ‘cell’, or part of the same Site could affect coastal ecosystem, or where there are • Carmarthen Bay and Dunes coastal processes interrelationships with or between different physical SAC • coastal processes. Limestone Coast of South West Wales SAC • Gower Commons SAC • Gower Ash Woods SAC
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Sites which have significant ecological links with • Limestone Coast of South land affected by the plan, for example, land in the West Wales SAC For plans that plan area may be used by migratory birds, which • Carmarthen Bay and could affect also use a SPA, outside the plan area, at different Estuaries European Marine mobile species times of the year Site
Table 3.1: European Sites potentially affected by the local flood risk management strategy
4.9 It is apparent from the checklist that the sites to be included in this HRA are as follows: • Carmarthen Bay and Estuaries European Marine Site (comprising the Carmarthen Bay and Estuaries SAC, Carmarthen Bay SPA and the Burry Inlet SPA and Ramsar) • Carmarthen Bay and Dunes SAC • Limestone Coast of South West Wales SAC • Crymlyn Bog SAC and Ramsar site • Gower Ash Woods SAC • Gower Commons SAC
4.10 Gower Ash Woods SAC and Gower Commons SAC are predominantly terrestrial sites. A boundary of Gower Commons SAC runs adjacent to the coastline however between Hillend and Rhossili. Gower Commons SAC is therefore considered to be potentially affected by flood management activities, which may directly or indirectly affect the coastal processes along this stretch of the coastline, and will be screened for likely significant effects. Likewise, parts of Gower Ash Woods SAC is in close proximity to the coastline (at Bishop’s Wood near Caswell Bay, Lockway Wood near Pwlldu Bay and Nicholasten Woods near Nicholasten Burrows). Therefore, at this preliminary stage, Gower Ash Woods will also remain within the HRA for further screening.
4.11 Full details in respect of each site are provided in Appendix 3.
Are any listed Ramsar sites potentially affected?
4.12 Crymlyn Bog SAC and the Burry Inlet SPA are also listed Ramsar sites. Planning Policy Wales, Edition 5, November 2012, at paragraph 5.3.10 indicates that it is government policy to treat listed Ramsar sites in the same way as designated European sites
Summary of Potential Effects relevant to the LFRMS
4.13 In summary, based on the above checklist and the nature, scope, content and function of the LFRMS, it is clear that there is potential for activities to take place within the boundary of a European site. Activities within the boundary of a European site will have direct effects on the site. The implications for such direct effects within the site boundary are sufficiently distinct to indirect effects from similar activities outside of the boundary that they shall be considered separately within this assessment. The potential effects that have been identified as relevant to the LFRMS are listed below; each is then briefly introduced in the subsequent paragraphs:
a) Effects from activities within the boundary (or adjacent to) a European site having direct effects. b) Effects from activities beyond the boundary of a European site but having indirect effects, including: • Effects on hydrological regime
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• Effects on mobile species of Limestone Coast of South West Wales SAC and Carmarthen Bay and Estuaries European Marine Site. • Effects on coastal processes
Direct effects from activities within (or adjacent to) the site boundary
4.14 Table 5.1 below is taken directly from the National Strategy HRA and details the potential range of activities that may be related to the LFRMS activities.
Table 5.1: Summary of flood management activities and potential associated effects 13
13 Table 5.1 is based upon information obtained from related Environment Agency Guidance. NB: FCERM stands for Flood and Coastal Erosion Risk Management 11
Appendix C
4.15 The potential range of effects from the type of measures and actions associated with flood management are broad. Where these activities are carried out within the boundary of European sites, or adjacent to them, the potential for likely significant effects will need to be carefully considered.
4.16 The management of flood risk is likely to involve activities adjacent to watercourses and coastal areas. A large extent of the coast around Swansea is designated as a European site and the potential for significant effects is considerable.
Indirect effects from activities beyond the site boundary
Effects on the hydrological regime
4.17 The hydrological regime of a site is essentially the movement of water into, through and out of the site. In the context of this report the effects of LFRMS on the hydrological regime of a site are potentially significant. Works which retain flow or provide for flood storage will need to be assessed to consider whether they will have a likely significant effect on any European sites.
Effects on mobile species
4.18 Mobile species are those listed features of a site that are dependent on areas of land outside of the designated site boundary, such as birds, bats, fish etc. The mobile species relevant to this HRA are as follows:
a) Great Horseshoe bat (Limestone Coast of South West Wales SAC) b) River lamprey (Carmarthen Bay and Estuaries SAC) c) Sea Lamprey (Carmarthen Bay and Estuaries SAC) d) Allis shad (Carmarthen Bay and Estuaries SAC) e) Twaite Shad (Carmarthen Bay and Estuaries SAC) f) Otter (Carmarthen Bay and Estuaries SAC)
4.19 The Management Plan for the Limestone Coast of South West Wales SAC states that the ‘ bats are known to feed widely over the Castlemartin peninsula and elsewhere along the limestone coast – utilising any number of coastal caves as temporary overnight shelters in between feeding periods or as longer term roosts’ . Grazing animals and wooded areas are specifically referred to as providing a suitable range of insects upon which the bats feed. Off site impacts upon bats from flood management activities are considered to be a very low risk.
4.20 The Shad, river lamprey and sea lamprey features of the Carmarthen Bay and Estuaries SAC all spawn in upstream rivers. As such the SAC is an important migration route and the populations for which the site is designated are potentially affected upstream of the SAC boundary. The European Marine Site management plan does not make any reference to shad or lamprey species spawning in the rivers upstream of the Loughor Estuary. Shad, river lamprey and sea lamprey all migrate through the SAC to reach the River Tywi. The River Tywi is thought to be one of only four rivers in Wales where shad spawns. Of relevance to this HRA report the River Tywi SAC drains into the Tywi Estuary and it is considered highly unlikely that activities within the Swansea LFRMS will exert effects at that distance. However, until further detail is available of the
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nature and scale of the activities that may be identified, potential off site effects on these species cannot be excluded on the basis of objective information at this stage.
4.21 With regard to potential off-site impacts on otter, the European Marine Site management plan states that:
“Otters are known to use most areas of the coast within and adjacent to the SAC. Otters and spraints have been seen on Llanrhidian sands and Llanelli levels and it is likely that otters are coming into the estuary from the River Loughor. Otters are known to use the coast between Llanelli and Burry Port and have been seen crossing the railway line which runs along the coast. Pembrey Forest, adjacent to the SAC is well used by otters and although Cefn Sidan sands have not been surveyed, it is very likely that otters use them.
The coast within the SAC is well supplied with rivers and streams and it is highly likely that otters travel from one watercourse to another along the coast. Otters living on the coast must have access to freshwater streams and pools for drinking and washing.”
4.22 The management plan goes on to state that “we currently do not know where otters rest within the SAC due to their secretive nature and current lack of survey work around the coast ”. As a result the FRMS need to be assessed in light of the potential use of all suitable areas out-with the EMS boundary by otters.
4.23 The listed bird features of the Burry Inlet SPA are also ‘mobile’; at high tide many of the wader species are likely to seek refuge in supporting habitat outside the SPA boundary. This is because birds are forced out of the intertidal habitats by the tide and habitats above mean high water within the SPA become too ‘crowded’ (by roosting birds) or too disturbed. The birds will therefore from time to time need to use supporting habitat outside the SPA; these can include arable fields or playing fields because these provide birds with a degree of security from predators by offering long distance views of ground based predatory approaches. In absence of evidence to the contrary, any suitable land within 1km of the estuary may be used as supporting habitat for SPA species at high tide, or in severe weather, and records would need to be checked before such areas are identified in association with actions and measures to be delivered through the LFRMS.
Effects on coastal processes
4.24 Coastal defences to protect land and property can interfere with natural erosion processes resulting in coastal squeeze. Coastal squeeze can then result in a range of potential effects within European sites including habitat loss.
Screening the LFRMS
4.25 The LFRMS has been considered in light of the existing CCW guidance for plan making authorities on the appraisal of plans under the Habitats Directive 14 . Section 5 of this guidance (screening the plan for likely significant effects) sets out four categories of potential effects against which elements of a plan should be assigned. The categories are:
14 Tyldesley, D., 2009, Guidance for Plan Making Authorities in Wales: The Appraisal of Plans under the Habitats Regulations for Countryside Council for Wales CCW Bangor revised 2010 and 2012
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a) Category A: elements of the plan / option would have no negative effect on a European site at all; b) Category B: elements of the plan / options that could have an effect, but the likelihood is there would be no significant negative effect on a European site either alone or in combination with other elements of the same plan, or other plans or projects; c) Category C: elements of the plan / options that could or would be likely to have a significant effect alone and will require the plan to be subject to an appropriate assessment before the plan may be adopted; d) Category D: elements of the plan / options that would be likely to have a significant effect in combination with other elements of the same plan, or other plans or projects and will require the plan to be subject to an appropriate assessment before the plan may be adopted;
4.26 Categories A, C and D are further subdivided so that the specific justification for the allocation of individual elements / options is more transparent, as set out below:
Category A justification classes
Category A: A1 Options / policies that will not themselves lead to development e.g. because they relate to design or other qualitative criteria for development, or they are No negative not a land use planning policy. effect A2 Options / policies intended to protect the natural environment, including biodiversity, unless, exceptionally, there may be an adverse effect on a European site
A3 Options / policies intended to conserve or enhance the natural, built or historic environment, where enhancement measures will not be likely to have any negative effect on a European Site
A4 Options / policies that positively steer development away from European sites and associated sensitive areas
A5 General policy statements or policies which only express general intentions or political aspirations and there are no ‘clear and direct’ links to European sites.
