Written evidence submitted by the Greater Manchester Combined Authority (FLO0062)

Background

The Greater Manchester Combined Authority is made up of the ten Greater Manchester councils (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan) and is jointly run by their leaders and the Mayor of Greater Manchester, Andy Burnham.

Greater Manchester Combined Authority recognises the importance of its infrastructure and the multiple parties which are involved in its management and delivery.  The UK Government established the National Infrastructure Commission in 2015 and the importance of strategic infrastructure was reinforced through the National Industrial Strategy in June 2018.  Greater Manchester strongly supports the recommendation of the first National Infrastructure Assessment (July 2018) that an integrated strategy for infrastructure needs to be backed up with stable, substantial devolved funding. We have produced our own Local Industrial Strategy and Strategic Infrastructure Framework in line with the National Infrastructure Commission recommendation.

Our Local Industrial Strategy includes the first city-region clean growth mission which sets out how Greater Manchester is aiming to be carbon neutral by 2038, twelve years ahead of national ambition in order to meet fair contributions to national/international obligations on climate change. Action is being progressed through the 5 Year Environment Plan[1] and adaptation/mitigation to future climate change is a key consideration, specifically it highlights the need to increase the resilience of critical infrastructure and to have a clear strategy in place for flood risk investment. The ability for economic areas to recover after flooding and increased resilience across the city region will ensure any risks to productivity of the city-region are minimised.

Key trends impacting on Greater Manchester’s infrastructure up to 2040 have been identified and have informed the development of a series of key challenges which sit within the Greater Manchester Infrastructure Framework[2].   Flood and water management has been identified as a key challenge area that can support delivery of a more integrated and sustainable approach through green and blue infrastructure in making the city-region more resilient.  The flood and water theme is cross cutting of many elements of the Greater Manchester Strategy[3] vision, which aligns with many themes within GM.  For example the Greater Manchester Spatial Framework[4] sets out how Greater Manchester should develop up until 2037 supporting the delivery of key infrastructure whilst protecting the important environmental assets.  Greater Manchester is committed to meeting its Local Housing Need (as established by the Government’s standard methodology) as required by the National Planning Policy Framework.

Greater Manchester Combined Authority has  made changes to its water governance in line with the formation of the Greater Manchester Infrastructure Framework to improve communications across partners.  However this alone is not enough to ensure delivery of a more integrated and sustainable approach through green and blue infrastructure in making the city-region more resilient.  The following response from Greater Manchester Combined Authority to this ‘Call for Evidence’ is to highlight the key challenges that may impact on its ability to deliver a more integrated and sustainable approach in managing flood and water management in the future.

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

The current national governance and co-ordination arrangements are on the whole adequate, however the relevant organisations need to be adequately resourced in order for these arrangements to be fully effective.  It is the case that a number of duties and powers set out in the 2010 Act[5] are not being widely used due to lack of resources to deliver them.  For example there are legal implications of designating assets which could result in lengthy and costly disputes with third parties.

The last decade of austerity has impacted on nearly all services within our already overstretched Local Authorities.  They have experienced unprecedented cuts since 2010 and have seen central government funding cut by almost 50% in real terms.  Research found that when looking at the cuts in town hall spend, the average cost of austerity in Britain is the equivalent of £287 per person. But that figure is higher in six of Greater Manchester's local authorities[6].

The enactment of the Flood and Water Management Act, 2010 gave additional responsibilities to manage local flood risk to all Greater Manchester Local Authorities as Lead Local Flood Authorities.  Revenue funding provided to support discharging of Local Authority duties under the Act is not ring fenced and competes with other Local Authority priorities.  The Local Government Financial Settlement (GFS) provides £7,000 to £24,000 per district across Greater Manchester.  For some districts this does not fully fund 1 (Full Time Equivalent) post and would not even cover the time spent on planning applications.  

The only service area to see an increase in spending within Local Authority over this last decade is social care[7], all other services including highways and transport and planning and development have seen significant cuts in expenditure and are functions that are intrinsically linked to spatial planning and delivery of flood and water management programmes. 

