Written Consultation
Consultation on draft Flood Risk Management Plans and Strategic
Environmental Assessment
This consultation runs from the 10 October 2014 and ends on 31 January 2015. We look
forward to receiving your feedback.
Mr J B Griffiths
Sector and Organisation
Farmers’ Union of Wales
Contact details (e-mail and phone
01970 820820
River Basin District Response for
Western Wales, Dee and Severn Flood Risk
Management Plans
Yes I would like a copy of this response to be included in the final response document (please
tick as appropriate)
(Under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004,
Natural Resources Wales may be required to disclose your response to this consultation, but will not
include any personal information. If you have requested your response be kept confidential, it may still
be required to provide a summary.)
Would you like your details to be added to our stakeholder list to
keep you updated on this work and events that may be happening
locally to you?
How can I find out more?
Further information on the Flood Risk Management Plan consultation is available through
the Natural Resources Wales or the Environment Agency’s websites.
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Flood Risk Management Plan Consultation Questions
Consultation Question 1
Do you agree this draft plan sets out the most significant flood risk issues for your area?
Consultation Question 2
What do you consider to be the highest priorities for managing the risk of flooding in your
The Farmers’ Union of Wales believes that the targeting of specific objectives and
resources toward the National Strategy objectives 1 and 2 are vital. These are listed
1. Social: people & communities
2. Economic: potential cost & economic benefit.
The Union regards objective 3 of the National Strategy, Environment, cultural
heritage, landscape & habitat diversity as important but of a lesser priority.
Objectives 1 and 2 are also inter-related, as maintaining communities is intrinsic to
developing a vibrant resilient economy.
The FUW supports the Welsh Government National Flood & Coastal Erosion Risk
Management Strategy objective in the most at-risk communities. Using the
Communities at Risk Register, these communities are those in the high risk
categories (1 in 30 chance of floods), and the medium risk categories (1 in 100
The Union believes that outside of urban businesses and households, agriculture
and rural tourism should be the next priority business sector in Wales. The
agricultural industry is hugely affected by flooding of land and is always under
potential threat from rivers and coastal areas. The disaster of the Somerset levels
should serve as an example of the damage, loss and distress that can be inflicted
on rural communities and businesses as a result of flood damage.
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It is important to have the right objectives for managing the risk of flooding, taking account
of the impacts of flooding on people, property and the environment.
Consultation Question 3
Do you understand the objectives as described in the draft plan?
Consultation Question 4
Is the balance right between the ‘social’, ‘economic’ and ‘environmental’ objectives, as
explained in the draft plan?
If not, what would you change and why?
As indicated previously, the balance between social, economic and environmental
objectives needs to be carefully considered within the draft flood management plan.
In the FUW’s opinion, resources need to be directed towards social and economic
objectives in the first instance, as the agricultural industry and supporting businesses
generate employment and is an important source to Wales’ GDP.
The Flood Risk Management Plan sub-objective 2 should include a statement
demonstrating the need to defend business’ resilience through better flood risk
management as well.
As regards the Policy options of the Catchment Flood Management Plans, it is
difficult for rural businesses to accept a reduction (policy option 2) in flood risk
management options when their homes and businesses are at risk due to climate
change and to decision making beyond their control.
Policy action 6, which would take action to store water or manage run-off to reduce
flood risk is an option the FUW believes should be judged on a case by case basis.
Deliberately flooding agricultural land to control flood risk would compromise farm
incomes and negatively affect Welsh Government objectives of developing a
sustainable agriculture. Were this policy option adopted, it is likely that the run-off
areas would largely be in the lowlands. This land is the most productive agricultural
land (grades 1-3) in Wales and is traditionally supported by higher land support
payments. The implications of using such areas for flood management need to be
fully costed out, not only with reference to the impact on food production; farmers will
need to be convinced that they will be fully compensated accordingly for any loss in
land availability.
Consultation Question 5
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Are there other flood risk management objectives that should be included?
This draft plan proposes new ‘measures’ to manage flood risk, alongside measures which
are already ‘agreed’ and ‘ongoing’.
Consultation Question 6
Do you understand the difference between on-going, agreed and proposed measures, as
explained in the draft plan?
Across all proposed, agreed and ongoing measures, the plan describes ‘prevention’,
‘preparation’, ‘protection’ and ‘recovery and review’ approaches.
Consultation Question 7
Is the balance right between these different types of approach, as explained in the draft
The proposed implementation of the plan through the delivery of preventative measures
does not appear to be fit for purpose, when considering its practical application. This has
an issue
with the
of previous
If been
not, which
would you
change, planning
and why?decisions, and NRW is at risk of
repeating these errors. For example, the objective of not building in a known area of flood
risk needs to be adhered to, but there are recent examples of this not being the case. For
example, planning was approved for a retail park in Parc y Llyn, Aberystwyth on land which
was formerly a dairy farm. Grassland was replaced with concrete, tarmac and roofs which
could potentially exacerbate existing flooding problems in the area. Aberystwyth is at risk
from high tides in the spring and autumn, and two rivers, the Ystwyth and Rheidol, sourced
in high rainfall catchments meet the sea at the town. The granting of such developments
appears totally at odds with measures to prevent flooding by not developing in present and
future flood-prone areas, and these areas have indeed experienced severe flooding
problems in the last two years.
Recovery and Review is an approach described as “returning to normal conditions as soon
as possible and mitigating both the social and economic impacts on the affected population”.
There seems to be very few examples using this measure in the delivery plan.
