28Th Oct 2016 FINAL Dear Sheffield City Council Thank You for Consulting Us on the Flood Prevention Proposals for the Upper
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28 th Oct 2016 FINAL Dear Sheffield City Council Thank you for consulting us on the Flood Prevention proposals for the Upper Don, Sheaf and Porter Valleys. We totally understand the need for increased flood protection measures in Sheffield and applaud the Council for securing substantial funding from the central Government and the Environment Agency to address the risks. Q1. Do we agree with the objectives of the Sheffield Flood Protection Programme? - Protect our communities – yes, we do understand this is the priority for the programme and agree it is the primary objective – flooding can be totally devastating to communities, individuals and businesses and although we have substantial comments to make on the proposals we are not suggesting that nothing should be done. - Grow our Economy – this is not a general principle that we would object to, but the consultation is lacking in detail. All the information we can find in the consultation says: o enabling development of 46 hectares of land – but it does not say where or for what purpose so it is difficult for us to comment at this stage o Potential for 15,000 new jobs – again no detail about this so we cannot comment at the moment o 27,000 new homes – again it does not say where so we cannot comment at this stage o £150million annual economic growth into Sheffield – again no detail about how this figure has been derived so we cannot comment at this stage. Have the economic and other benefits (ecosystem service etc) of natural flood management upstream been assessed at all? It must not be assumed that ‘hard’ defences are the only measures that can bring economic benefits. - Transform our waterways – again the consultation is lacking in detail so in theory we agree with this objective but we would like more information o Reliable river maintenance – this sounds like a good idea so agree o New recreation opportunities – this could be a good idea but it depends where and what? o Hydro-electric power generation – likewise this may be good assuming no negative impact on fish passage but we would need to know more details o Sustainable transport routes – there is no information about this in the consultation or how it links with the flood defence proposals, but again it sounds positive? o Regeneration of 30 hectares of riverside for people and wildlife – this could be good but without any information on where and what we cannot comment – we would welcome the opportunity to be involved in this objective. We have recent relevant experience of delivering riparian improvements in Sheffield and Rotherham. These include Centenary Riverside (see later), created as part of the Rotherham Flood Defence Scheme, wetland habitat creation at Kilnhurst Ings and river restoration at Catcliffe (which included ensuring habitat improvement did not result in increased flood risk for properties in this sensitive area). We would be happy to share more information about these schemes. o Improved health and wellbeing – again, we are supportive of this as an objective but are not sure how health and wellbeing would be improved Sheffield & Rotherham Wildlife Trust , Victoria Hall, 37 Stafford Road, Sheffield, S2 2SF T: (0114) 263 4335 E: [email protected] W: www.wildsheffield.com Registered charity no. 700638 Company no. 2287928 through these proposed measure? Again, we would welcome the opportunity to be involved in relevant discussions. Q2. Which aspects of Sheffield’s rivers do you value most? Please tick all that apply, or add your own thoughts about the value of the rivers to your community and the city - As a Wildlife Trust the aspect we value the most is ‘supporting a wide variety of plants and wildlife ’ but our work also includes engaging people in enjoying the natural environment and improving the quality of the environment. We know that the rivers are the natural backbones of Sheffield and provide the ecological corridors through the city. Our mapping shows the highest levels of ecological connectivity along the corridors and it is essential to maintain and enhance this. The rivers also provide a sense of place to the people of Sheffield and enhance their quality of life. As the water quality of the Don and its tributaries has increased over the last few decades, wildlife has returned to the city and the rivers provide some of the wildlife oasis’s in the urban environment. There is always more to do to enhance the rivers for wildlife and we hope that this consultation will offer the opportunity to do this. Q5. Options for reducing flood risk from the Sheaf and the Don overall do you agree with the range of options that is being considered? We are pleased that a range of options are being considered. However, the options have been arranged into four themes but the consultation only covers