Local Authorities are managing competing priorities and it is often difficult to plug in to decision makers.  Since the 2010 Act was introduced, there has been an increase in Mayoral combined authority areas including the Greater Manchester Combined Authority and with this some devolution of powers and funding.  There are 10 unitary Authorities in Greater Manchester and further devolution would help facilitate funding to deliver flood and water management locally.  Greater control over sub regional funding would enable stronger alignment and blending of  existing funding mechanisms in Greater Manchester so that this could also be invested in the wider benefits of blue and green infrastructure, ultimately leading to a more integrated and sustainable approach in making the city-region more resilient. 

It is difficult to plan long term with a year on year funding approach for Local Authorities when trying to align with other longer term programmes that other organisations work to such as the Environment Agency and United Utilities.  Local Authorities receive no additional funding to manage and maintain their assets and funding for capital works are competing with other Local Authority delivery functions. It is also worth noting that the formula for calculating Local Authority levels of funding does not include deprivation levels.

The Environment Agency has a more focused remit, however none of the plans and strategies produced more recently provide the same level of overview and direction for the management of ‘main river’ flooding as the Catchment Flood Management Plans published more than 10 years ago. We would welcome an update to these as part of the Environment Agency’s strategic overview for flood risk. Looking across catchment areas which include more than one Local Planning Authority, such plans would help support cross boundary working and duty to co-operate issues, particularly when looking at maximising storage in upland areas.

The North West Regional Flood and Coastal Committee approach is now stronger, supported by a new Business Plan more inclusive of surface water risk management.  Welcome changes have also been made to the Grant in Aid Partnership Funding metrics to improve possible funding opportunities to Local Authority led schemes but the new formula has yet to be tested.  It has previously been difficult to fund smaller surface water schemes and it is important that these changes are sufficient to ensure delivery of surface water projects otherwise the risk will continue to increase with the impacts of climate change.

Manchester Ship Canal is hugely significant in hydrological terms for Greater Manchester and Salford in particular but historic Manchester Ship Canal Company legislation does not reference flood risk management function. This needs to be rectified as soon as possible so they are legally obliged to consider flood risk. The canal is not currently classed as a main river which is an omission, given the sub regional significance of the watercourse. It is currently treated as an ordinary watercourse by the seven Lead Local Flood Authorities through which it flows. A stronger approach is required to consider flood risk management from the canal involving all Lead Local Flood Authorities, Environment Agency, Manchester Ship Canal Company and United Utilities as the current approach is not achieving desired outcomes. There may be other similar watercourses in other parts of the country.[8]

The Greater Manchester Spatial Framework is strengthening spatial planning policy in respect to flood risk management but further legislation is required to ensure Local Planning Authorities and Lead Local Flood Authorities have the appropriate powers to ensure sustainable practices are integral to every planning application especially in respect to Sustainable Drainage Systems (SuDS).

Greater Manchester has significant viability challenges across much of its area. This is linked to a multiplicity of factors including contamination issues linked to industrial uses in the past, infrastructure requirements and lower values. We are undertaking a strategic viability assessment as part of the Greater Manchester Spatial Framework, using the methodology in national planning practice guidance. This has identified a significant proportion of our land supply which will require some intervention to bring forward. The viability issues have made it difficult to access Government funding programmes as evidenced by the recent decisions around the Housing Infrastructure Forward Fund[9]. In this context, it is difficult to successfully negotiate the funding of SuDS and other flood mitigation schemes through the planning application process. In addition there is little appetite for Local Authorities to adopt SuDS due to increased pressure on resource and budgets.

Lead Local Flood Authorities when consulting on planning applications see their feedback, requests for Flood Risk Assessments and additional flood and drainage data constantly challenged by developers.  Sites being deemed non-viable due to SuDS are difficult to manage.  The decision not to create and implement SuDS Approval Boards impacted on the control Lead Local Flood Authorities should have in respect to flood risk management and how the developers design and manage the site.

Issues with the built environment come to the fore long after the developer has walked away and Local Authorities have to pick up the pieces. Impermeable surfaces are increasing and whilst legislation is in place the resource to manage and enforce is not.  Consideration needs to be given at a national level as to how the problem of gardens/green space being made into hard impermeable surfaces can be resolved.  Education on the benefits of keeping permeable spaces can be improved and increase in penalties may be a deterrent but without the resource to identify offenders and enforce the legislation they are ineffective.

