Written evidence submitted by Telford & Wrekin Council (FLO00008)

 

  1. Executive Summary 

 

1.1.               Telford & Wrekin Council is a Unitary Local Authority, which acts as Lead Local Flood Authority (LLFA) for the Borough.  Telford & Wrekin recently experienced and responded to severe flash flooding from Storm Dennis, followed by fluvial flooding along the River Severn. The flooding caused significant disruption to communities and businesses within the Ironbridge Gorge World Heritage Site or WHS (through which the River Severn runs) and is having lasting long term impacts to those communities and the Council.

 

1.2.               The only defence against flooding is the local area is temporary barriers in the Ironbridge area, with a number of communities along the length of the River Severn including Jackfield and Coalport having no defences at all. A comprehensive set of measures is required to improve resistance and resilience to flooding including the need for permanent defences to protect communities along the Severn. The cost of permanent flood defences in the Ironbridge area is estimated to be in excess of £70m in capital funding given the complexities of working within a World Heritage Site, land constraints and the need to rebuild the river retaining wall (costs subject to formal technical studies). This is beyond the capacity of the Council to fund and would require a capital contribution from Central Government.

 

1.3.               There are three key issues that need addressing in the response to flooding events such Storm Dennis and its aftermath, these are:

 

1.3.1. Strengthen the ability of local authorities, such as Telford & Wrekin Council, to deal with flooding events quickly, safety and with the right powers and resources to provide ‘community leadership’ to affected residents and businesses as well as a strong coordination role with partner agencies

 

1.3.2. Dealing with the aftermath of flooding events is a key issue for all communities that are affected. The need to return to ‘business as usual’ is particular acute in areas that have a high proportion of small and medium independent businesses which are harder hit by the loss of revenue.

 

1.3.3. Longer term planning and investment is needed to ensure that communities, homes and businesses have the best protection possible against repeat instances of the recent floods. Resilience to flooding can be best achieved a whole system approach from planning policy to flood storage to capital investment in flood defences to individual property protection. 

 

1.4.               The Council are justifiably proud of the response to the recent events including the actions of the organisation, partner agencies (such as the EA) and the local community. What the events clearly demonstrated was there is a need for capital investment, from Central Government, in flood defences and flood resilience that is required now, which is beyond the financial resources of the Council. This also needs to be supported by Government commitment to a whole system approach to river management as a long term answer to the devastation wrought by these increasingly frequent flooding events.

 

Inquiry Questions

  1. Are the current national and local governance and co-ordination arrangements for flood and coastal risk management in England effective?

National Government

2.1.               Improvements can be made to governance and co-ordination arrangements at a national level which would greatly help aide the response to flooding events, these include:

 

2.2.               Centralising Ministerial responsibility - Aspects of flood management fall under both MHCLG and DEFRA, who often have different and sometimes competing proprieties. Authority under one department would be far more effective e.g. the NPPF doesn’t give enough weight to surface water flood risk; LLFAs and LPAs are restricted to how they can manage this under the government guidance and it is unclear for developers. 

 

2.3.               Implementation of Sewers for Adoption 8 – This may address some of the issues around sewer design, SuDS adoption and ultimately reducing flows into rivers such as the Severn, however it has seen a lengthy delay in implementation at a national level. A significant number of new developments have been built since the Flood and Water Management Act 2010 and since the transfer of private drains and sewers in October 2011. Water and Sewerage Companies do not appear to have been provided with much resource to effectively deliver SfA8 and engagement with LLFAs has been minimal. This needs to be addressed as part of a whole system approach.

 

2.4.               Better balance with National Flood Funding - Funding is based on homes protected which means that some flood defence schemes are shelved as they cannot effectively access funding e.g. schemes that principally benefit businesses.  This leaves certain areas, communities and types of flood defence schemes disadvantaged by the current rules. Ironbridge in Telford is a UNESCO World Heritage Site where the local economy is based on tourism and small-medium sized independent businesses that are heavily reliant on footfall with 1.5m visitors annually.  The WHS has significant economic value in the Borough contributing £90m to locally economy and the impact of flooding is strongly felt. The issue is the economic contribution and significance of areas such as the WHS are ignored in the distribution of flood defence funding.