Category C justification classes
Category C: C1 The option, policy or proposal could directly affect a European site because it provides for, or steers, a quantity or type of development onto a Likely European site, or adjacent to it significant effect alone C2 The option, policy or proposal could indirectly affect a European site e.g. because it provides for, or steers, a quantity or type of development that may be very close to it, or ecologically, hydrologically or physically connected to it or it may increase disturbance as a result of increased recreational or other pressures
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C3 Proposals for a magnitude of development that, no matter where it was located, the development would be likely to have a significant effect on a European site, see paragraph 2.32 above
C4 An option, or policy that makes provision for a type of development, generally, (and may indicate a broad scale and / or one or more broad locations e.g. a particular part of the plan area), so a likelihood of a significant effect cannot be ruled out, but the more precise scale and / or detailed location of the development is to be selected following consideration of options in a later, more specific, lower tier plan , subject to Habitats Regulations Appraisal
C5 Options, policies or proposals for developments or infrastructure projects that could block options or alternatives for the provision of other development or projects in the future, which will be required in the public interest, that may lead to adverse effects on European sites, which would otherwise be avoided see paragraph 2.34 above and 5.18 -19 above
C6 Options, policies or proposals which depend on how the policies etc are implemented in due course, for example, through the development management process. There is a theoretical possibility that if implemented in one or more particular ways, the proposal could possibly have a significant effect on a European site, and is not merely a general statement of policy, see paragraph 2.69 above
C7 Any other options, policies or proposals that would be vulnerable to failure under the Habitats Regulations at project assessment stage; to include them in the plan would be regarded by the EC as ‘faulty planning’, see paragraph 2.39 - 40 above and 5.19 above
C8 Any other proposal that may have an adverse effect on a European site, which might try to pass the tests of the Habitats Regulations at project assessment stage by arguing that the plan provides the imperative reasons of overriding public interest to justify its consent despite a negative assessment, see paragraph 2.35 above
Category D justification classes
Category D: D1 The option, policy or proposal alone would not be likely to have significant effects but if its effects are combined with the effects of other policies or Likely proposals provided for or coordinated by the plan (internally) the significant cumulative effects would be likely to be significant effect in combination D2 Options, policies or proposals that alone would not be likely to have significant effects but if their effects are combined with the effects of other plans or projects , and possibly the effects of other projects provided for in the plan as well, the combined effects would be likely to be significant
D3 Options or proposals that are, or could be, part of a programme or sequence of development delivered over a period, where the 15
Appendix C
implementation of the early stages would not have a significant effect on European sites, but which would dictate the nature, scale, duration, location, timing of the whole project, the later stages of which could have an adverse effect on such sites
4.27 The LFRMS has been screened in accordance with the above guidance and categories. Sections 1-4 of the report include ‘Introduction’, ‘Legislation’, ‘Flood Risk management Authorities’ and ‘The assessment of local flood risk for the purpose of the strategy’. All four of the sections are concerned with setting the context and relevant background to the objectives, actions and measures set out within sections 5 and 6. Sections 1-4 have been considered in light of the CCW guidance and are considered to have ‘no negative effect’. They will not lead to any proposals which could have a negative effect on any European site in accordance with category A1.
4.28 Section 5 of the LFRMS sets out the objectives for managing flood risks and the options to achieve them. The detailed screening for section 5 is provided in appendix 1.
4.29 Appendix 1 shows that objectives 1, 2, 3, 5, and 7 are considered to have ‘no negative effects’ on any European site in accordance with category A in the CCW guidance for plan making bodies already referred to. Objectives 1, 2, 3 and 5 are regarded as general policy statements for which there are no clear and direct links to European sites (category A5). Objective 7 is intended to protect the natural environment and makes specific reference to European sites and can be screened out under category A2.
4.30 Objectives 4, 6 and 8 are considered to make provisions for potential activities which could possibly have significant effects on European sites. However the precise nature, scale and location for such activities will be determined following a consideration of options as part of a later, more specific, lower tier plan or project assessment. In accordance with paragraph 5.20 of the CCW guidance for plan making bodies these objectives will need to be considered as part of an appropriate assessment to enable CCS to ascertain that they would not have an adverse effect on any European sites.
4.31 Section 6 of the LFRMS sets out the actions and measures to improve flood risk management. The detailed screening for the 24 measures identified is provided in Appendix 2 which shows that 15 or the measures are screened as having no negative effects in accordance with category A5, 1 measure is considered to have no negative effects in accordance with category A2 with another under category A3. The remaining 7 measures are considered to make provisions for potential activities which might have likely significant effects on European sites. In accordance with paragraph 5.20 of the CCW guidance for plan making bodies these seven measures will need to be considered within an appropriate assessment to enable CCS to ascertain that they would not have an adverse effect on any European sites.
4.32 A summary of the screening results for the objectives and measures listed in sections 5 and 6 is provided in table 4.1 below:
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Screening Justification Objectives and Measures Category A2 Proposals intended to protect the natural Objective 7 environment Measure 10 A3 Proposals intended to conserve of enhance the Measure 16 natural environment, where enhancement measures will not be likely to have any negative effect on a European site A5 General policy statements or policies which only Objectives: 1, 2, 3 and 5 express general intentions or political aspirations Measures: 1, 2, 3, 5, 6, 9, 11, and there are no clear or direct links to European 12, 13, 14, 19, 20, 21, 23 and sites 24. C4 Proposals that makes general provisions so a Objectives: 4, 6 and 8 likelihood of significant effects cannot be ruled out, Measures: 4, 7, 8, 15, 17, 18 but the more precise scale and / or detailed and 22. location of the proposals is to be selected following consideration of options in a later, more specific, lower tier plans, subject to HRA Table 4.1: Summary of screening decisions for the objectives and measures within sections 5 and 6
4.33 In accordance with the CCW guidance for plan making bodies an appropriate assessment is therefore required in relation to the objectives and measures which are screened to be within category C4.
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5 APPROPRIATE ASSESSMENT
5.1 CCW guidance for plan making bodies provides further guidance in relation to the assessment of proposals which are classed as category C4 in paragraphs 6.19-6.21. Para 6.19 states that:
“Options, policies or proposals in category C4, where a plan makes provision for a type of change, generally, and perhaps its broad location or general scale, but not its particular magnitude or specific location, may be more appropriately appraised either later in the plan making process, or in a lower tier plan, where there will be one. However, reliance on the later or lower tier plan appraisal is only appropriate where the later or lower tier appraisal will ensure that there would be no adverse effect on site integrity and that this can be established with appropriate certainty before the proposals are assessed as projects, at application stage ”
5.2 Para 6.21 then goes on to set out three criteria which all need to be met to enable a plan making body (such as CCS in this instance) to reasonably ascertain that there would be no adverse effect on the integrity of the European site(s). The three criteria are stated below:
“Subject to appropriate adjustments to the plan itself the plan-making authority can reasonably ascertain that there would be no adverse effect on the integrity of the European site arising from the policy or proposal if the following three criteria are all met:
a) The earlier, or higher tier, plan appraisal cannot reasonably predict the effects on a European site in a meaningful way; whereas
b) The later or lower tier plan, which will identify more precisely the nature, scale or location of development, and thus its potential effects, retains sufficient flexibility over the exact location, scale or nature of the proposal to enable an adverse effect on site integrity to be ruled out (even if that would mean ultimately deleting the proposal); and
c) The later or lower tier appraisal is required as a matter of law or Government policy, so it can be relied upon.”
5.3 The objectives and measures identified under category C4 are listed below and considered against the three criteria within the CCW guidance.