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

The Property Level Resilience grant scheme[10] is unchanged following the 2015 Boxing Day flooding when several Local Authorities operated a scheme.  There is little guidance on what makes a good scheme and similarly little guidance on good practice in flood resilience to ensure that funding is not spent on unsuitable products by suppliers who subsequently cease trading.  Property resilience schemes have had problems from survey, installation and if fully funded from specification of survey long term maintenance is at the discretion of the property owner.  More guidance is needed and that formalised standards relating to flood resilience are drawn up.

Reflecting on 2015 Boxing Day flood event the total available resource of all responders can be quickly over-stretched in a flooding incident which covers a large geographic area and many locations. This is particularly stark in a large urban area highlighting the need for resilience and emergency planning to be adequately resourced.

Following more recent flood events it is evident that there still need to be improvements around the lines of communication between risk management authorities.  This is especially important where flood events have occurred across district/county boundaries as there iareoften different governance arrangements and it not always clear who the points of contact should be especially during a flood event.   Local Authorities have limited staff on duty 24 hours a day to respond to local flood incidents, other risk management authorities have more robust mechanisms in place to respond.  

There are several organisation involved in management of and response to flooding, further education is still required across communities including businesses to explain the roles and responsibilities of risk management authorities.  Likewise communities, businesses and riparian owners need to be made aware of their responsibilities.  Having different responders is difficult for communities impacted by flooding but is equally difficult for Local Authorities, Environment Agency, United Utilities and 3rd sector partners to manage public expectations.  For example sandbags are often requested by communities prior to flooding and the response can be different across Local Authorities and partners.  To provide ongoing tailored community engagement is resource intensive and capacity to deliver this is not readily available across Local Authorities.

An accurate evidence base is of high importance to identify risk and priorities and to fully understand where investment is required.  A clearer line of sight from Local Authority to Government for post event reporting would reduce duplication and clearer guidance would ensure consistent evidence/data collection.  Collecting and collating flood event data across multiple Local Authorities and other partners remains difficult, it is often an ad hoc approach and inconsistent in its detail.   Greater Manchester is working towards a more consistent approach through a project that is reviewing data collection processes and metrics internally and across other risk management authorities.  However, national funding could take this to the next level and support the creation and maintenance of a central partnership hub/data platform which all Risk Management Authorities could use and report against. This could be replicated in other partnerships across the county and link to a national hub and would provide a consistent approach and help break down barriers when sharing data.  Currently we do not have funding identified to develop the platform itself but are keen to take this forward as a pilot.

Within a report published following the National Infrastructure Assessment, 20189 it states that ‘a lack of reliable data has meant that it has not been possible to consider surface or waste water in detail for this Assessment. Surface water flooding is significant and there has been little progress in the decade since the Pitt review. Further work is needed urgently.’

Existing evidence has a strong focus on rivers and sea and there are limitations to existing surface water mapping which the Environment Agency states ‘it is unlikely to be reliable for a local area and very unlikely to be reliable for identifying individual properties at risk’.  Surface water risk is complex including water from run off of higher ground, drainage capacity, blockages etc. Updated modelling/mapping work needs to be procured to reflect this complexity and include recent flood event data.  The level of resource required to undertake this mapping work needs to be acknowledged as most Local Authorities do not have the capacity to deliver this ‘in house’. Across Greater Manchester the numbers of properties at risk from surface water flooding is double the numbers at risk from fluvial flooding but the level of investment given to surface water, groundwater and ordinary watercourse flood risk is not reflective of the scale of the problem. Adding to this is the consistency of reporting and sharing of data as noted above.

3.  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? 

The first National Infrastructure Assessment was launched on 10 July 2018[11] and acknowledges that the current approach is too piecemeal and reactive and there should be a long term national programme.  In the past, government budgets for flood risk management have been reduced, only to be increased again after floods events which does not make for planning of long term sustainable solutions.  The Commission recommends that government should set out a strategy to deliver a nationwide standard of resilience to flooding with an annual likelihood of 0.5 per cent by 2050 where this is feasible. A higher standard of 0.1 per cent should be provided for densely populated areas where the costs per household are lower.

