Brinkworth Parish Council                            FRE0137

Written evidence submitted by Brinkworth Parish Council

Strengthening flood resilience

1. To what extent are current flood resilience assets and interventions fit-for-purpose and what are the strengths and weaknesses?

• Are there alternative approaches from across the UK and elsewhere which could help inform improvements and innovation?

Flood resilience along M4 corridor between junction 16 and 17 needs urgent attention:

Culverts which were built in 1969/70 before the onset of climate change were not deep or wide enough to cope with floodwater resulting from intense rainfall. Because the M4 was built on a floodplain, the floodplain cannot work to mitigate the sudden intense levels of rainfall. Because the culverts were not able to cope with the level of flooding the water is diverted along the M4 flooding farmland, property and the Motorway itself. Houses that were never flooded prior to the M4 being built are now flooding. Houses built from the 1980s until more recently are flooding.

Irrespective of any flood level risk, there should be no new housing developments considered or approved in those areas that flood or the access floods significantly.

Environment Agency maps (which are currently being updated) are out of date and do not reflect current or future flood levels. Outside towns they are not reaching an acceptable level of accuracy.

2. How appropriate is the current balance between 'green' nature-based solutions and 'grey' hard infrastructure resilience assets, and what adjustments, if any, are needed to improve it?

• What role can natural flood management techniques, such as wetland restoration and tree planting, play in enhancing flood resilience while contributing to broader biodiversity and climate objectives?

Green nature solutions should be applied where necessary (The Woodbridge brook north of the M4 in this same section floods and holds the water for 24-48 hours before releasing the water back into the stream thus slowing down to rise of the river Avon further downstream). The meandering nature of the watercourse also helps to slow down the flow and attenuation ponds would assist further.

This in turn alleviates the volume of water flowing through the more built up towns of Malmesbury and Chippenham.

Where there is sewage plant spill/overflow (in this case Wessex Water and Thames Water west of Royal Wootten Bassett) water meadows and reed beds/marsh should be part of the solution to avoid polluting farmland and property downstream.

In the past solids from sewage was separated and stored on agricultural land as a means of offsetting sewage being discharged into water courses during flash flooding.

3. What changes to the planning system and building regulations are needed to ensure that buildings and infrastructure are resilient to flooding in the short, medium, and long-term?

Not building on flood plains where there is a conflict of priorities i.e. motorway and local communities.

Link any development to compulsory flood mitigation schemes.

• What long-term land use strategies and approaches to flooding should the government consider, especially for communities that cannot be protected from flooding or inundation?

Digging out ditches, dredging rivers/watercourses in these key areas, increasing the size of culverts where necessary (it is vital that Parish Councils and Local Authority should call on local experience).

Monitoring flood resilience

4. To what extent are current metrics for monitoring the effectiveness of flood resilience fit for purpose, and what improvements could make them more effective?

• Do current metrics capture the range and effectiveness of privately-owned flood resilience assets, and if not, how can this be improved?

• Do we have appropriate metrics and mechanisms to measure the cost effectiveness of flooding assets and interventions in terms of investment versus long-term savings and, if not, what should they look like?

Repeated flooding has enabled householders to introduce basic measures through their insurance to mitigate against flooding to a limited extent. However, insurance companies are repeatedly having to pay for restoration and part of the policy should include engineering work to prevent future flooding (i.e bunds, tanking, etc) Door flaps, etc only delay and are ineffective if the water rises from underneath which brings us back to improving grey infrastructure (ditches, culverts, drains) and where appropriate, water meadows and natural solutions, thus preventing sewage from entering watercourses/farmland and property.

The current build back better scheme which offers up to £10,000 is slow to implement because it requires 3 surveys (which in themselves can amount to £3,000) and create a backlog.

Metrics are not readily available: past or current rainfall and water levels.

Coordination of flood resilience

5. How effectively and how frequently do flood risk management authorities work together to tackle flooding issues and do they have sufficient resources and skills available to carry out their work?

• For instance, how can the government ensure that areas prone to flooding near the mouth of a river, are not negatively impacted by increased pressure on the river, or by flood-mitigation measures taken upstream?

• Where is the interface between the responsibilities for river and surface water flooding, and how could monitoring and coordination be improved to enhance effectiveness and early warning of flooding?

The Environment Agency, Highways and Network Rail have not enough resources dedicated to work that is necessary.

1)      Network Rail: during the last 40 years engineering has been carried out to widen embankments to support heavier trains and attenuation ponds which were originally installed by Brunel have been filled in and not replaced by new flood mitigation measures.

2)      National Highways: ditches and culverts along the M4 have not been cleared on a regular basis.

3)      The Environment Agency: when the EA took over from the National River Authority it changed the terms of reference without enough warning to landowners that they would no longer be maintaining main rivers.

6. What should the key priorities be for the Flood Resilience Taskforce, and how can it enhance coordination and improve flood resilience?

• Is there a role for community-based flood response teams, and who is responsible for building that resource?

Local knowledge should be embraced to carry out engineering projects to alleviate flooding in the form of digging out ditches, dredging watercourses, introducing culverts, attenuation ponds to allow water to run into water meadows.

7. Is there a backlog in maintenance of existing flooding adaptation/resilience assets and in identifying where new ones could be introduced?

• Is there clarity about whose responsibilities these are, and how could this be improved?

There is confusion as to who is responsible for the maintenance of main rivers and flood mitigation assets between riparian owners and the EA. The system of licenses for de-silting water courses is excessively complex.

• How strong is the knowledge base on both the condition of existing assets and where new ones might be needed and what steps could strengthen it?

Resources, funding and support for flood resilience

8. What level of flood resilience is required to address the flood risks identified in the Climate Change Risk Assessment and is current funding adequate to meet these risks effectively?

• Is there sufficient government support and funding for the maintenance of privately-owned flood defence and resilience assets?

Farmers/landowners can apply for grants through Defra and administered by the County Council, to carry out work to dredge/clear watercourses of fallen trees and silt where appropriate, or to pay a contractor to do this. There is a time limit on this till 1st July 2025 and they are quite often deterred by the cost of obtaining licences.

• What changes, if any, should be made to the next iteration of the Flood and Coastal Erosion Risk Management (FCERM) investment programme to improve its outcomes?

• How well does the National Adaptation Plan address the need for flooding adaptation measures, and what additional steps should be taken to ensure effective long-term flood resilience in high-risk areas?

Creating new attenuation ponds.

9. How can the Government encourage more long-term private investment in flooding defences and resilience measures?

• What role can the insurance industry play in supporting this?

There should be a clause in the insurance policies which holds householder/landowner responsible for maintaining ditches on their property if it is subject to flooding or causing flooding to their neighbours. Perhaps a reduction in their premium if they carry out this work?

The current licensing system is a barrier to property/landowners actively clearing ditches.

10. What support do property owners and neighbourhoods require to enhance their resilience to flooding?

• What is the current level of awareness among property owners about flood resilience measures, how they can be improved, and who can support it?

Using local knowledge and a local task force has been shown in the past to achieve more for less expense than using EA employees.

See earlier point about insurance policies under section 4.

Owner of property which floods should be given 50% grants to install flood defences, if it is deemed this will protect the property from future flooding.

January 2025