 

2.5.               Forward planning for Flood defence schemes – Schemes are managed on the basis of a 6 year programme and this works well to forward plan investment. This is the final year of the current 6 year programme but there still has not been the detail for how the next 6 year programme will run. This makes effective forward planning beyond the current 6 year programme difficult, especially in light of the recent events.

 

Local Government

 

2.6.               Improvements can be made to governance and co-ordination arrangements at a local level which would greatly help aide the response to flooding events, these include:

 

 

 

2.7.               Regional cooperation works well - Telford & Wrekin fall within the English Severn & Wye Regional Flood and Coastal Committee Area; the RFCC is effective at bringing together various government bodies, Councils and organisations working to manage flood risk within the Severn Catchment. Also good flood network within the Shropshire Middle Severn Catchment Based Approach group, which facilitates local water/environmental/climate change projects.  Regional water resource management is also beginning to grow with the inception of Water Resources West.

 

2.8.               Stakeholder management - The range of Authorities and Strategies involved in managing flood risk both regionally and locally can become unwieldly (e.g. RFCC, CaBA, Water Resources West, Severn Trent Water, STW’s Drainage and Wastewater Management Plans, LLFAs, Local Flood Risk Management Strategies, LPAs, Local Plans, IDBs). Consolidation of responsibilities would help especially in planning and distributing flood defence funding.

 

2.9.               Local capacity works The Council have maintained and invested in its in-house engineering team. This is has been a critical elements of its ability to work alongside other partners (Severn Trent, EA and LPA) to ensure there is a fast and effective response to flooding and also plan for the longer term.  There is also good coordination internal coordination between drainage and engineering teams.

 

2.10.               Flood relief grants for businesses – The system of Flood Relief Grant scheme worked well for immediate issues in terms of clear up costs for those directly affected by the flooding. The grant also provide some help for things such as loss of trade for businesses up to a point, it was a generous sum to small businesses but only a token contribution to others. In the case of the WHS the larger businesses such as pubs and restaurants are critical to the economic eco-system of the area and have struggled as a result of losses incurred, this has also been compounded by the Covid 19 Pandemic. The key to improving this scheme is a wider range of grant values to better reflect the scale of losses for severely affected businesses especially, some businesses were flood 3x times over a two week period. The Council invested officer time in meeting business owners face to face to explain the scheme, this was time intensive but it resulted in better quality applications with less follow up time at a later date. Face to face contact also showed community leadership from the Council and the public sector as a whole and staff were also able to address or sign post in relation to a wider range of issues.

 

2.11.               Flood Resilience Grants Sums of £5k are expected to be made available for affected properties. In the case of businesses and homes within a WHS they will have higher costs associated with the need to take account of heritage and conservation of the area. These additional ‘costs’ will undermine the value of the grants and the level of protection that they can provide, these factors should be taken into account when apportioning grant to, for example areas of high conservation value. In some cases £5k is insufficient especially where homes and businesses would benefit from better more sizeable measures such as removable barriers. Flexibility in the pooling of grants is needed, this is especially useful in smaller communities that might benefit from a single scheme rather than individual property protection. The immediate concern of the Council is that there has been no notification of when these funds will be available and how businesses can access them, despite repeated requests for this information – this needs to be resolved.

 

  1. What lessons can be learned from the recent floods about the way Government and local authorities respond to flooding events?

 

Immediate Response

 

3.1.               Local lessons learned in the Councils immediate response to the flooding events is summarised below:

 

3.2.               Multi-agency working and community leadership - The Local response to the recent floods was generally good and showed that a multi-agency approach can work. Councils are well placed to provide a ‘community leadership’ role however access to additional resources and emergency powers at short notice are key to making this work. A key part of this role is the support for local communities and responding to what can be complex and serious needs in a high pressure situation. This is especially the case in Telford where some communities were quickly and severely impacted by flooding.