The report goes on to say that ‘despite the many challenges, cities across the country have shown that when they are given the funding and freedom they are capable of designing and delivering infrastructure programmes that change the shape of the city for the better.’  This further supports the reference made in question 1, that further devolution and greater control over sub regional funding would enable stronger alignment with existing funding mechanisms in Greater Manchester, helping to invest in the wider benefits of blue and green infrastructure that supports delivery of a more integrated and sustainable approach in making the city-region more resilient to climate change. 

The ‘Draft National Flood and Coastal Erosion Risk Management Strategy for England Vision’[12] was put out for consultation in 2019 and states ‘The cost of becoming resilient to flooding and coastal change can be spread between government, business and people by promoting sustainable investment in infrastructure, housing and the environment.’ There is a strong message from both this strategy and the National Infrastructure Assessment that flood risk cannot be managed in silo and must be considered through the infrastructure lens as identified in some of the key challenges which sit within the Greater Manchester Infrastructure Framework. 

It is difficult to provide a monetary figure in respect to what future investment should look like but to provide some context, in the current 6 year programme Greater Manchester secured £51m Grant in Aid funding and £3.2m Local Levy contributions that is forecast to deliver 4,729 homes better protected by the end of 2021. 

Of the £51m Grant in Aid funding only £4m is for the delivery of Local Authority led projects which are predominately to reduce surface water risk.  The current scale of flood risk for Greater Manchester is far greater for surface water and has not previously been the focus of investment.  There continues to be barriers to attracting private investment on smaller less economically viable schemes relating to surface water.

The National Infrastructure Commission recommend that a nationwide standard of resilience, to flooding with an annual likelihood of 0.1% should be delivered in densely populated areas. In Greater Manchester ~163,000 properties are at risk of surface water flooding with an annual likelihood of 0.1% with a further ~63,000 properties at risk from river flooding.  This current investment programme will deliver benefits to less than 5,000 properties to deliver the resilient vision by 2050 would take serious upscaling of investment to achieve this outcome. 

Since the Boxing Day flooding[13], 2015 three of the hardest hit areas Salford, Rochdale and Bury have had approved capital schemes through the Grant in Aid process.  Whilst funding is currently provided for one off capital schemes, in the case of Salford’s second flood basin the design was predicated on further works being necessary in the future to address impact of climate change and maintain the same level of protection. However those future works are not currently funded and it is not clear how they would be given increasing pressures on funding nationally.   For this reason the planning framework for development and flood risk needs to be reviewed in the context of the latest climate change scenarios. 

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

Local Authority flood forums have been effective in bringing together many organisations and communities involved in responding to and managing flood risk, for example Salford Strategic Flood Forum has been very effective in bring together all parties concerned with flood risk management in the city. It is benefitting greatly from the input of community representatives enabling them to be linked into statutory agencies and processes. Including Emergency Planning and resilience, clearly communities are on the front line in any flooding incidents affecting their areas and links are vital.

One of the lessons learnt from the 2015 Boxing Day flood event was the importance of working with communities to help them become more resilient.  Community engagement as one of the more difficult ‘other responses’ that is underfunded due to the difficulty in identifying the direct financial benefits. 

Flooding is known to have longer term effects on mental health[14], mainly due to the damage and protracted disruption caused to homes and livelihoods. The report following the 2015 Boxing Day flooding stated that the psychological impacts, whilst not fully known at the time of publication, the stress caused to those affected had been clear.  Many people affected were highly vulnerable due to health, age and income.  5 of the 10 Greater Manchester Local Authorities sit within the top 32 most deprived areas in the country7 including Salford and Rochdale which were 2 of the 3 areas most affected during the Boxing Day flood event.  

Involving communities should be about empowering communities and they need to be adequately supported to be involved. It should not become an excuse to ask communities to shoulder unreasonable burdens themselves to fill the gap left by underfunding of agencies.

Engagement often is limited to post flood event where this is beneficial not just to the community but provides an opportunity to capture flood data required to build cases for future schemes.  Rochdale and Salford have continued to work with their communities and action groups outside of events but this is resource intensive.  Salford encourages attendance from community representatives at their Flood Forum and Rochdale has continued to build on a Defra pathfinder[15] initiative with support from the National Flood Forum. 

