150128 NFF Manifesto (2)

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National Flood Forum
Old Snuff Mill Warehouse
Park Lane, Bewdley
Worcestershire DY12 2EL
Tel 01299 403055
www.floodforum.org.uk
National Flood Forum Manifesto
It is clear from the recent survey of flood risk communities undertaken by the
National Flood Forum, that people feel that a huge amount of work is necessary if we
are to be successful in managing and reducing our flood risk. To achieve this will
require much more coordinated action from all parts of society, including government
and its agencies in all their guises, Flood Risk Management Authorities, business,
the insurance industry, as well as communities and individuals.
Respondents identified three areas to focus on:
1. Flooding is a national priority: for Government and everyone. Without action
many more people will flood
2. Putting communities first: A step change to put the needs of people at the
centre of flood risk management
3. Do what we are already doing better: Review and improve.
Within these, there was a huge range of suggestions about what needs to be done to
manage flood risk, to help people during a flood and to keep people safe.
1. Flooding is a national priority: for Government and everyone. Without
action many more people will flood
The Committee of Climate Change projects that flooding will get much worse and
people regularly tell us that that flooding impacts are far greater than they used to
be. There is a real risk that when Flood Re ends and people have to access
insurance on the open market, many people will not be able to access protection. All
parts of government and society need to rise to the challenge that this presents:

There should be a clear Government ambition to reduce the residual number
of households at risk of flooding through a clear, long term, cross-government
approach, taking account of projected increases in flood risk.

Each department should take this forward with their agencies can contribute
to this programme. Examples of actions include:

Some fire and rescue services already work with communities to
reduce flood risk. We need to promote good practice;
1
The National Flood Forum • Registered Charity No. 1121642
• A Company Limited By Guarantee • Registered in England & Wales No. 4349401
Registered Office: Old Snuff Mill Warehouse, Park Lane, Bewdley, Worcs DY12 2EL • VAT Registered No: 786 2681 83
National Flood Forum
Old Snuff Mill Warehouse
Park Lane, Bewdley
Worcestershire DY12 2EL
Tel 01299 403055
www.floodforum.org.uk

Ensure that public health services are able to deal with the impacts of
flooding. During last winter’s floods many people presented to our
recovery service with a range of illnesses, but did not go to their GP.

Require private landlords to have adequate insurance that includes
flood risk cover. This would provide the minimum safety net for tenants

Review the standards for drainage, sewerage and highway drains. Are
they current for our current weather patterns and infrastructure loads?
Are they adequate for projected scenarios in 20 and 50 years’ time?

Incident plans for organisations in areas of significant flood risk – they
are far more likely to flood than suffer a fire, and we know that being
prepared leads to better outcomes.

The funding profile for each FRM Authority over the next parliament should be
defined, to give certainty and encourage plan development.

Flood Re, the household flood risk insurance measure, will help to address
insurance availability and affordability. It also offers a great opportunity and a
challenge to get flood risk management right by the time a free market is
introduced. A cross-sector project board should maximise the opportunities to
reduce flood risk and smooth the claims profile for insurers

Review of the extent to which competition really occurs in household
insurance.

Delivery of the Pitt Review recommendations, in full.

Implementation of SUDs in ways that meet the aspirations of the Pitt Review.
Issues include:


Long term maintenance of SUDs schemes

The automatic right to connect to sewerage and drains;

The impact that even minor development can have (including the
paving over of driveways).
Land management:
2
The National Flood Forum • Registered Charity No. 1121642
• A Company Limited By Guarantee • Registered in England & Wales No. 4349401
Registered Office: Old Snuff Mill Warehouse, Park Lane, Bewdley, Worcs DY12 2EL • VAT Registered No: 786 2681 83
National Flood Forum
Old Snuff Mill Warehouse
Park Lane, Bewdley
Worcestershire DY12 2EL
Tel 01299 403055
www.floodforum.org.uk

Enforcement of the Codes of Good Agricultural Practice would make a
massive difference to flood risk, improved agricultural productivity and
various types of pollution. Could this be funded, for example, by some
of the savings in water treatment costs that would arise?

Stronger fiscal links between water supply and land management
(slowing the flow) where it is needed to reduce flooding, winter storage
irrigation and reduced aquifer extraction

Further tying together of Floods Directive, Water Framework Directive
Habitats Directive, etc. Looking to the Dutch may help here; we should aim to
be really pragmatic and bold, linking this through to regeneration, tourism and
local economies, wherever possible; for example, the creation of
wetland/green space in order to enable development of housing.