 

3.3.               Good forward planning - The Council ensured additional officers were on duty when Storm Dennis struck, allowing it to respond quickly to flooding occurring overnight and to respond to property flooding and keep the critical highway network safe.  Contractors also facilitated additional resource to meet this demand. Telford & Wrekin Council staff also supported the EA with extra staff to deploy the Ironbridge flood barriers.  The Council recognised the pressure on the EA as the storms necessitated the deployment of large numbers of flood barriers across the country and the EA had to resource this.

 

3.4.               Good forecasting - This is essential to planning emergency responses. The Met Office send regular updates during flood season, however the Storm Dennis was more severe than anticipated, as were its impacts on the River Severn.  Investment in forecasting and data sharing is needed to provide the best window of opportunity for emergency responses.

 

3.5.               Consistent use of data - Forecasting river levels is very difficult but the messaging to the public needs to be clear and consistent.  There were high levels of uncertainty in the recent events which reduces the effectiveness of messages and use of information technology / social media.

 

3.6.               Central control and coordination - The Council and Emergency Services across the Borough had to respond to a high volume of calls during the floods and extra shifts were brought in to cope with the demand.  The Councils contact centre also played a key role in keeping in touch with affected residents to understand their needs and arranging help where possible. A fast response from the Councils Emergency Planning team was effective in helping to coordinate multi-agency working and get ‘on the ground’ quickly to support immediate community needs such as re-homing residents for the duration of the flooding. The ability to redeploy resources to aid in an emergency response is a key part of the Council community leadership role, this was done across a number of areas including; Customer Services, Environmental Services, Finance, Planning, Business Support and Emergency Planning.

 

Longer-term response

 

3.7.               It is the Councils view that a resolution to learn from these recent events requires a long term approach to lessons learned and what action is required in the future, these include:

 

3.8.               Residential insurance is a problem - Despite Flood RE, a high proportion of our residential properties have fed back that they are not able to easily obtain viable flood insurance.  As a result, a large number of the properties that flooded were uninsured. The Council are able to help provide advice and link people to e.g. grants and volunteer groups, but there is a real need to ensure that insurance is accessible and reasonable for home owners in areas such as the Ironbridge and the surrounding communities or Jackfield and Coalport. Recovery for these people will take a long time

 

3.9.               Flood insurance protection for business is an urgent priority - The impact on businesses is far worse, particularly smaller businesses that rely on footfall as is the case in the WHS. This was either from direct flood damage or as a result of being forced to close by e.g. road closures, evacuations etc.  Business flood insurance, particularly for smaller businesses with lower turnovers, is needed as an urgent priority.  This will help smaller businesses to get back on their feet and invest in measures to increase their flood resilience and is especially critical in areas like the WHS which have a large visitor economy. Some of our smaller businesses flooded 2 or 3 times in the space of a week and this has been devastating to them.

 

3.10.               Grants for homeowners and businesses - These need to be quick and easy to access for people who have flooded (and seen their homes and/or businesses destroyed).  The mental health impacts of flooding are huge and as much “red tape” as possible needs to be removed in times of emergency. The Central and Local Governments response to COVID-19 is a case in point.

 

3.11.               Access to immediate emergency funding for Local Authorities - e.g. Bellwin Scheme, is very helpful, however remuneration is a slow process and needs to be sped up to increase the efficiency of the response.

 

3.12.               Infrastructure resilience - There are also no emergency funding pots to help the Council address managed works after an event. In this case riverside carriageway repair works in Ironbridge will be needed to maintain its integrity following the flooding (the carriageway is fundamental to the performance of the temporary flood barriers).  The Council would also like to redesign the carriageway (e.g. materials, camber etc.) to perform better with the flood barriers.  Currently the cost for this unplanned work will fall to the Council to find resource for amid other budget pressures e.g. Adult Social Care. Area such Ironbridge and the surrounding communities have complex, challenging and historic engineering legacy issues which are beyond the capital resources of local authorities to address, Central Government investment is critical. The February 2020 floods on the River Severn were only moderate in terms of return period, but showed how much infrastructure damage and transport and economic disruption can be caused by flooding. Associated infrastructure should also be consider as part of any response to addressing flooding. Locally this concerns telecommunications within the WHS, which had traditionally suffered from poor signals. The ability to use phones and broadband in areas such as the WHS in times of emergency is absolutely critical in providing information to residents and coordinating the response of agencies.