The Rochdale Defra Pathfinder pilot was a partnership project between Rochdale Council and the National Flood Forum which identified the need to create a community engagement officer post that would be an effective ‘honest broker’ in the community working with flood affected, hard to reach and often significantly socially and economically disadvantaged communities and small businesses to help build sustainable resilience.  Supporting them in forming and maintaining their Flood Action Groups and ensuring they are actively engaged in future flood risk management proposals that will benefit their communities. 

The post is also helping to manage and deliver innovative new approaches including a natural flood management programme and associated landowner and community engagement. Stronger community relationships, trust and openness and local knowledge have been established which is helping to more effectively deliver the third strand of the work programme which is to help ensure positive engagement with the development and delivery of the Littleborough to Rochdale flood alleviation scheme[16]. The post is continuing to contribute to a valuable body of transferable good practice and innovation for Greater Manchester.

The benefits of investing in community engagement are evident if measured through the lens of health and wellbeing, this is especially true in some of the harder to reach areas of Greater Manchester, for example Gorton go green project[17] and tree planting with City of Trees in Smithills[18].  A wider network of community officers working directly within the communities is needed building on the Salford and Rochdale models and could also support the dissemination of other key climate change messages.  There are limited avenues for this funding and this remains a barrier in expanding this type of resilience work.

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

More often than not the ‘greener/softer’ aspects of development and infrastructure projects are often design costed out given the perception of the economic benefits associated with them. Recently we have seen a movement in line with DEFRA’s 25 Year Environment Plan about the importance of a natural capital approach and Greater Manchester has produced a set of Natural Capital Accounts[19] which demonstrates that the natural environment provides £1bn in ecosystems services every year. This clearly demonstrates that there are economic benefits from the natural environment and this should be strengthened as part of any procurement approach or in relation to government funding bids. In this context, other government departments should be encouraged to consider how their own departmental spend could be tailored to deliver wider outcomes in relation to flood risk management and/or delivery of a natural capital approach.

The vision within the Greater Manchester Environment Plan[20] is for Greater Manchester to be a clean, climate resilient and a carbon neutral city region by 2038 with a thriving natural environment and circular, zero-waste economy.  The plan recognises the benefits of environment on health and wellbeing promoting walking, cycling and a ‘Street for All’ approach for street design and management with a target to plant 1m trees by 2024. 

Greater Manchester has launched its own walking and cycling strategy to outline the approach to help increase activity levels and improve air quality (from reduced reliance on transport). There is an opportunity through the renewed commitment from government for increased investment[21] in cycling to couple this with investment in sustainable drainage systems/natural flood management to create wider outcomes for place making and the environment. E.g any allocation of funding could also mandate the inclusion of sustainable drainage for any bids submitted or give greater weighting to those that do. =

Greater Manchester has a history of joint working across number of partners including the Environment Agency, Natural England, United Utilities and Rivers Trust, collaborating on a number of key projects such as Urban Pioneer[22], Natural Course[23] and IGNITION[24], building a platform for future opportunities and collaboration 

However it remains difficult to justify more innovative, integrated and sustainable solutions to flood and water management.  The benefits of environmental and other measures that have flood benefits whilst acknowledged are often not brought into the normal boundaries of considered solutions.  Managing cross (district, county and catchment) boundary solutions dealing with procurement and funding issues is a barrier to many projects happening. Natural flood management solutions are difficult to evidence the tangible benefits from a catchment approach directly to communities at risk.  Grant in Aid funding is focused around existing flood risk to homes which often discounts some of the more innovative solutions that can deliver multiple benefits and a more integrated catchment approach, environmental measures that have flood benefits need to be brought into the normal boundaries of considered solutions. To deliver through a more catchment approach relies on stronger partnership funding to unlock potential opportunities to create a climate resilient city-region. 

Flood risk measures are quantified by attributing a proportion of the economic damage avoided by the successful operation of flood defences.  Whilst the benefits of flood defences and related responses are well understood and readily quantifiable through established approaches, those of other responses e.g. natural flood management, spatial planning and development management, community engagement and awareness raising are more difficult to assess and quantify. This could lead to an over-emphasis on expensive structural solutions and underinvestment in other responses that may be more cost-effective.