themes 2. and 3. (although Q11 and Q13 do briefly mention themes 1 and 4 so it is rather confusing). We are disappointed that the consultation does not provide more information about theme 1 and I will pick this up in Q11. I pick up the fourth theme in Q13. We disagree with the way you have used the term ‘Slowing the flow’ – to categorise the options. You have used this to cover: 1a. Rural land management; 1b. Managing existing reservoirs; 1c. Creating new storage areas; and 1d. Urban water management. However in other projects it is just used for the 1a. Rural/natural land management approached (e.g. see Slowing the Flow at Pickering referred to in Q11). Although you could say that the use of SUDS in 1d could be classified as slowing the flow, we would argue that 1b and 1c are actually ‘Containing the flow’ options. 1b. Managing existing reservoirs does sound like an option worth exploring with Yorkshire Water who are the third partner in the Sheffield Flood Risk Management Partnership (with SCC and the EA). We appreciate that reservoirs are primarily managed for drinking water and that this will remain the main priority, but could ‘compensation reservoirs’ provide large areas of storage in times of potential floods? There is no further information in this consultation about this option and no question about it. What difference would this make to the amount of water that may have to be contained further downstream? The Sheffield- Flood-Risk-Management-Strategy (2013) says “a component of the SFRMS will be to investigate the effect that upstream reservoir operation and flow management may have in reducing flood risk in the Don Valley” and “the Upper Don Reservoir Storage Study schedules for completion in 2013 that is assessing the potential for upstream management of flows .” Has this investigation of the 23 reservoirs upstream of the city been undertaken and the results been taken into account as part of these studies? 1d. Urban Water management – SUDS schemes, green roofs, rain gardens, green infrastructure in the city centre and using permeable materials will all contribute to reducing runoff and flooding. Again there is no more information in this consultation about these options and what a difference they could make and no question about them. There Sheffield & Rotherham Wildlife Trust , Victoria Hall, 37 Stafford Road, Sheffield, S2 2SF T: (0114) 263 4335 E: [email protected] W: www.wildsheffield.com Registered charity no. 700638 Company no. 2287928 are champions of SUDS schemes within SCC and this should be explored to a greater extent (see our suggestion in Q12). The Green Roof Centre in Sheffield should be supported through funding and strengthening planning policies to increase the number of green roofs on new developments (e.g. why has the new IKEA not got a green roof?). It is estimated that surface water flooding contributed 5% of the flooding in 2007. There is a ‘Sheffield Surface Water Management Plan’ (not sure if this is publically available but it is referenced in the Sheffield Flood Risk Management Strategy. There has clearly been much work going into this area since 2007, which is positive - how will putting these measures in place contribute to the risk of future flooding? 2a. Removing pinch points - De-culverting, modifying bridges and weirs and re- landscaping are all mentioned. Three places are mentioned in the text (no questions about these?) – Sheaf debris improvements, Lower Porter river improvements and modifying the weir at Oughtibridge. These are all certainly worth exploring further and may well have been by the Surface Water Management Plan. It would also tie in with the ambitions of the ‘Sheffield Waterways Strategy: City of Rivers’. A recent example at Matilda St has provided flood storage, green infrastructure and increased economic value of the land. Has there been an exercise to see if more like this could be created? We would also like to make the point that otters, white-clawed crayfish and bats use the River Don and its tributaries and so all work of this kind should consider the impact on these protected species. Q6. Our current work is showing that due to the nature of the Upper Don and Sheaf Catchments, the most appropriate options are focused on the balance between flood storage areas and flood defences. Do you agree in principle that we should try and find spaces to temporarily store flood water in areas of existing flood plains along the rivers, in order to reduce flood risk and potentially minimise the impact of flood defences downstream within the city? Please write any additional suggestions. Agree (but) Comments: we agree that some flood storage areas are probably necessary but we do not necessarily agree with the current approach which seems to be favoured. The emphasis seems be on building a small number of large engineering solutions – embankments, supported by a small number of ‘basin-style’ flood storage areas on existing green spaces.