 

  1. Given the challenge posed by climate change, what should be the Government’s aims and priorities in national flood risk policy, and what level of investment will be required in future in order to achieve this?

 

4.1.               It is the Councils opinion that national flood risk policy must incorporate the following aims and priorities to be effective in order to tackle climate change:

 

4.1.1. Levelling the playing field between residential and business flood protection measures

 

4.1.2. Increasing capital investment in flood defences as part of a whole systems approach to river management

 

4.1.3. Resourcing Lead Local Flood Authorities and Local Authorities in having an effective community leadership role with both financial measures and legal powers to act and act quickly

 

4.1.4. Seek best data and information available on flood risk, modelling and forecasting and making this available to Local Authorities and stakeholders.

 

4.1.5. Give Local Planning Authorities the tools to seek integrated drainage, ecology, biodiversity and open space schemes from developers as a must in major development schemes.

 

4.2.               Specific comments are included below:

 

4.3.               Future growth The response to climate change and growth are intrinsically linked and it should be a requirement of investment through LEPs, Combined Authorities and Central Government to proactively integrate climate resilience into all infrastructure works. One of the key aims in the new National Flood and Coastal Erosion Risk Management Strategy is expected to be that “today’s growth and infrastructure is resilient in tomorrow’s climate.”

 

4.4.               NPPF Strategic planning policy is fundamental to providing a joined up approach to flooding, climate change and growth. The NPPF requirement for development outside Flood Zones 2 and 3 does not currently consider climate change. Surface Water flow paths and exceedance flows are also poorly understood and designed for. LPA’s require greater powers to secure better schemes from developers. Better understanding and delivery of high quality, multi-functional SuDS by developers, architects and civil engineers is also needed to ensure that National policies can reach grass roots level and facilitate delivery of more effective sustainable drainage.  This will support carbon reduction and sequestration. 

 

4.5.               Better resourced LLFAs These can support early engagement and proactive delivery of high quality SuDS on new developments and act as facilitators to the delivery of housing targets. It is often the case that poorly resourced LPA’s are slower at determining planning applications thereby stalling developments needlessly

 

  1. How can communities most effectively be involved, and supported, in the policies and decisions that affect them?

5.1.               There are a range of measures that could be used to effectively involve and support communities in policies and decisions that affect them in relation to flood risk, these include:

 

5.2.               Community Champions - The new Flood and Coastal Erosion Risk Management Strategy will aim to encourage a “Nation of climate champions”.  This will require clear and honest communication with residents across the range of government levels and stakeholders involved.  Community engagement tends to be time consuming and requires active and ongoing communication to provide lasting impact, there are many proven schemes that can form a model for this.

 

5.3.               Advice from the National Flood Forum – The NFF have links and resources that are not available to local authorities.  Support should be offered to the NFF to continue to help those affected by flooding and resource LLFAs to better engage with local communities. This could be done through support and encourage for local Flood Action Groups.

 

5.4.               Target / proportionate consultation - Consult on new policies e.g. Planning, Local Flood Risk Management Strategy is a way of proactively seeking community input. The range of different flood related policies led by different organisations is a challenge in engaging communities effectively. Reducing consultation burdens on Councils would help especially where targeted consultation is more proportionate to the issue at hand. Global Council wide consultations will usually dissipate resources that could be far better targeted to the right communities and stakeholders.

 

  1. With increasing focus on natural flood management measures, how should future agricultural and environmental policies be focussed and integrated with the Government’s wider approach to flood risk?