Objective/measure Criteria (a) Criteria (b) Criteria (c) Objective 4: Established regular maintenance schedules for flood and coastal erosion risk (refer measures management 15, 17, 18 & 22 below)
Objective 6: Enhance property and community level of resilience (refer measures 7, 8 & 22below) Objective 8: Prioritising investment in the most at risk communities (refer measures 7, 8 & 22 below) Measure 4: Water Cycle Strategy (WCS subject to 18
Appendix C
HRA) Measure 7: Emergency response plans including multi-agency plans (emergency plans subject to HRA) Measure 8: Community flood plans (community plans subject to HRA) Measure 15: Consenting to works on ordinary watercourses (proposals will be included in Measure 17: Construction of flood defences LFRMP which Measure 18: Cause incidental flooding for will be subject to purposes of flood risk management HRA)
Measure 22: Flood risk management plans (LFRMP subject to HRA) Table 5.1: screening of C4 objectives and measures against CCW criteria
5.4 As set out in table 5.1 above, all of the objectives and measures which were screened as category C4 meet the three criteria set out within the CCW guidance. The elements of the objectives and measures which were identified as potentially resulting in likely significant effects will all be subject to HRA in due course as part of a later or lower tier plan or project HRA.
5.5 Subject to consideration of alternative solutions and imperative reasons of overriding public interest therefore, following the later HRA, any proposals which are likely to have a significant effect, will only be progressed after having ascertained that they will have no adverse effect on the integrity of any European site.
5.6 Once the details concerning the nature, scale and location of the proposed measures are better understood any necessary mitigation measures will be secured as part of a later or lower tier plan or project HRA.
5.7 In relation to the LFRMS, with reliance on the mitigation provided by the later HRA, CCS are able to conclude that the LFRMS will have no adverse effect upon the integrity of any European sites.
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Appendix C
6 RECOMMENDATIONS AND FURTHER WORK
6.1 In light of the conclusions listed above, it is clear that the full implementation of the LFRMS will require further stages of HRA. The further HRA requirements will be undertaken when the necessary detail is available as part of later, lower tier plan HRAs.
6.2 The need for subsequent HRA has been specifically identified in relation to:
• Water Cycle Strategy • Emergency Response Plans • Community Flood Plans • Capital Schemes identified through the Local Flood Risk Management Plan • Plans to artificially manage floodwater levels • Local Flood Risk Management Plan
6.3 These later plan HRAs will need to fully explore the potential impacts upon European sites and where appropriate consider possible mitigation measures which might be necessary to avoid likely significant effects or adverse effects on site integrity. It is possible that the derogation tests of alternative solutions and imperative reasons of overriding public interest (together with related compensatory measures) may also need to be considered in subsequent HRAs.
6.4 With regard to potential mitigation measures that may need to be explored, relevant guidance, case law and authoritative decisions which are relevant to the consideration of mitigation measures as part of a Habitats Regulations Assessment demonstrate that, in summary, mitigation measures would need to be included in the subsequent plans, particularly the LFRMP.
In-combination considerations
6.5 This HRA has considered the potential effects of the objectives and measures set out within sections 5 and 6 of the LFRMS. Most of the objectives and measures are considered to have no negative effects and do not therefore requires assessment ‘in combination’ with other plans or projects. Only effects which are insignificant ‘alone’ need to be considered in combination, where there are no effects (rather than insignificant ones) than there is no mechanism through which the effects could combine with those from other plans or projects.
6.6 As set out in table 4.1 above, ten of the objectives/measures were considered to have the potential for likely significant effects. Consequently, the LFRMS alone was determined to be likely to have significant effects on a European site. These possible effects were taken forward to appropriate assessment stage where it was concluded that, on its own, the LFRMS would not have an adverse effect on the integrity of any European site, for the reason explained earlier in this section, that is, the reliance on later appraisal. It is necessary therefore, for CCS to ascertain that there would be no adverse effect on the integrity of any European site in combination with other plans or projects. Because the later appraisals would also deal with any in combination effects, CCS can equally rely on the later HRAs to ascertain that the LFRMS would not have an adverse effect on the integrity of a European site either alone or in combination with other plans or projects.
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Appendix C
Dr Caroline Chapman MIEEM: Senior Habitats Directive Specialist David Tyldesley and Associates 1st February 2013
21
Appendix C
APPENDICES
Appendix 1: Screening of Section 5
Appendix 2: Screening of Section 6
Appendix 3: European sites and features
22
Appendix C
Appendix 1: Screening of Section 5 Objectives and actions to achieve them
Objective Actions to achieve Assessment Justification Further HRA Category required?
1. To improve the • To provide a clear explanation of the specific statutory A5 The objective expresses a No understanding of Flood duties of other flood risk management Authorities with general aim or aspiration for and Coastal risks and to the administrative area of the City and County of which there are no clear or ensure that all Swansea. direct links to European sites • To involve property owners and communities who are stakeholders understand affected by flooding incidents and allowing them to take their roles and on responsibilities which will assist in the protection of responsibilities in relation the affected community. to Flood and Coastal risk • To increase flood risk awareness and provide a clear management steer on roles and responsibilities by increasing access to public websites and production of flood leaflets • To record flooding related incidents and to investigate flooding incidents if considered significant. • To develop a consistent approach to designation of structures important to flood risk management • Promote local resilience groups and provide support to ensure proper guidance. • To ensure joint working partnership with other flood risk management authorities and to share information for the benefit of all parties. • To work with Joint Resilience Unit 2. To work together with • To continue with partnership working. A5 The objective expresses a No other flood risk • Develop investment plans for flood risk schemes which general aim or aspiration for management Authorities could be jointly funded. which there are no clear or • to reduce flood risk, Ensure that consideration is given to achieving short direct links to European sites term flood risk improvements where local partners wish using all available to contribute, alongside a commitment to resources and funds in understanding future risks an integrated way and in • Promote cost effective flood protection measures such so doing derive overall as individual property protection and local action benefit. groups. • Carry out a review of resources and skills available and tasks that are required by the different organisations to Appendix C
identify the best model for delivery of the new responsibilities alongside existing flood and coastal risk management activities. 3. Develop policies for • Ensure that the Planning process is properly informed A5 Whilst the objective refers to No effective land use and by considering relevant plans and policies such as development it is only in so far management and Catchment Flood Management Plans and Shoreline as to ensure that development enhance development Management Plans. does not increase flood risk. • To encourage the use of Sustainable Drainage control procedures. To The scale and location of Systems prevent an increase in • Planning Policy to take into account TAN15 which development will be flood risk as a result of relates to flood risk areas. determined by the Local development by • To prepare and maintain a database of historic and Development Framework preventing additional flow predicted local flood risk to provide data for the documents. The objective entering existing Planning Authority. expresses a general aim or drainage systems and aspiration for which there are watercourses whenever no clear or direct links to possible European sites.
4. Established regular • Develop and promote clear process for consenting of C4 The location of the flood and Yes maintenance schedules new structures to safeguard future maintenance of coastal erosion risk for flood and coastal privately owned structures management assets is as yet • erosion risk management To regulate ordinary watercourses and to enforce unknown. The actions include powers to maintain a free passage of flow. assets ‘consenting’ of new structures • Ensure riparian owners are aware of their duties for watercourse and culverts on privately owned land. and ‘regulation’ of • To improve the database on all assets which are watercourses. The likelihood of important to flood risk management and to collect data significant effects from such on such assets when possible activities cannot be ruled out at this stage.
5. Raising awareness of • Implement a raising awareness action plan to flood A5 The objective expresses a No and engaging people in affected communities general aim or aspiration for response to flood and • Actively engage communities which there are no clear or • coastal erosion risk Actively communicate current and future risk to local direct links to European sites. communities
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Appendix C
6. Enhance property and • Increasing flood resilience will reduce damages caused C4 The emergency plans referred Yes community level of by any water that gets into a property. This measure to within this objective relate to resilience will attempt to raise awareness of the techniques that enhancing ‘property and could be utilised when repairing properties subject to community level of resistance’. repeated flooding in order to reduce future damages. Likelihood of significant effects Initial awareness campaigns will be targeted at areas identified as being at high risk of surface water flooding is considered to be low but from surface water flood modelling cannot be ruled out until • Ensure that emergency plans are prepared at local further detail is available levels as required and that response to and recovery regarding the precise location, from flooding incidents is effective nature and scale of proposed activities set out within the plan.
7. Take a sustainable and • To consider the wider environmental benefits in the A2 The objective here is deliver No holistic approach to flood design and construction of projects wider environmental benefits. and coastal • Reduce impacts on protected environments. The maintenance or • management, seeking to Promote the concept of water cycle management and improvement of European blue corridors/green infrastructure. deliver wider sites is specifically referred to. • Consideration to given relevant plans and policies e.g environmental and social WFD, SMPs, SFRA and CFMPs benefits • Maintain or where possible improve the status of SSSI’s, SACs, SPAs, Ramsar sites and other sites of importance for nature and conservation. 8. Prioritising investment in • To consider the balance of the frequency of flooding C4 The objective refers to the Yes the most at risk incidents and the extent of damage against the investigation and communities consequence of flooding looking at cost/benefit ratios implementation of ‘quick fix for the promotion of flood alleviation schemes solution’. The potential scope • To investigate and implement quick fix solutions if and location of such actions considered economically sound • To provide a transparent priority system which can are not clear, and the inform allocation of funding likelihood of significant effects • To build up community resilience if considered an on European sites cannot be appropriate alterative measure. ruled out at this stage.
