Written evidence submitted by Worcestershire County Council (FLO0029)             


Worcestershire has long history of flooding from all sources and it was significantly impacted during the Autumn of 2019 and the Winter of early 2020. More than 1,000 residential properties, businesses and pieces of critical infrastructure were flooded and severely impacted at a cost of many millions of pounds.

Worcestershire County Council is confident that the investigation into the flood events will describe a generally very good, coordinated and well received response and recovery effort from all the RMAs, other partners and the community.

However, along with all partners, the council is determined that lessons will be learned and improvements made locally. The additional ability to contribute to the review and potential improvement of wider regional and national factors via this consultation is welcomed.  

This response has been produced by Worcestershire County Council’s Flood Risk Manager, Planning Services Manager and Cabinet Member with Responsibility for the Environment. Responses have been kept brief on the basis that we would be extremely happy to engage further and provide more detail if necessary and requested.  

Consultation questions and responses

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


a)      Local governance and co-ordination arrangements work well in Worcestershire

b)      Regional governance and co-ordination via the English Severn & Wye RFCC and the West Mercia LRF works well

c)      Government departments eg Defra, MHCLG and DfT are not always well aligned with each other or apparently with the EA or LLFAs

d)      Government funding needs to be better aligned eg across flood risk, environment, agriculture, planning, transport and economic development


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


a)      Generally, the combined response in Worcestershire was very good

b)      LLFAs shortages of budget and capacity were highlighted but mitigated in the short term

c)      EA resources were clearly overstretched at times eg depth of experienced capacity

d)      Weather forecasts were less reliable than usual

e)      River modelling and forecasting was inconsistent and less accurate than usual. They clearly struggled to fully take into account surface water and ground water conditions

f)       Government recovery grant funding threshold eligibility criteria are illogical, inconsistent and unhelpful. They need to be urgently reviewed

g)      Government recovery grant funding was too slow to be rolled out

h)      Councils should not have been allowed to claim flood recovery grant funding from Government but not distribute it as intended

i)        Government funding for PFR was rolled out too slowly

j)        Farm support grant funding was rolled out too slowly and in an inconsistent manner

k)      There is generally an unhelpful imbalance in the focus on and resource allocated to surface water flooding and main river flooding despite surface water flooding being the most frequent, widespread, impactful and difficult to mitigate, plan for and respond to.

l)        River modelling needs to fully take surface water and ground water into account

m)   Residential and business insurance remains extremely inconsistent and problematic.  Legislation is necessary to maintain consistency with the insurance industry

n)      Timely, clear and aligned Government funding support for infrastructure recovery, to match that for EA flood defences, would have been extremely helpful eg for surface water, ordinary watercourse and highway drainage investigation and repair

o)      The National Flood Forum provides a unique and ideal independent conduit between RMAs and communities. However, increased NFF capacity is required



  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? 



a)      Greater and more fundamental community engagement and resilience is needed. This will require increased NFF and LLFA revenue capacity

b)      Greater balance of emphasis on residential, business and infrastructure flood risk in FRM funding

c)      Increased and more integrated deployment of NFM approaches, alongside the range of other approaches. Increased revenue and / or re-aligned existing capital funding

d)      Increased and more flexible capital funding for schemes via the RFCC

e)      More accessible RFCC funding bid / scheme development process

f)       Increased LLFA revenue resource for capacity and activity via ringfenced Government funding for FWMA (2010) implementation

g)      Planning policy review and development

h)      Increased LPA capacity and emphasis on planning condition discharge monitoring and enforcement

i)        More structured and robust SuDS scrutiny, adoption and maintenance. Adoption by Water Authorities and commencement of revised FWMA schedule 3

j)        Review and development of PFR and community resilience behind flood defences

k)      Review and redress the current imbalance of resources allocated to the management of surface water v/s main rivers

l)        Planning policy guidance is ineffective.   Mandatory planning policies are required to enable the local authorities to maintain an adequate infrastructure for all new developments

m)   Flood risk management should, whenever possible, also take into account and help mitigate drought 


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


a)      Greater emphasis and resource allocated to the support for creation and maintenance of local community Flood Action Groups via the National Flood Forum and with multi-agency engagement

b)      Increased emphasis placed on individual and community ownership of flood risk issues, responsibilities and solutions

c)      Local knowledge should be routinely included when looking at any flood mitigation issues, including that from local flood groups and parish councils

d)      Increased revenue invested into LLFAs to help facilitate this

e)      Resource made available (new or re-aligned) to the NFF whilst maintaining its critical independence


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


a)      Review and re-alignment of agriculture and land management financial support / incentives to include appropriate NFM and other FRM measures and disincentive for works which would have a negative impact on watercourses and flood risk

b)      Greater catchment / cross-border approach across organisations and national / regional policy


  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? 


a)      Increased SuDS awareness, integration into design policy and practice and more robust construction monitoring, adoption and maintenance including orphaned SuDS - commencement of revised FWMA schedule 3

b)      Planning policy review / development

c)      Increased emphasis on monitoring and enforcement of discharge of planning conditions

d)      Proposals for housing/ development outside Flood Zone 1 only permitted in exceptional circumstances and this should be applied strictly analogous to green belt policy

e)      Review and development of building regulations

f)       Investment in LLFA and LPA capacity

g)      Review / removal of the automatic right to connect to the sewer system

h)      Planning Inspectorate will need to justify adequate infrastructure is in place

when determining any new development

i)        No negative impact on existing housing stock from the supply or discharge of water from any new proposed development



May 2020