Reform of upland land management – we currently have a fossilised system
that doesn’t really deliver economically, or on any other front. A review is
needed to establish some visions and to detail ways to enable change.

Internal Drainage Boards provide a really useful function, but the current
governance arrangements and legal framework need significant reform, so
that they:

Cover the areas where IDBs are really needed

Have an adaptive remit covering land management, flooding and water
cycle issues and environmental issues – Water Framework directive,
Floods Directive, Groundwater Directive, Habitats Directive and Birds
Directive

Are much more democratic, involving the population of the area
 Create the opportunity for communities undertake maintenance work for Risk
Management Authorities and also for communities to ask Risk Management
Authorities to undertake duties such as managing an asset or riparian
management. Communities should be able to raise funds collectively to pay
for work, such as a surcharge on Council Tax, but also receive funds if they
undertake work for a Risk Management Authority.
3
The National Flood Forum • Registered Charity No. 1121642
• A Company Limited By Guarantee • Registered in England & Wales No. 4349401
Registered Office: Old Snuff Mill Warehouse, Park Lane, Bewdley, Worcs DY12 2EL • VAT Registered No: 786 2681 83
National Flood Forum
Old Snuff Mill Warehouse
Park Lane, Bewdley
Worcestershire DY12 2EL
Tel 01299 403055
www.floodforum.org.uk
2. Putting communities first: A step change to put the needs of people at
the centre of flood risk management
Increasingly communities want to, and are, getting involved in managing their flood
risk. We need to support them to initiate and use local knowledge to improve flood
risk management, so they do not have to rely on Environment Agency and local
authorities to make progress:

We need to invest in flood risk management now to prevent much bigger
costs later.

Simplify and clarify Partnership Funding arrangements to encourage small
applications;

Give communities a route to bid directly for funding to address local flood
problems;

Through training, development and changes to service delivery, develop a
culture change in Environment Agency and local authority staff that
recognises the value of local knowledge and skills and puts supporting people
at the centre rather than organisational delivery;

Support the development of networks of flood groups across the country to
provide peer to peer support.

A bond on developers, or insurance, linked to each development to ensure
that people have a proper recourse when things go wrong. At present people
seem to have fewer rights than if they had bought a Mars bar.

Address the problem of reinstatement where planning conditions are applied
but insurance companies will not pay for them. There is a danger of some
people being left homeless from flooding last winter where they cannot afford
the additional costs.
3. Do what we are already doing better: Review and improve.
Major changes have occurred since 2007 in the way that we manage flood risk.
Some of these have been excellent, others do not appear to be working so well. We
need to review and improve what we are doing if we are to seriously tackle the
impact of flooding on people’s lives:
4
The National Flood Forum • Registered Charity No. 1121642
• A Company Limited By Guarantee • Registered in England & Wales No. 4349401
Registered Office: Old Snuff Mill Warehouse, Park Lane, Bewdley, Worcs DY12 2EL • VAT Registered No: 786 2681 83
National Flood Forum
Old Snuff Mill Warehouse
Park Lane, Bewdley
Worcestershire DY12 2EL
Tel 01299 403055
www.floodforum.org.uk

Review how the planning system actually operates for flood risk management
and can contribute to addressing flood problems, from development plans and
development control to building inspections. We think that under the current
system it tends to fall down at each stage, but that the answer is not to
“remove red tape” but to focus on doing things really well, particularly as part
of the pre-application process. The challenge is how to do this with reduced
resources.

Update building regulations to make developments more resilient. This would
remove a subsidy for developers, paid for by increased insurance premiums
and the trauma of being flooded.

Specify more clearly which organisation has lead responsibility during a flood
incident, and make the whole process much better understood by local
authority councillors and the public.

Review how effectively Lead Local Flood Authorities are undertaking their
duties and utilising allocated funds, identifying and promoting best practice
and supporting them to lead on flood risk management in their areas.

Have a much stronger focus on maintenance, of assets such as gullies and
culverts, of riparian responsibilities, and highways management. Almost all
flooding incidents involve one of these aspects not being adequate.

Develop up to date standards (particularly in building regulations and
planning) on reinstatement and property protection, for flooding, water cycle
issues such as using rainfall and grey water in new developments and
refurbishment. This would have a real impact by being applied evenly through
insurance claims
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The National Flood Forum • Registered Charity No. 1121642
• A Company Limited By Guarantee • Registered in England & Wales No. 4349401
Registered Office: Old Snuff Mill Warehouse, Park Lane, Bewdley, Worcs DY12 2EL • VAT Registered No: 786 2681 83
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