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FUW members commented that the flooding of agricultural land caused damage to soil
structure, loss of invertebrates and nutrients, loss of crops and posed a danger to farm
animals. The recovery of that land to production includes the removal of debris, fencing
and reseeding; all costs which are borne by the farmer, and this should be recognised and
compensated for, particularly if that flooding is part of a river basin management approach.
Consultation Question 8
Are there other proposed measures that should be included?
The FUW believes there should be a greater emphasis on flood prevention rather than
merely reacting to a crisis. Members felt there should be a return to the dredging of
rivers and canals so that water flows more easily to the sea. The control of
encroaching invasive species, such as Japanese Knotweed alongside riverbanks
should be prioritised, involving a whole catchment area approach, with landowners
financially incentivised to work together. This would aid the free movement of water to
the sea.
More flood prevention could be achieved if farmers were offered realistic payments for
environmental schemes which contribute to peatland and habitat restoration. As a
consequence water movement from the hills would slow down. Payment rates for
voluntary environmental schemes need to be set at a level which might persuade
landowners to join and adjust their management practices accordingly
If policy option 6 of the Catchment Flood Management Plan was to be adopted for Mid
and East Wales as shown on the map this would financially penalise farmers in those
areas, but the benefits of reduced flood risk would be realised by others in Wales and
beyond. As a result, this policy should only be considered following full consultation
with the farmers and landowners affected.
The FUW feels that other measures should be considered such as quickly replanting
alternative tree species in clear fell areas in the hills. Unless this is done, surface
water quickly runs-off through open furrowed land, exacerbating the risk of flooding.
Consideration should also be given to incorporating farm flood planning into the
knowledge transfer schemes of the RDP.
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Consultation Question 9
How can you support the work set out in the draft flood risk management plan to reduce
flood risk?
The FUW is happy to communicate with its membership and the agricultural
community to disseminate information and knowledge regarding flood risk
The Union also consults its membership before responding, to any consultation. In
doing so, farmer expertise, knowledge and opinions are conveyed to government
departments and agencies.
The FUW, is always willing to work with other organisations, such as the NRW, to
facilitate joint working and disseminate advice and guidance to the agricultural sector
in Wales.
As well as draft flood risk management plans, Natural Resources Wales is consulting on
draft updates to river basin management plans, which set out measures to improve water
in rivers, lakes, estuaries, coasts and in groundwater.
Consultation Question 10
Are there things you think should be done to improve co-ordination of river basin and flood
risk management planning?
The Union considers that, as there is an overlap between the FRMPs and RBMPs to
meet the targets set by the Water Framework Directive, there should be a level of
integration between these Management Plans.
This could be achieved by
considering the relevant measures outlined in the current RBMPs and integrating
them into the FRMPs during their development.
Consideration should also be given to the role that the Glastir agri-environment
scheme plays in Wales, particularly how the options outlined as part of the water
management aspects of the Advanced element, could be integrated into FRMPs.
The Union believes that improved flood risk management can be achieved by coordination of the objectives of the RBM and the FRMP for each area. For example, if
wetlands were developed in the lower Severn River basin, this would also contribute
to the slowing down of water movement. This would require less intervention using
policy 6 of the Catchment Flood Management Plan. Not all measures to reduce flood
risk should be in the hills.
The FUW supports woodland development in the Midlands to manage improved
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water storage.
For the Severn River Basin District only
We have proposed a change to the boundary between the Severn and South West River
Basin Districts.
Consultation Question 11
Do you agree this proposed change should be adopted in the final plan?
FUW members were not able to respond to this question, as there was insufficient detail
provided in the consultation documentation to provide an informed response.
Strategic Environmental Assessment Consultation Questions
A strategic environmental assessment (SEA) has been undertaken to consider how the
draft flood risk management plan could affect people and the wider environment. The
environmental report presents the results of this assessment and summarises the effects
that are significant for the river basin district as a whole.
Consultation Question 12
Do you agree with the conclusions of the environmental assessment?
Members did not articulate any views on this matter.
Consultation Question 13
Are there any further significant environmental effects of the draft plan which you think
should be considered?
The comments to previous consultation questions should be considered, as regards the
need for acknowledgement of the wider social and economic impact of flooding practices
on the agricultural community.
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We have described potentially ‘negative effects’ of the draft plan on the environment which
would need mitigation, as well as wider opportunities to achieve ‘positive effects’.
Consultation Question 14
Are there further mitigations or opportunities that should be considered for the plan?
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How to respond
Your response to this consultation needs to be returned by 31 January 2015.
We would like you to use this consultation pro forma to respond to this consultation. You
can return it by email to [email protected] or
by post to:
Rachel Sion
Natural Resources Wales
Ty Cambria
29 Newport Road,
CF24 0TP
How will Natural Resources Wales use your information?
We will publish our full response to each FRMP consultation in April 2015. It will include
summary comments and queries we received in the responses and will outline our
recommendations which will take these into account. The report will be available on our
website and circulated to all consultees. We will include the name of the organisation for
those responses made on behalf of organisations. We will not publish the names of
individuals who respond. Should you not wish your response to be included please
ensure that this is stated clearly on the front of this proforma.
Under the Freedom of Information Act 2000 and the Environmental Information
Regulations 2004, Natural Resources Wales may be required to publish your response to
this consultation, but will not include any personal information. If you have requested your
response be kept confidential, it may still be required to provide a summary.
If you have any questions or complaints about the way this consultation has been carried
out, please contact:
Rachel Sion
Natural Resources Wales
Ty Cambria
29 Newport Road,
CF24 0TP
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consultation on the draft flood risk management plan