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Appendix C
Appendix 2: Screening of Section 6 actions and measures to improve flood risk management
Measure Delivery and Benefits Screening Justification Further Category assessment required?
Development, Planning and adaptation
Measure 1: Establish SuDS Approval Body
The Flood and Water Management Act 2010 Reduction of run-off rates and reduce A5 The measure expresses a No assigns CCS the role of a Sustainable Drainage flood risk downstream of new general aim or aspiration for System (SuDS) Approval Body (SAB). A SAB will developments which there are no clear or be responsible for: direct links to European sites. Encourage Groundwater recharge by • assessing and approving the drainage infiltration techniques design for all construction work which has drainage implications, and Enhancement of amenity, water quality and environmental improvements • adoption and maintenance of SuDS schemes which connect more than one property
Measure 2: City and County of Swansea Local Development Plan Strategic Flood Consequences Assessment To allow allocated sites to be free of A5 The measure expresses a No flooding constraints general aim or aspiration for Strategic Flood Risk Assessment (SFCA) which there are no clear or undertaken to support the LDP. The primary The LDP aims to ensure that existing direct links to European sites. development is protected from flooding focus was to assess flood risk for key that may be created from new development sites at strategic level. development The LDP plan includes specific policies which set out how development proposals should be
26
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required? considered in relation to flood risk
Measure 3: Planning policy and Wales TAN 15
Land use planning policies are supplemented by To ensure that all new development is A5 The measure expresses a No a series of Technical Advice Notes (TANs). located away from land that is subject general aim or aspiration for to flood risk; which there are no clear or Key policy objectives as identified in section 4.4 direct links to European sites. of PPW include the need to minimise the risks To provide an identification process of posed by, or to, development on, or adjacent to, where further consideration and land liable to flooding. Section 9 requires local assessment is required before development can take place. planning authorities to promote sustainable residential environments, giving regard for biodiversity, nature conservation and flood risk. Chapter 13 sets out the broader objectives for planning and environmental management. This is to control where development can take place and what operations may be carried out, to ensure the avoidance of, or minimising, the adverse effects of any environmental risks associated with flooding on present or future land use.
TAN 15 provides technical guidance which supplements the policy set out in Planning Policy Wales. It advises on development and flood risk and provides a framework within which risks arising from both river and coastal flooding, and from additional run-off from development in any location, can be assessed.
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Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
Measure 4: Water Cycle Strategy
To bring together all the elements of the water The Study is a partnership document C4 The measure refers to Yes cycle relevant to the development and involving the planning authority, water strategic issues such as water infrastructure planning process. This would company, Environment Agency and supply, water management include Countryside Council for Wales The and wastewater disposal. The latter two will be part of the new single potential scope and location of • water supply to meet current and future body from April 2013. Joint working potentially related actions are demands,· ensures that the study provides not clear, and the likelihood of • water management within existing benefits to all stakeholders. significant effects on European developments, sites cannot be ruled out at For Welsh Water benefits include this stage. The Water Cycle • water management in new developments, timely input to water infrastructure Strategy will be subject to planning regarding future HRA. • waste water treatment and disposal and development, strategic needs, the impact of all of these on the environmental constraints, Water movement of water through the Framework Directive management catchment (including flood risk), water quality, natural hydrological processes requirements, reduced flood risk and and ecology. enhanced water quality.
For the EAW/CCW benefits include a framework for water and nature conservation policy compliance, for detailed development control observations and Local Development Plan consideration.
Developers benefit from clear guidance regarding water efficiency targets, SuDS, infrastructure 28
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
timescales and costs, and environmental constraints.
The public will benefit from reliable infrastructure for supply and water treatment, good planning for climate change and flood risk management and potential savings from a strategic approach.
For the Planning Authority evidence is provided for the Local Development Plan for site allocation and infrastructure planning and for implementation through development control, Community Infrastructure levy / S106 etc.
Flood Forecasting, Warning and Response
Measure 5: Flood Awareness
The Council has a duty under the Civil The Government believes a well- A5 The measure expresses a No Contingencies Act 2004 to warn and inform its informed public is better able to general aim or aspiration for residents of the risks and implications of those respond to an emergency and to which there are no clear or risks before, during and after any incidents. As minimise the impact of flooding direct links to European sites. part of this the Council’s web site holds consequences on the community. information and links to further sources of Informing the public as best we can will information in relation to flooding incidents. On build their trust and involve them in occasion, when significant flooding does occur flood mitigation solutions. It will also staff from the Council attend areas / properties to help minimise disruption and improve / 29
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required? provide advice to the affected residents. ease the response to any flooding incidents. This can be extended further under the general requirements of the FWMA 2010. Officers to inform affected communities with best practice measures for property resilience against flooding
Measure 6: Flood Warning
The Council has a duty under the Civil To allow and inform communities to A5 The measure expresses a No Contingencies Act 2004 to warn and inform its access to warning systems i.e. EA general aim or aspiration for flood alerts or other media means. residents of the risks and implications of those which there are no clear or Preparation against the consequences risks including during and after significant flooding of flooding will reduce impact and direct links to European sites. incidents costs
Measure 7: Emergency Response Plans including Multi -Agency Plans Provides clear explanation on the roles C4 The legislation governing this Yes Emergency planning should aim where possible and responsibilities of key measure has not yet been to prevent emergencies occurring and when they stakeholders in an event of an enacted. As such there is do occur, good planning should reduce, control or emergency. insufficient information mitigate the effects of the emergency. It is a regarding the potential scope, systematic and ongoing process which should Preparation of flood evacuation scale and location of procedures in the Multi Agency Plans evolve as lessons are learnt and circumstances potentially related actions. The provides for a planned response to act change. in a co-ordinated reactive manner likelihood of significant effects on European sites cannot be Multi agency plans have been developed which ruled out at this stage. concentrate on different agencies responsibilities
30
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required? as well as command and control. This has been produced by the Joint Resilence Unit of CCS/NPT.
Measure 8: Community Flood Plans
Community flood plan provide a Non- Structural Communities to take on some C4 The measure refers to non- Yes solution to mitigate the effects of flooding. The additional responsibility for flood structural solutions in the event Environment Agency have taken the lead on this related matters in their communities of a flooding incident to to date. Lead Local Authorities to develop their and enables them to become more mitigate the effects of flooding own plans with the aim to develop resilient resilient. at local community level. The communities when faced with serious flooding likelihood of significant effects incidents. Collaborative working between LLFA on European sites is and Communities is essential in order considered to be low but to improve communication in the cannot be ruled out at this response to flooding. stage.
Measure 9: Land Management
Good Land Management Techniques can reduce Through the provision of sustainable A5 The measure expresses a No the extent of surface water run-off and this will be solutions for new schemes. general aim or aspiration for explored whenever possible. which there are no clear or Through consultation with developers direct links to European sites. as part of the new SAB role for approving surface water strategies for new sites
Advising landowners of the advantages of land management techniques to mitigate against the risk
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Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
of flooding
To promote wider environmental benefits of using ‘softer’ engineering approaches to land management in order to reduce surface water run-off
Measure 10: Environmental Enhancement
Measures contained with this strategy to support Consultation with EAW/CCW to ensure A2 The measure is intended to No opportunities to develop enhancement to the compliance to the objectives and protect the natural environment whenever possible. directives set out in the SEA which environment, with specific supports this strategy. reference to SACs, SPAs and • Protection to SACs, SPAs, Ramsar sites Ramsar sites. and SSSI’S through water level Creation of habitats whether management compensatory or enhancement of existing habitats to be considered for Enhancement and compensatory creation of the wider benefit of the environment. Habitats
Asset Management and Maintenance
Measure 11: Asset Register and Records
CCS is required to keep both asset registers (for To update records following flood risk A5 The measure expresses a No public use) and asset records (for use by risk incident as part of the investigation general aim or aspiration for management authorities) for structures and process. which there are no clear or features which are considered to have a direct links to European sites. significant effect on flood risk. There is no formal To collect continually information on definition of when an asset has a ‘significant assets significant to flood risk and to effect’ but will largely be determined on the flood record ownership and responsibility of history of the site and the vulnerability of any 32
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required? infrastructure likely to be affected by a failure of those assets. the asset. To establish assets prone to flooding in CCS will continually update the asset register order to inform future improvement through the information received via the planning works process and watercourse consenting duty. To ensure adequate maintenance regimes and proper condition of those structures.
Measure 12: Power to request information
In certain circumstances the Authority will request CCS has new powers to request A5 The measure expresses a No information from other risk management information which will improve the general aim or aspiration for availability of flood risk data held by Authorities or private landowners regarding their which there are no clear or Authority. assets. direct links to European sites.
The new powers contained within the FWMA 2010 provides CCS with the powers to request this information. Failure to do so can lead legal action being served.