 

6.1.               There are a range of measures that the Government must support and resource to reduce flood risk and improve resilience that include natural flood management measures, these include:

 

6.2.               A whole system approach - Natural Flood Management should be seen as one of a package of flood defence measures that can be provided in combination with watercourses and catchments viewed as a whole system.  This will require cross boarder river management e.g. on the River Severn measures upstream in Wales to manage flows, as well as investment in physical flood defences within the Borough. This will need to work together to reduce flood risk along the whole river, particularly given the challenge climate change will bring with increased severity of river peaks.  We cannot keep building flood defences higher but similarly, NFM alone is not the answer it is a combination of both.  In Telford for example, this could include a range of measures on top of the exiting balancing lakes and temporary flood defences e.g. upstream flood storage in Shropshire and Wales, NFM, wetland and/or lake creation in the north of the Borough, on-site PFR and a system of permanent flood defences.

 

6.3.               Legislative alignment - Working across such broad regions and will require aligned policies across the whole of the UK (ref. the different enactment of the Flood and Water Management Act between Wales and England) and a framework in which flood risk management can align across borders.  River management also requires clear governance to ensure that flood risk management measures work together and that the appropriate bodies are overseeing the river system as a whole and making decisions based on this.  The English Severn & Wye RFCC goes some way towards this, however this does not encapsulate works taking place in Wales and nor does it oversee the management of water along the river Severn as a whole, but rather the management of flood defence schemes. Water system management is more in line with how Internal Drainage Boards operate e.g. the Strine IDB in Telford, this in some respects is a system reliant on good will on cooperation and needs strengthening.

 

6.4.               Reforming NFM payments - The current countryside stewardship and payment system for NFM is restrictive, heavily bureaucratic and does not encourage uptake.  If flood defence works are taking place on private land then suitable arrangements for their maintenance will be needed.  If landowner engagement is going to be relied on then these schemes will need to be attractive to landowners (i.e. not leave them out of pocket or liable for ongoing costs).  At a catchment scale, measures will also need to be strategically planned and will also require a knowledgeable and skilled central body to manage their ongoing effectiveness.

 

  1. How can housing and other development be made more resilient to flooding, and what role can be played by measures such as insurance, sustainable drainage and planning policy?

 

7.1.               There are a range of measures which should be considered to help make communities, homes and businesses more resilient to flooding, these include better policies and measures in the fields of insurance, sustainable drainage and planning policy. These are summarised below:

 

7.2.               Insurance - Take up of Flood RE for residential households is inconsistent and the scheme needs to be more accessible and allow people to “put back better”.  More resilient housing will have to be the solution in some areas, but if we are designing houses to flood and asking residents to live with this, we need to be clear with communities and ensure that the understand.  Authorities also need to have an ongoing presence to support residents who will flood, regardless of how resilient their homes are.  The mental impacts of flooding also need to be considered.  The needs for a resilient property will vary according to the needs of each individual inhabitants, which can change.  The current PFR market is still developing e.g. Warranties are limited and property resilience is something that is still evolving.

 

7.3.               Planning Policy - New build properties however are not eligible for flood funding because they “shouldn’t” be built where they could flood – this is predicated on the management of flood risk to new development being robust and always being fully effective. Strong planning policies are required to ensure this happens – the starting point of this is the NPPF and NPPG.

 

7.4.               Strategic land use planning - Taking in to consideration growth but also agricultural areas and other strategic land uses such as employment sites, could help make development more resilient. Telford for instance benefits from a designed water management system (oversized sewers, balancing lakes etc.) installed by Telford Development Corporation.  In this instance, the growth of the New Town was designed to be resilient in the future.  As such, wide scale surface water flooding is generally rare. Where new systems are put in place there is a need to ‘over provide’ to meet future, sometimes unforeseen development needs.

 

7.5.               Better quality guidance and information - As well having robust planning policies, designers, civil engineers and architects need to be better informed about ‘good’ sustainable drainage design to be able to provide high quality SuDS as part of an integrated package of blue / green infrastructure serving climate resilient developments.

 

7.6.               Building regulations – consideration should be given to a comprehensive review of building regulations to ensure that all aspects of development in areas at high risk of flooding are considered.