Habitat, carbon banking and green infrastructure finance models are identified as part of the Greater Manchester Natural Capital Investment Plan[25] and are being taken forward through the development of a Greater Manchester Environment Fund[26].  There will be clear opportunities to deliver funding opportunities for natural flood management measures as part of these proposals.  We will still need to consider how best to stack multiple benefits to maximise the potential investment opportunities for beneficiaries and funders.

Agricultural and environment policies should be integrated with the Government’s wider approach to flood risk. The use of Environmental Land Management Schemes[27] and habitat banking to deliver wider natural flood management benefits will be a key consideration within this where there are opportunities to maximise natural flood management.   

Defra has said the Environmental Land Management Schemes system will be the cornerstone of agricultural policy in England from the end of an agricultural transition (likely to be 2022) and pilot schemes are likely to be commissioned from 2020. Improved land management is equally important and this transition period creates an opportunity to influence how Environmental Land Management Schemes can support this. 

Rochdale Local Authority are undertaking a natural flood management program of pioneering works and have identified that more consideration needs to be given to ownership and liability of that work.  Landowners are becoming more risk averse due to an increase of flooding incidents and near misses from surface water run off coming from the hills and people are looking to apportion blame.  Anecdotal evidence only to support the issue at this point but by March 2021 a report around challenges with engagement and landowner buy in and securing attenuation will be published from this program of works. 

Landowners need to be incentivised through Environmental Land Management Schemes as current natural flood management schemes do not consider whole life costs to include maintenance and are currently reliant on goodwill and persuasion to get landowners involved.  Grant funding can deliver capital work only, whilst the maintenance may be low the measures installed still require inspection and work e.g. damage during events, vandalism. 

We also do not yet know the durability of these measures over time in the uplands.  If short term measures and if they start to deteriorate there are similar issues to Property Level Protection. Can Environmental Land Management Schemes create that lifetime contribution over 15 – 50 year life span?

The Environmental Land Management Schemes policy needs designing in such a way that not only incentivises the inclusion of natural flood management measures but can be used alongside other funding sources (e.g. Biodiversity Net Gain if it involved habitat creation, carbon offsetting if it involved peatland restoration). How these policies come together to pay for the potential multiple benefits delivered by many natural flood management schemes is key.

6. 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? 

Climate change needs to be considered stronger as part of building regulation/control and more encompassing of all possible shocks and stresses. We need to lobby and influence changes to building regulation and legislation in new build properties and there are opportunities to do this with the emerging new regulatory framework as described in the Independent Review of Building Regulations and Fire Safety Report[28].  Whilst the driver of the report is building safety, recommendations for the new framework suggests this will provide opportunities for scope of innovation in building practices.  A whole house/building approach to resilience, incorporated at the time of building would ultimately present economies of scale.  There should be flood and energy measures incorporated into all new build developments as standard practice, whilst not all new sites are classed as at risk of flooding but this can change with the impacts of climate change.  This as a more sustainable approach would future proof developments against future shocks and stresses.

Greater Manchester’s 5 Year Environment Plan[29] has identified the need to retrofit 61,000 homes every year if we are to meet our 2038 carbon neutrality commitment. At present deep retrofit projects are in the scale of the 100s rather than 1000s each year. Where developments are already in place retrofit of flood and energy measures should be considered as part of wider whole property approach which lends itself to blended finance projects from cross departmental budgets or for capturing wider outcomes where costs benefits of schemes are negligible (as in the case of Defra GIA funding).

The Government previously committed to introducing “zero-carbon” new homes from 2016, an ambition that was abandoned in 2015 despite being widely support by industry and the third sector[30]. The Government is not opposed in principle to the idea of 2050-ready homes but it is concerned about cost. In its Housing White Paper, the Department for Communities and Local Government states, “We will consult on improving requirements on new homes this Parliament if evidence suggests there are opportunities to do so without making homes less affordable for those who want to buy their own home. “

Given the difficulty of saving carbon in other sectors it has been suggested we are likely to need to come close to a complete decarbonisation of our building stock by 2050.  Whilst this debate continues it provides an opportunity to gather evidence to lobby for change not just for the inclusion of carbon reduction energy measures but to further consider the inclusion of flood measures into new build properties.  Again this is an example of silo thinking that can be influenced to change to drive a whole house approach remit.