Measure 13: Designation of Structures
The Flood and Water Management Act To ensure no alterations are made to a A5 The measure expresses a No establishes CCS as the ‘Designating Authority’ designated structure without approval general aim or aspiration for with the power to designate a structure (whether from the Authority. which there are no clear or man-made or a natural feature) if CCS believes direct links to European sites. that the structure or feature is significant to flood Ensures that a register of structures is risk. A person cannot make alteration to the maintained by the Authority. structure unless permission is granted by the 33
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
Authority Designated Structures will be registered with the Land Registry
Measure 14: Creation of SuDS Approving Body (SAB) Ensures future maintenance of SuDS A5 The measure expresses a No The Flood and Water Management Act places a Schemes by the LLFA. general aim or aspiration for duty on the City and County of Swansea to adopt which there are no clear or sustainable drainage systems. This part of the Act Surface Water Strategies to be direct links to European sites. has not been implemented yet, but is expected to approved prior to Planning Consent, be enacted April 2013. either through the Planning process or separate application. The process will involve application approval, inspection and adoption of sustainable drainage systems which will serve new developments which will comply to National Standards.
Measure 15: Consenting to Works on Ordinary Watercourses CCS will determine a consent C4 This measure refers to the Yes From 6 April 2012 CCS became responsible for application with the 2month standard consenting activities of CCS in issuing Ordinary Watercourse consents for works period. relation to works on ordinary to ordinary watercourses (streams and ditches watercourses. The nature, both natural and manmade and culverts etc) or Consultation with other stakeholders scale and location of the type taking enforcement action for any breaches. In with applications which possibly could of consent that may be applied future all land drainage consents for works within have an adverse affect on the for are not clear at this stage. City and County of Swansea will be issued by Environment. A likelihood of significant Authority’s Drainage and Coastal Management effects cannot therefore be Section . CCS to adopt EAW policies on non- ruled out. culverting of watercourses. This is
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Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
City and County of Swansea will take a risk- because :- based approach to enforcement where unconsented works have been carried out on • The ecology of the ordinary watercourses. The purpose of ordinary watercourse is likely to be watercourse regulation is to control certain degraded by culverting; activities that might have an adverse flooding • impact Culverting introduces an increased risk of blockage (with consequent increase in flood risk);
Culverting can complicate maintenance because access into the culvert is restricted (in some cases being classified as a confined space and requiring trained operatives and specialist equipment)
Measure 16: Enforcement to maintain flow in watercourses CCS has new powers to reduce the A3 This measure refers to the No Acting as the Land Drainage body CCS has likelihood of flood risk due to a enforcement activities of CCS permissive powers to serve notice on riparian restricted flow in a watercourse caused in relation to works that may landowners in order to remove any obstruction by an obstruction. be required to remove which is impeding the flows in a watercourse. obstructions to flow in ordinary watercourses. Such activities will reinstate the normal ‘natural’ flow and will not have any negative effects on European sites
35
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
Measure 17: Construction of Flood Defences
Capital Schemes will be developed through the The Authority is expected to deliver a C4 This measure refers to capital Yes Project Appraisal route where they will be Flood Risk Management Plan by 2015. schemes for flood risk scrutinised against technical and economic management. The nature, appraisal. The Flood Risk Management Plan will scale and location of the type identify capital schemes, allowing of schemes that may be potential funding streams to be identified are not clear at this explored. stage. A likelihood of significant effects cannot The Authority will use cost/benefit analysis for potential schemes through therefore be ruled out. the Project Appraisal Route
Measure 18: Cause incidental flooding for purposes of flood risk management To provide impounded water solutions C4 This measure refers to the Yes CCS has powers to manage flooding and water for the benefits of both flood risk and powers to manage flooding the wider environmental objectives levels in the interest of wider flood risk and water levels. The nature, management, nature conservation, the scale and location of the type preservation of cultural heritage or people’s of activities that may be enjoyment of the environment proposed/required are not clear at this stage. A likelihood of significant effects cannot therefore be ruled out.
Studies, Assessment and Plans
Measure 19: Duty to Investigate Flooding Incidents To undertake investigative studies to The measure expresses a 36
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
The FWMA has placed a new duty of LLFAS to areas which are subjected to A5 general aim or aspiration for No investigate and record significant flooding ‘significant flooding’ in order to provide which there are no clear or incidents. The investigation must identify a clear understanding of ownership of direct links to European sites. ownership of the asset which has caused the the cause of flooding. flooding and the respective risk management Authority involved. To provide solutions for consideration
Flood Investigations will be reported using the To increase the level of flood data held flowing criteria:- by the Authority which will inform future flood risk management plans • Where there is internal flooding to one or more property on more than one occasion
• When more than five properties have affected by flooding
• When a commercial premises has been affected
• Critical Services has been affected
• Critical Infrastructure has been affected
When a community have been ‘cut off’ by a flooding event
Measure 20: Resilience measures
Initial awareness campaigns will be developed to The Authority is expected to develop a A5 The measure expresses a No those communities with highest risk of flooding transparent system to prioritise flood general aim or aspiration for and those who have experienced flooding defence schemes by 2015. Non- which there are no clear or 37
Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required? incidents. This measure will attempt to provide Structural solutions to warn and inform direct links to European sites. residents, businesses and other organisation communities affected flood risk will be affected by flooding with information to improve promoted as a solution. their awareness of good resilience techniques so that the consequences of flooding can be The proposed Flood Risk Management Plans for CCS will identify resilience reduced. schemes as an alternative to structure solution if considered appropriate
Measure 21: Flood Risk and Hazard Maps
The Flood Risk Regulations (2009) require all Flood Hazards Maps will be produced A5 The measure expresses a No Local Lead Flood Authorities with indicative Flood by all Local Lead Flood Authorities by general aim or aspiration for Risk Areas to produce Flood Risk and Hazard 2013 in order to provide a greater which there are no clear or Maps by 2013. These maps will be used to understanding of the probability and direct links to European sites. identify the level of hazard and risk of flooding consequences of surface water within CCS. These maps will subsequently flooding in the Flood Risk Areas; The indicate in detail the areas which are most at risk benefits will include:- from surface water flooding and will be used to inform the content of Flood Risk Management • Better understanding on the Plans. level of flood risk to affected communities • Help prepare and inform the Flood Risk Plans to be produced by the Authority by 2015 Measure 22: Flood Risk Management Plans
The Flood Risk Regulations (2009) require Lead The Flood Risk Management plan will C4 This measure refers to a lower Yes Local Flood Authorities to prepare and publish provide a clear steer on how CCS will tier plan which will include Flood Risk Management Plans by June 2015 deal with Flood Risk Areas and will recommendations for location
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Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required? where the risk of flooding from local flood risk is recommend measures for managing specific flood management significant as identified in the Preliminary Flood flood risk within its area measures. The nature, scale Risk Assessment (PFRA). and location of the type of The plan will help raise awareness and measures that may be The statutory requirement is only to produce a improve knowledge of local flood risk. identified are not clear at this Flood Risk Management Plan for the flood risk stage. A likelihood of The Plan will be used to inform other area identified as part of the PFRA. However, the significant effects cannot Flood Risk Management Authorities PFRA assessment identified other areas which therefore be ruled out. had high risk of flooding and these areas will be with the Authority’s intentions to included in plan also, so that all high risk areas manage flood risk and will help explore within Swansea can be managed accordingly. the possibilities of collaborative working for joint benefits.
High Level Awareness and Engagement
Measure 23: Community Engagement
Raising community awareness and Working with communities will help: A5 The measure expresses a No communicating effectively with local communities general aim or aspiration for will enable CCS to set realistic expectations and • Understand the need of which there are no clear or achievable outcomes for local flood risk individuals, communities and direct links to European sites. businesses management. CCS proposes to inform those that are at risk of local flooding and advise them on • Make better informed plans what steps to take. decisions and policies
• Communities to understand what flood risk means to them
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Appendix C
Measure Delivery and Benefits Screening Justification Further Category assessment required?
• Meet goals
• Increase local support
Measure 24: Collaborative Working
The City and County Swansea will work Working with other flood risk A5 The measure expresses a No collaboratively with other flood risk management management Authorities will help: general aim or aspiration for Authorities and to share information to inform which there are no clear or flood risk management aims and objectives. • Understand collectively the direct links to European sites. range of Flood Risks within Swansea
• To explore possibilities of joint funding
• To work in Partnership for common goals
• To participate in working groups for the benefit of Flood Risk Management
• To ensure best practice and a consistent approach with other Authorities
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Appendix C
Appendix 3: The sites and their features
1.0 Crymlyn Bog/Cors Crymlyn Special Area Of Conservation (SAC)/ Crymlyn Bog Ramsar Site
1.1 The following information is taken from CCW’s Core Management Plan (including conservation objectives) of Crymlyn Bog/Cors Crymlyn SAC/Crymlyn Bog Ramsar Site, 2008 15 .
