Consultation Response Form
Consultation closing date: 6th March 2015
Your comments must reach us by that date
Flood and Coastal Investment Programme
(FaCIP)
This consultation seeks views on our proposals to change the way the Welsh
Government allocates funding for flood and coastal erosion risk management in Wales.
We want to make flood risk investment clearer and more consistent.
We want to help identify at-risk areas so that long-term planning can commence and
appropriate schemes and land management put in place. In doing so we hope to raise
awareness of flooding in those areas, reduce risk and build resilience in communities.
Information provided in response to this consultation, including personal information,
may be subject to publication or disclosure in accordance with the access to information
regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act
1998.
If you want all, or any part, of your response to be treated as confidential, please explain
why you consider it to be confidential.
If a request for disclosure of the information you have provided is received, your
explanation about why you consider it to be confidential will be taken into account, but
no assurance can be given that confidentiality can be maintained. An automatic
confidentiality disclaimer generated by your IT system will not, of itself, be regarded as
binding on the Department.
The Welsh Government will process your personal data (name and address and any
other identifying material) in accordance with the Data Protection Act 1998, and in the
majority of circumstances, this will mean that your personal data will not be disclosed to
third parties.
Please tick if you want us to keep your response confidential.
Reason for confidentiality:
Name: Mr J B Griffiths
Please tick if you are responding on behalf of your organisation.
Name of Organisation (if applicable):Farmers’ Union of Wales
X
Address: Llys Amaeth , Plas Gogerddan, Aberystwyth, Ceredigion SY23 3BT
Please mark the box that best describes you as a respondent. If 'Other', please specify
in the box below.
Child/Young Person
Local Authority
Natural Resource
Wales
Please Specify:
Adult
X
Organisation
Other
Q1. Do you agree with the general need for a Flood and Coast Investment Programme
as put forward in sections 2 and 3 above?
Strongly agree
Disagree
X
Agree
Neither agree nor
disagree
Strongly disagree
Comments:
The FUW generally supports the need for a Flood and Coast Investment Programme.
Members did however question why flood and coastal erosion budgets were split
between revenue (55%) and capital expenditure (45%). Some members felt that a
30:70 percent split between staffing revenue costs and capital expenditure would be
more appropriate.
Over the last few years we have experienced a period of quite extreme flooding events
and coastal erosion incidents; this needs to be addressed with higher investment in
capital projects to resolve the problem.
The FUW welcomes the commitment to build, maintain and operate flood defences. It
is important that when existing or newly built defences serve a vital purpose, they are
adequately maintained not only to protect populated areas but also to minimise flooding
of agricultural land. It is paramount to ensure that food production is not threatened.
Once necessary improvements to flood defences have been undertaken then
investment could be re-directed towards raising awareness, maintenance work and
staffing issues.
Q2. Do you have any comments on using the Programme for all aspects of flood and
coastal erosion risk management in whatever way is most appropriate to address risk?
Comments:
The Programme should enable the allocation of resources to manage risks from all
aspects of floods and coastal erosion in a structured and controlled manner.
Members expressed the view that the factors used to score risk should include an
element of local knowledge as this could help identify potentially low cost solutions to
some of the problems. It is important therefore that the programme governance and
monitoring is delivered by a board which has a wide cross section of public
stakeholders.
Q.3 Do you have any comments on the proposal for a National Index of Flood and
Coastal Risk to help understand risk from all sources?
Comments: The proposal for the creation of a National Index for Flood and Coastal Risk
is accepted as the targeting of limited resources towards areas of highest risk in times
of austerity is considered to be a pragmatic approach.
Any value which is derived from the constructed index will only be effective if the data
fed into it is rigorous and accurate. The consultation document admits that the risks of
floods occurring do not remain constant, and the consequences of the floods in an area
are linked to the development, infrastructure or land use that exists at that place at a
particular time. This suggests that the risk index calculated at a particular place could
fluctuate over time.
To create a Flood Risk Index based on land areas is a sound initial approach, but
adopting Lower Super Output Areas (LSOA) as the building block of the index is
questionable due to the variability between areas. For example, a sparsely populated
rural LSOA of 1500 homes is likely to cover a large area of land mass, possibly
extending to more than one river catchment area, of differing flood risks . This could
lead to different houses having the same risk score, but in reality have a very different
exposure to flood risk and/or coastal erosion.