As well as considering a whole house approach as best practice a whole place approach is equally part of the wider picture.  Further work is being rolled out to deliver Biodiversity Net Gain and Nature Recovery Networks but it is not flood risk management driven.  However if there is evidence to suggest that the introduction of SuDS or similar nature based measures do add value, there are opportunities to create stronger links to planning policy.  Multiple benefits must be maximised and supported through policy and legislation as a whole place approach to stop inappropriate building and deliver on housing and growth in a more sustainable way. There is an existing evidence base formed through the Urban Pioneer and Natural Course projects including Ecosystem Services Opportunity Mapping[31] and as noted earlier Natural Capital Accounts, which have been developed to inform policy and decision making

The National Infrastructure Commission identified that there is a lack of incentive for utility companies to develop increased capacity in advance of development, putting these costs on house builders. This can create coordination failures where upgrades are large and exceed the needs of any individual development[32].   Therefore it is of high importance that case studies are used to inform best practice, for example United Utilities are testing the LENS approach (Linking Economy and Landscapes) in Bolton which will also have implications for flooding, development and sustainable drainage. Nestlé are paying farmers to manage their land differently through a sustainability bonus[33], which is paid when farmers undertake actions to support greater sustainability. The sustainability bonus was set up in January 2017 and focuses on actions that will support habitat protection. As the programme develops it will look at actions that support improvement in soil and water health.

There is a potential role that building regulations could play in terms of SuDS (compliance and minimum standards). SuDS references to planning are inferred they are not prescriptive and the work around embedding SuDS as standard within developments needs stronger legislation to enable the Lead Local Flood Authorities to be able to ensure that the best possible schemes are installed as standard.  SuDS is instrumental not only in new development but as a retrofit for existing urban areas.  Without the support legislation can provide guidance remains just that as experience has shown that whilst SuDS are a priority in the planning system, the reality is that very few schemes come forward.

Following the Pitt Review and the drafting of Schedule 3 of the Flood and Water Management Act guidance and rules regarding the use of Sustainable Drainage in developments is not as effective as it could be.  There are too many ways for developers to not uses SuDS and instead construct traditional drainage systems.  There is also danger in relying on emergency planning measures to allow developments to proceed in flood risk areas. The planning system cannot guarantee that appropriate emergency planning response will be in place if required. These issues needs to be addressed and planning policy stricter.

Planning Policy and guidance has become more flexible since the loss of PPS25[34] and its Companion Guide. Additionally, a loss of resources at the Environment Agency has reduced the number of planning consultations they are able to respond to. It is therefore harder for the Local Planning Authority to ensure that development is made resilient to flooding as there is not adequate support from national guidance or agencies. National guidance and policy should be clearer to assist the Local Planning Authority in discussions with developers.

Lack of insurance take up, whilst we know is a problem the scale and reasons for it are currently not fully quantified.  Flood Re has been introduced but what impact this has had on making this affordable for everyone is still not clear.  Rochdale Borough Council working with the National Flood Forum and other partners participated in a previous Pathfinder programme and established what could be termed ‘flood poverty’.  Building on this there is now scope for further work that seeks to deliver a step change in flood resilient behaviour and outcomes with a strong emphasis on addressing ‘flood poverty’ with a possible project delivery partnership including Greater Manchester Combined Authority, Rochdale Borough Council, Salford Borough Council, United Utilities, University of Manchester, National Flood Forum and Flood Re.

As part of the proposal it will look at how communities and businesses can be encouraged to take up of appropriate levels of insurance through better knowledge and appropriate support programmes, identifying approaches to incentivise and support a sustainable market through insurance and physical investment programmes in property, infrastructure and land management as appropriate.  A summary of the proposal is included in appendix A and for any further details contact francis.comyn@rochdale.gov.uk.

Under and non-insured homes and businesses and access to affordable policies that covers flooding is a huge problem even with the introduction of Flood Re.  We need to define market failure and how we can incentivise in some meaningful way. Evidence is mostly anecdotal but following Storm Eva Rochdale Local Authority gathered information on insurance as part of the grant scheme.   A survey was carried out in flood affected areas and 375 residential properties and businesses responded.  The results showed that 68% had building insurance, 41% had contents cover and of this group only 27% applied for the flood resilience grant.  This is a baseline snap shot of the scale of the problem at a very local level. 