1.2 Crymlyn Bog SAC crosses the boundary of Swansea and Neath Port Talbot (Figure1). The SAC comprises two component Sites of Special Scientific Interest (SSSI): • Crymlyn Bog SSSI, and • Pant-y-Sais SSSI Apart from approximately 35 hectares of land at the northern end of Crymlyn Bog, the majority of the SAC (including Pant-y-Sais SSSI) is also designated a Ramsar site. Approximately one-third of Crymlyn Bog, and all of Pant-y-Sais (excluding the adjoining Tennant Canal), is declared as a National Nature Reserve (NNR). Pant-y- Sais is also a Local Nature Reserve (LNR).
Table 1: Designated Features of Crymlyn Bog SAC, SPA, Ramsar site and Conservation Status
Designated Features Conservation Status
SAC Features Annex 1 habitats that are a primary reason for selection of this site 1. Calcareous fens with Cladium mariscus The feature is assessed as unfavourable and and species of the Caricion davallianae probably declining due to the calcareous fen (EU habitat code 7210) vegetation becoming dense and overgrown, with a reduction in species-richness.
2. Transition Mires and quaking bogs (EU The feature is judged to be in unfavourable habitat code 7140) condition due to the loss of transition mire vegetation.
Annex 1 habitats present as a qualifying feature, but not a primary reason for
15 http://www.ccw.gov.uk/landscape--wildlife/protecting-our-landscape/special-sites-project/cors- fochno-to-cwm-sac-list/idoc.ashx?docid=01d20149-ecf7-4def-9c4e-0d6908964016&version=-1
41
Appendix C selection 3. Alluvial forests with Alnus glutinosa and The feature is judged to be in unfavourable Fraxinus excelsior (Alno-Padion, Alnion condition due to the presence of oak saplings and incanae, Salicion albae ) (EU habitat code the shortage of positive ground flora indicator 91E0) species in Area A; plus the presence of dead/dying alder trees and the frequency of negative ground flora indicator species in Area B.
SPA Features Not applicable Ramsar Features (provisional)
Note: The Ramsar features for Crymlyn Bog SAC are open to interpretation at present. They will be subject to a ‘quality control’ exercise in the near future, to confirm the qualifying features. Hence the following list of Ramsar features is only provisional at present. Conservation objectives for the Ramsar features will be developed once the confirmed list of features has been agreed. 4. Topogenous fen 5. Slender cotton-grass 6. Peatland invertebrate assemblage 7. Plant species assemblage
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Appendix C
2.0 Carmarthen Bay Dunes/ Twyni Bae Caerfyrddin SAC (Special Area of Conservation)
2.1 The following information is extracted from CCW’s Core Management Plan (including conservation objectives) for Carmarthen Bay Dunes/ Twyni Bae Caerfyrddin SAC (Special Area of Conservation), 2008 16 .
2.2 Carmarthen Bay Dunes SAC crosses the boundary of the Swansea and Carmarthenshire County Council (Figure 2). The SAC comprises four component SSSI’s: Pembrey Coast SSSI Whiteford Burrows, Landimore Marsh and Broughton Bay SSSI Laugharne and Pendine Burrows SSSI The SAC also includes Burry Inlet RAMSAR and Burry Inlet SPA.
2.3 The SAC is located in three sections - Laugharne and Pendine on the Carmarthenshire coast to the south of St Clears Around Pembrey on the Carmarthenshire coast south west of Kidwelly Whitford on the north west of the Gower peninsular
Table 2: Designated Features of Carmarthen Bay Dunes SAC, SPA and RAMSAR and Conservation Status of SAC features
Designate features Conservation Status
SAC Features Annex 1 habitats that are a primary reason for selection of this site 1. Embryonic shifting dunes (EU The embryonic shifting dunes of the Carmarthen habitat code 2110) Dunes SAC are considered to be in favourable conservation status. 2. Shifting dunes along the shoreline The shifting dunes along the shoreline of the with Ammophila arenaria (`white Carmarthen Dunes SAC are considered to be in dunes`) (EU habitat code 2120) favourable condition.
3. Fixed dunes with herbaceous The fixed dunes with herbaceous vegetation of vegetation (`grey dunes`) ( EU Carmarthen Dunes SAC is considered to be in habitat code 2130) unfavourable declining conservation status. This is due primarily to undergrazing and scrub development.
16 http://www.ccw.gov.uk/landscape--wildlife/protecting-our-landscape/special-sites-project/cadair-to- coed-y-sac-list/idoc.ashx?docid=dfdab667-e5e7-472d-9896-5885c1e488c8&version=-1
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Appendix C
4. Dunes with Salix repens ssp. The two features are considered together as the argentea (Salicion arenariae ) (EU issues and management of both are linked. habitat code 2170) The dunes with Salix repens ssp. Argentea of 5. Humid dune slacks (EU habitat Carmarthen Dunes SAC are considered to be in code 2190) unfavourable declining conservation status. Annex II species that are a primary reason for selection of this site 6. Narrow-mouthed whorl snail The narrow-mouthed whorl snail Vertigo angustior of Vertigo angustior (EU species code Carmarthen Bay Dunes is considered to be in 1014 ) unfavourable declining conservation status (June 2006). 7. Petalwort Petalophyllum ralfsii The Petalophyllum ralfsii of Carmarthen Dunes SAC is (EU habitat code 1395) considered to be in unfavourable declining conservation status (April 2003) due to the lack of suitable habitat at the site. 8. Fen orchid Liparis loeselii (EU The Liparis loeselii of the Limestone Coast of South habitat code 1903) West Wales SAC is considered to be in unfavourable declining conservation status (August 2002). SPA Features 9. Pintail Anas acuta 10. Shoveler Anas clypeata 11. Teal Anas crecca 12. Wigeon Anas penelope 13. Dunlin Calidris alpina 14. Knot Calidris canutus 15. Oystercatcher Haematopus ostralaegus 16. Curlew Numenius arquata 17. Grey plover Pluvialos squatarola 18. Shelduck Tadorna 19. Redshank Tringa tetanus 20. Common scoter Melanitta nigra Ramsar Features 21. Ramsar criterion 5 Assemblages of international importance : Species with peak counts in winter 41655 waterfowl (5 year peak mean 1998 / 99 – 2002/03) 22. Ramsar criterion 6 Species / populations occurring at levels of international importance. Qualifying species / populations (as identified at designation) : Species with peak counts in spring/autumn
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Appendix C
Common redshank Tringa tetanus Species with peak counts in winter 23. Northern pintail Anas acuta 24. Eurasian oystercatcher Haematopus ostralegus 25. Red knot Calidris canutus islandica Species / populations identified subsequent to designation for possible future consideration under criterion 6 Species with peak counts in winter 26. Northern shoveler Anas clypeata
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Appendix C
3.0 Limestone Coast of South West Wales SAC
3.1 The following information is extracted from CCW’s ‘Core Management Plan including Conservation Objectives for the Limestone Coast Of South West Wales/ Arfordir Calchfaen De Orllewin Cymru SAC’, 2008 17
3.2 The Limestone Coast of South West Wales SAC comprises a series of SSSI’s stretching from Castlemartin at the western end of southern Pembrokeshire to the Bishopston Valley on the south east coast of Gower. Some of the SSSI’s that underpin the SAC have management units that extend beyond the boundaries of the SAC and they are not included in the Management Plan.
3.3 The SAC covers three separate unitary authority boundaries: Pembrokeshire Coast National Park Authority, Pembrokeshire County Council, and the City and County of Swansea. The following designations are covered: o Broomhill Burrows SSSI o Castlemartin Cliffs and Dunes SSSI o Stackpole SSSI o Stackpole Quay to Trewent Point SSSI (SAC section only) o Freshwater East to Skrinkle Haven SSSI (SAC sections only) o Lydstep Head – Tenby Burrows SSSI (SAC sections only) o Gower coast – Rhossili to Porth Eynon SSSI o Pwll Du Head and Bishopston Valley SSSI (SAC sections only) o Oxwich Bay SSSI (SAC sections only)
Table 3: Designated Features of Limestone Coast of South West Wales SAC and Conservation Status
Designated Feature Conservation Status
SAC Features Annex 1 features that area a primary reason for selection of this site 1. 1230 Vegetated sea cliffs of the Atlantic In 2004 the Vegetated sea cliffs of the and Baltic coasts Atlantic and Baltic coasts was considered to be unfavourable declining conservation status due to scrub invasion. 2. 2130 Fixed dunes with herbaceous In 1999 the sand dune habitats were vegetation (“grey dunes”) considered to be in favourable conservation status. Annex I habitats present as a qualifying feature, but not a primary reason for site
17 http://www.ccw.gov.uk/landscape--wildlife/protecting-our-landscape/special-sites-project/halkyn-to- mynydd-sac-list/idoc.ashx?docid=ce92d77c-b987-43d0-9898-eb5a8ef419f4&version=-1
46
Appendix C selection 3. 4030 European dry heaths In 2006 the Dry (calcareous) heath was considered to be in unfavourable declining conservation status due to excessive burning and scrub invasion. 4. 6210 Semi-natural dry grasslands and In 2006 this feature was determined to be in scrubland facies: on calcareous substrates unfavourable declining conservation status (Festuco-Brometalia) / Dry grasslands and due to damage from agricultural operations scrublands on chalk or limestone and over-grazing.
5. 8310 Caves not open to the public The feature is considered to be in favourable conservation status. 6. 8330 Submerged or partially submerged This feature was assessed in 2006 as being sea caves in favourable conservation status. Annex II species that are a primary reason for selection of this site 7. 1304 Greater horseshoe bat Rhinolophus The Greater horseshoe bat of the Limestone ferrumequinum Coast of South West Wales SAC is considered to be in favourable condition on the Pembrokeshire section of the SAC Annex II species present as a qualifying feature, but not a primary reason for site selection 8. 1395 Petalwort Petalophyllum ralfsii The Petalophyllum ralfsii of the Limestone Coast of South West Wales SAC is considered to be in favourable condition on the Pembrokeshire section of the SAC. Annex II species that are a primary reason for selection of this site 9. 1654 Early gentian Gentianella anglica The Gentianella anglica of the Limestone Coast of South West Wales SAC is considered to be in unfavourable declining conservation status on the Pembrokeshire section of the SAC. SPA Features Species that are a primary reason for selection of this site 11. A346 Chough Pyrrhocorax The Red-billed chough of the Limestone Coast of South West Wales SAC is considered to be in favourable condition on the Pembrokeshire section of the SAC. Ramsar Features Not applicable
Conservation Status:
47
Appendix C
The Marsh fritillary butterfly of the Limestone Coast of South West Wales SAC is considered to be in favourable condition on the Pembrokeshire section of the SAC. Not found on the Gower sections of the SAC.
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Appendix C
4.0 Gower Ash Woods SAC
4.1 The following information is taken from CCW’s Core Management Plan (including conservation objectives) for Gower Ash Woods SAC, 2008 18
4.2 The Gower Ash Woods SAC is located within Swansea. It is notified as six component SSSIs: • Parkmill Woodlands and Llethrid Valley SSSI • Pennard Valley SSSI • Bishop’s Wood SSSI • Pwll Du Head and Bishopston Valley SSSI • Oxwich Bay SSSI (part of Oxwich NNR) • Nicholaston Woods SSSI (Oxwich NNR)
Table 4: Designated features of Gower Ash Woods SAC and Conservation Status Designated Features Conservation Status
SAC Features Annex I habitats that are a primary reason for selection of this site 1. Tilio-Acerion forests of slopes, screes and The Tilio-Acerion woodland was monitored in ravines (code:9180) 2004. The overall assessment was that the feature is in unfavourable condition. Annex I habitats present as a qualifying feature, but not a primary reason for site selection 2. Alluvial forests with Alnus Monitoring that took place in 2004 concluded glutinosa and Fraxinus excelsior that the alluvial woodland is in unfavourable (Alno-Padion, Alnion incane, condition. Salicion albae) (code:91E0) SPA features Not applicable Ramsar features Not applicable
18 http://www.ccw.gov.uk/landscape--wildlife/protecting-our-landscape/special-sites-project/glannau-to- gweunydd-sac-list/idoc.ashx?docid=eaa990e3-b132-4ddd-b68e-1baa1a5efd0d&version=-1
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Appendix C
5.0 Gower Commons SAC
5.1 The following information is taken from CCW’s Core Management Plan (including conservation objectives) of the Gower Commons SAC, 2008 19 .
5.2 Gower Commons SAC is situated within Swansea. The SAC is notified as five component SSSIs: • Cefn Bryn Common SSSI • Rhossili Down SSSI • Fairwood, Pengwern and Welshmoor Commons SSSI • Courthouse Grasslands SSSI • Sluxton Marsh, Whitemoor SSSI
Table 5: Designated features of Gower Commons SAC and Conservation Status Designated Feature Conservation Status
SAC Features Annex I habitats that are a primary reason for selection of this site 1. Northern Atlantic wet heaths with Erica The condition of the wet heath of the Gower tetralix (code:4010) Commons was reported as unfavourable due to the cover of ericoids are too low and cover of sphagnum is too low. 2.European dry heaths (code:4030) Monitoring that took place in 2003 concluded that the dry heath feature is in unfavourable. 3. Molinia meadows on calcareous, peaty or Monitoring carried out in 2003 indicated that clayey-siltladen soils (code:6410) the Molinia meadows at Gower Commons SAC are in unfavourable condition . Annex II species that are a primary reason for selection of this site
Southern damselfly (code:1044) At Cefn Bryn the condition was favourable and at Rhossili Down the condition was unfavourable. The overall conclusion is that the feature is unfavourable . Marsh fritillary butterfly (code:1065) The marsh fritillary feature is Unfavourable .
19 http://www.ccw.gov.uk/landscape--wildlife/protecting-our-landscape/special-sites-project/glannau- to-gweunydd-sac-list/idoc.ashx?docid=29aea3a5-3a4b-42bd-9151-9372727f0256&version=-1
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Appendix C
6.0 Carmarthen Bay and Estuaries/Bae Caerfyrddin ac Aberoedd European Marine Site comprising: - Carmarthen Bay and Estuaries/Bae Caerfyrddin ac Aberoedd (SAC) - Carmarthen Bay/Bae Caerfyrddin SPA - Burry Inlet Protection Area & Ramsar Site
6.1 The following information is taken from ‘Carmarthen Bay and Estuaries/Bae Caerfyrddin ac Aberoedd European Marine Site, comprising: Carmarthen Bay and Estuaries/Bae Caerfyrddin ac Aberoedd Special Area of Conservation; Carmarthen Bay/Bae Caerfyrddin Special Protection Area Burry Inlet Protection Area & Ramsar Site. Advice Provided by the Countryside Council for Wales in Fulfilment of Regulation 33 of the Conservation (Natural Habitats, &C.) Regulations 1994, 2009’ 20
6.2 Conservation Objectives for the Carmarthen Bay and Estuaries Special Area of Conservation
Habitat Features: Sandbanks which are slightly covered by seawater all the time Estuaries Mudflats and sandflats not covered by seawater at low tide Large shallow inlets and bays Atlantic salt meadows Salicornia and other annuals colonising mud and sand
Range: The overall distribution and extent of the habitat features within the site, and each of their main component parts is stable or increasing.
Structure and Function: The physical biological and chemical structure and functions necessary for the long-term maintenance and quality of the habitat are not degraded.
Species Features: Otter Shad Alosa spp. River lamprey Sea lamprey
Populations:
20 http://www.ccw.gov.uk/landscape--wildlife/protecting-our-landscape/special-sites- project/idoc.ashx?docid=d3cc773f-53f7-48c6-a46f-aa1cb3eb1459&version=-1
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Appendix C
The population is maintaining itself on a long-term basis as a viable component of its natural habitat. Important elements are population size, structure, production, and condition of the species within the site.
Range: The species population within the site is such that the natural range of the population is not being reduced or likely to be reduced for the foreseeable future.
6.3 Conservation Objectives for the Burry Inlet and Carmarthen Bay Special Protection Areas
Burry Inlet SPA curlew Numenius arquata dunlin Calidris alpina alpine grey plover Pluviatilis squatarola knot Calidris canutus oystercatcher Haematopus ostralegus pintail Anas acuta redshank Tringa tetanus shelduck Tadorna tadorna shoveler Anas clypeata teal Anas crecca turnstone Arenaria interpres wigeon Anas penelope
Carmarthen Bay SPA common scoter Melanitta nigra
To achieve favourable conservation status all the following, subject to natural processes, need to be fulfilled and maintained in the long-term. If these objectives are not met restoration measures will be needed to achieve favourable conservation status. (i) The numbers of all SPA bird species are stable or increasing. (ii) The abundance and distribution of suitable prey are sufficient and appropriate to support the numbers of all SPA bird species. (iii) All SPA birds are allowed to inhabit their feeding grounds and resting areas with minimum disturbance, and are allowed to move unhindered between them. (iv) All states of the Conservation Objectives for the supporting habitats and species, subject to natural processes, are fulfilled and maintained in the long-term. Supporting habitats for bird species of the Burry Inlet SPA include: Estuaries Mudflats and sandflats not covered by seawater at low tide Atlantic salt meadows Salicornia and other annuals colonising mud and sand ‘Large shallow inlets and bays’ are the supporting habitat for the common scoter of the Carmarthen Bay SPA. (v) The management and control of activities or operations likely to be of significant effect to the oystercatchers, is appropriate for maintaining the feature at FCS and is secure in the long-term.