Property resilience retrofit has many problems from survey, installation and ongoing maintenance.  Often outside of a grant scheme there is little interest in the flood product market, this being one of the reasons businesses fail leaving no ‘product guarantee’.  If people don’t maintain or replace effectively this reduces over time until they are uninsurable, no longer meeting current specification.  Home owners and businesses then can’t afford the measure if not grant funded and can’t evidence to insurer for them to take the risk on.

There are currently no useable standards that address flood resilience in the construction of new housing schemes and additional guidance is needed.  Insurers of properties that flood should be made to consider cost effective resilience improvements rather than simple like-for-like replacements.

Appendix A

‘Flood poverty’ brief summary - GMCA Draft Proposal: Boosting action to make homes and buildings more resilient to floods.

Possible project delivery partnership – Greater Manchester Combined Authority, Rochdale Borough Council, Salford Borough Council, United Utilities, University of Manchester, National Flood Forum (NFF), Flood Re. 

Summary

Greater Manchester and its 10 districts have experienced substantial flooding since Storm Eva in December 2015. Rochdale BC working with the National Flood Forum and other partners participated in the previous Pathfinder programme and established what could be termed ‘flood poverty’. The term seeks to convey the challenge of affordable and achievable flood resilience for communities where the correlation between multiple deprivation, struggling SME business activities and significant flood risk is high.

There are many issues affecting ‘flood poverty’ and the ability to address it which include:

• Harder to reach individuals and wider communities due to cultural characteristics and high turnover of residents
• A lower level of adequate insurance cover due to affordability, access to providers, access to insurance information and ‘denial’ of risk or actual flood affects they have experienced, equating to a form of market failure
• Lower and often poor standards of wider property maintenance
• Affordability outside of a formal grant scheme to incentivise PLP
• Experience of the durability of ‘protection’ products and the long term affordability of keeping resilient
• A continued perception that flood resilience is not the householder/businesses responsibility but that there will always be financial help elsewhere e.g. grants.

These issues and others create market challenges in terms of securing greater proactive measures to improve flood resilience at the individual property and neighbourhood scale as the market only fully functions after a significant flood event and where funding for measures has been made available.

The GMCA proposal seeks to deliver a step change in flood resilient behaviour and outcomes with a strong emphasis on addressing ‘flood poverty’ and supporting more sustainable but independent resilient behaviour where homeowners, tenants, landlords, businesses and neighbourhoods take greater ownership of their risk and how it is managed.

This will involve:

• Take and review the learning from the Rochdale Pathfinder (and others) in the first programme along with experience of flood events since their completion regarding impacts, take up of PLP, performance of PLP products, insurance claims and coverage etc.
• Develop a task group with LLFAs, Flood Re:, Insurers, NFF, Social Housing Providers, EA, utilities providers and others to scope and review the blockers to effective flood resilience that takes full account of the challenges of ‘flood poverty’ and identifies approaches to incentivise and support a sustainable market through insurance and physical investment programmes in property, infrastructure and land management as appropriate.
• Encourage and secure better take up of appropriate levels of insurance through better knowledge and appropriate support programmes
• Establish an action plan and core pilot projects to test and review/disseminate ways to inspire, support and embed flood resilient behaviour and personal responsibility in key ‘at risk’ communities and within housing investment programmes for new build and refurbishment/improvement which create ‘whole house resilience’ around flood resilience and energy conservation.
• Test opportunities to embed natural flood management measures at the property and community scale as part of a natural capital approach to flood and water management
• Pilot and experimental activities will be established through exemplar activities around property maintenance, retrofit of measures, environmental actions etc
• Develop a GM code of practice for flood resilience property surveys based on best practice and nationally developed guidance e.g. CIRIA.
• Create a virtual technical hub through creating sectoral partnerships, enhancing skills sets within key local authority and housing sector disciplines (including the construction sector) so as to build capacity and embed best practice behaviour across disciplines rather than LLFAs alone. Identify ways of bringing new capacity and skills through for example via apprenticeships.
• Identify a sustainable management model for the hub through the GMCA which also helps support wider capacity building/good practice dissemination in the North West, working with the EA and RFCC.

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