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Appendix D
CITY AND COUNTY OF SWANSEA ——————————————————————————————————————————————— DINAS A S IR ABERTAWE
Councillor June Burtonshaw Please ask for: Gofynnwch Overview & Scrutiny am: Direct Line: Llinell Cabinet Member for Place Civic Uniongyrochol: 01792 637257 Centre Oystermouth Road e-Mail [email protected] SWANSEA e-Bost: SA1 3SN Our Ref Ein Cyf:
Your Ref Eich Cyf: Date Dyddiad: 29 January 2013 Dear Councillor Burtonshaw,
Local Flood Risk Management Scrutiny Working Group – 9 January 2013
This letter reflects the main issues and views arising from our discussion on the draft Local Flood Risk Management Strategy which was published for consultation by Cabinet recently.
The Working Group heard from the lead officers Chris Vinestock, Head of Transportation, and Mike Sweeney, from the Environment Department. They provided us with a background to the work going on in this area, explained the role of the Council as a Lead Local Flood Authority (LLFA), and answered questions about the strategy and next steps.
We understood that whilst certain agencies (e.g. Environment Agency) had specific responsibilities, being the LLFA meant the Council had overall responsibility for oversight of flood risk management and playing a coordinating role, bringing t ogether the various agencies and people involved. Members heard that the designation of LLFAs and the need to develop local strategies were designed to address historical weaknesses identified in the system, including fragmentation of responsibilities.
Cont’d…
OVERVIEW & S CRUTINY / T ROSOLWG A CHRAFFU CITY AND COUNTY OF SWANSEA / D INAS A SIR ABERTAWE CIVIC CENTRE , SWANSEA , SA1 3SN / C ANOLFAN DDINESIG , ABERTAWE , SA1 3SN www.swansea.gov.uk Appendix D
It was recognised that the establishment of LLFAs was a recent change in law and we noted that at this stage the draft strategy effectively represented a starting point. We learned that this would move on over the next year to detailed assessments and then plans to deal with flood risk, with the identification of action for specific areas in Swansea. It was stressed to us that prioritisation would be necessary because of limited resources, as well as considering other important factors such as environmental objectives.
We explored the different causes of flooding in Swansea and it was pointed out that solutions to flooding in the area were not simple or straightforward. Swansea had a disproportionately large number of springs and ground water issues (levels were high), with lots of different water interactions at play. Also, the number of old mine workings in the area posed a problem. What was made clear to us was that the priority for both the authority and the Environment Agency was flooding that risked damage to housing / buildings. For example, flooding to gardens would not be considered as top priority. Clearly the interaction of tides and rivers would pose the biggest problem in terms of severity of impact to Swansea but was less likely however the potential was nevertheless significant.
The officers shared some maps which showed past flooding events in the area, surface water risk maps, and the potential of groundwater flooding. It was noted that by December 2013 the authority would have flood risk and flood hazard maps from the Environment Agency. This will provide a greater evidence base to look at areas and issues in more detail. We were informed that a comprehensive flood risk plan would then be produced by 2015. It was clear from our discussion that historical records on flooding had been patchy but a new system and approach, combining records from other sources such as Welsh Water and the Fire Service, will ensure that high quality information will be collected a nd analysed. This will capture the nature of flooding, causes, action taken, likely recurrence, preventative or protective measures necessary etc.
We would like to bring to your attention the following points from our discussion and suggested actions:
Raising Awareness
Given the incidence of flooding in recent years much works needs to be done in raising awareness within communities and in the provision of information that will help people. The authority should ensure that people have advice about who to contact in the event of an incident or how to resolve an issue. Councillors can play a significant role but only if they are also well advised about the respective roles of relevant organisations and options in terms of signposting people, particularly where people are left to deal with issues that the authority may deem low priority. Whilst the authority may not always be the ‘responsible body’ we feel that as the LLFA the authority must be on hand to help, Appendix D
such as giving clear advice e.g. on causes and possible solutions, even to extent to supplying sandbags albeit with a nominal charge. We accept that the authority has to be realistic about what it can provide, and appreciate the efforts of those supporting this work given limited resources. We feel that the production of a ‘fact sheet’ on flooding may be of help to both councillors and local communities. The authority should also highlight how important it for people to check that work done to their property does not increase flood risk, e.g. driveways, patios.
Maintenance
We believe that many instances of flooding in the area can be attributed to poor drainage. Councillors shared their experiences of certain areas where this seemed to be a common occurrence after heavy rainfall. Although this may affect the highway more so than property, road safety and access is also impo rtant. We would stress the importance of maintenance to prevent flooding issues. Councillors also shared examples of culverts that have caused flooding and again felt that a good inspection, cleaning and maintenance programme would help to prevent flooding and risk to nearby properties. We did note, however, that the highway drainage system was very old and would require significant investment to not only improve but to excavate and inspect pipes for blockages etc.
The Planning Process and Permitted Development
We are concerned whether everything is being done not only to avoid inappropriate development in areas at risk of flooding but to ensure that wherever development is permitted adequate measures are in place to ensure effective drainage systems. The authority should be looking at sustainable drainage systems to be part of new developments and encourage the use of permeable surfaces. Unfortunately developers may look to the cheapest solutions to drain away water and these may fail in later years leavin g the authority to deal with the problem and pick up the cost. Not to mention the consequential impact on surrounding residents. We learned that new powers are being given to local authorities in terms of ‘approving’ drainage systems, though specific arran gements had not yet been agreed nationally. We would urge the authority to take advantage of such powers in tandem with the planning process, and give greater focus to drainage issues within planning applications and enforcement of conditions. Ideally this process will be self-funded through commuted sums or developer contribution. There may be a balance to be struck but the authority needs to agree at the outset liabilities and ensure that costs for future maintenance are covered. The burden should be on d evelopers to pay for improvements to water management systems required, not the council. Appendix D
Welsh Water not being statutory consultees has been an unfortunate flaw in the existing planning process. This has meant concerns about risks from certain development s may have not been adequately aired. However, we were informed by officers that there was a change in the law which will mean Welsh Water will be required to make comments and can object to developments. This will certainly be a step change in improving matters.
We were pleased to hear that the planning service routinely consults with the officers about applications and there were positive relations with clear systems in place for communication. The officers also reported good relations with the Environment Agency.
LiDAR Flood Risk Mapping
Some councillors had previously seen a demonstration of the digital terrain model data supplied by the Environment Agency, captured using the LiDAR (Light Detection and Ranging) system. We suggest that you consider whe ther all councillors (but particularly new councillors) would benefit from a meeting with colleagues from the Environment Agency to learn more about flood risk and their local modelling work. Perhaps you could arrange a councillor seminar in the near futur e as part of the ongoing work if the Environment Agency is able to do so. Members recalled how the LiDAR maps provided a very compelling picture of the impact of flooding in the area from potential events. We presume that you are using such information to inform future plans for prevention and protection in Swansea.
We were informed by officers that initial feedback from the Welsh Government and Environment Agency on the draft strategy was positive, though not surprisingly stressed the importance of moving onto the next stage i.e. detailed proposals and more focussed discussions. We noted that the strategy must be submitted to the Welsh Government by the end of March 2013.
Clearly there is a need for joined up thinking between relevant agencies but we also expect that you ensure that departments across the council are being mindful and attentive to playing whatever part possible to prevent and help protect Swansea f rom flooding. We would ask you to make sure that lessons are being learnt from experiences elsewhere, particularly with regard to emergency planning and response, including issues such as alerting people and communication in advance of risk and getting mes sages to people when they are in imminent danger. Appendix D
Summary of our recommendations:
• production of a community ‘fact sheet’ • improving advice and assistance to people dealing with local issues • improving inspection, cleaning and maintenance of drains and culverts • a councillor seminar on flood risk as the strategy develops • greater consideration of drainage issues in development control • ensuring a corporate approach to flood risk management • learning from experiences elsewhere
In conclusion the Working Group felt that there should be a further discussion by scrutiny when more detailed plans are developed and there is information about specific areas of risk. As flood risk and flood hazard maps were likely to be available towards the end of th e year it would be a good opportunity for the group to meet again. We would stress to you that consultation and engagement with communities will be more critical when there is information at a very local level, to ensure that flood risk is properly underst ood and proposed measures / remedies are supported. Flood risk management is not a one-off exercise but an ongoing process and therefore ongoing monitoring by scrutiny is important. We will ask the Scrutiny Programme Committee to consider this when determi ning the scrutiny work programme for the next year.
We would be grateful for your response to this letter.
Yours sincerely,
COUNCILLOR SUSAN JONES Convener, Local Flood Risk Management Scrutiny Working Group [email protected]
cc: Working Group Members Chair / Vice-Chair of Scrutiny Programme Committee Corporate Director (Environment) Chris Vinestock – Head of Transportation Mike Sweeney – Engineer, Environment Department