Q.4 Do you agree that a Flood Risk Index should remain a high level indicator of
combined risk but allow local flood modelling to be used to support evidence in
applications?
Strongly agree
Disagree
X
Agree
Neither agree nor
disagree
Strongly disagree
Comments:
As outlined above the Flood Risk Index is an acceptable but limited indicator of potential
floods and coastal erosion, but it is imperative that local flood modelling data should be
incorporated into the index. The use of local meteorological data and small catchment
hydrology should be used to provide an early warning system of localised floods, as
some of these occurrences will be replicated following similar weather patterns.
In addition, the Union believes that the local knowledge held by farmers and other land
managers of flooding hot spots and management practises should be gathered and fed
into the datasets.
Members strongly believed that flood risks and the maintenance of river banks and
waterways were strongly correlated. Management practices such as small scale
dredging to remove gravel and sediment, the clearance of fallen trees and the control of
invasive species could have a profound effect on the river flow. Without this
maintenance, as practised by Drainage Boards, the risk of flooding is greatly increased.
Members felt that in view of the disastrous environmental impact caused by flooding,
such as that experienced in the Somerset Levels last year, any environmental impacts
caused by the dredging of rivers and waterways were small in comparison.
Q.5 Do you have examples where flooding has repeatedly occurred in a place currently
shown as a low flood risk? Please provide relevant evidence as appropriate.
Yes
No
Not sure
Comments:
The Union‘s membership is distributed across Wales, and in view of the strong views
received about the lack of maintenance along river banks and the perceived
consequences thereof, it is highly likely that flooding has occurred in areas attributed as
low risk areas.
Q.6 Do you agree that information relating to defences should be excluded from the
Flood Risk Index? Presence of defences could be shown on any map and included in
the later appraisal stage.
Strongly agree
Disagree
X
Agree
Neither agree nor
disagree
Strongly disagree
Comments:
As nationally consistent datasets are not yet available on the level and physical
condition of defences, the FUW believe that this information should be excluded from
the Flood Risk Index until work has been undertaken to correlate this information.
A natural risk index would help local Risk Management Authorities make informed
decisions. A map of current flood defences and their condition is essential which should
be completed as soon as reliable data becomes available.
Q.7 Do you agree with the approach to Coastal Erosion risk and that it should be
marked separately to flood risk? If not, please provide an alternative suggestion.
X
Strongly agree
Agree
Disagree
Strongly disagree
Neither agree nor
disagree
Comments:
Creating a combined index to reflect the risk from the main identified sources of
flooding does have an appeal based on its simplicity. However, as the
consequences of flooding from the sea and from rivers are different, in terms of the
speed that it occurs and the permanence of damage caused it would be useful to
have separate indices for each source of flooding.
Within Wales productive agricultural land is a finite resource and when the cliff
retreats through coastal erosion this has a permanent detrimental effect on
livelihoods and on economic output. This management option threatens the most
productive lowland areas of Wales which could have adverse effects on food
production.
When a managed retreat from the sea is carried out, low output conservation
habitats such as saltmarshes are produced. Even if these habitats were supported
through habitat scheme payments such as Glastir, these are only offered to the
farmer for a five year period, and does not adequately compensate him for loss of
production. Once the land has reverted to a salt marsh it is lost to agricultural
production forever.
On occasions flooding is caused by a combination of the actions of sea, river and
infrastructure, and a separate index for each source would give a better
understanding of what is happening on the ground. For example, land may be
flooded as a consequence of high spring tides meeting swollen rivers following
above average rainfall, and together with rapid run-off of water from inappropriate
developments in a flood risk area; thus creating the perfect conditions for flooding.
The FUW commented in the Flood Risk Management Plan consultation that the
objective of not building in known areas of flood risk needs to be adhered to, but
there are recent examples of this not being the case. e.g. the development of a
retail park in the Ystwyth catchment area of the coastal town of Aberystwyth , a
known flood risk area.
The FUW believes that where possible separate indices for risks should be the
norm, thus enabling the total risk from all sources to be calculated as and when
these criteria come together. If these separate risks were included as one risk index
for an area, valuable modelling data is lost.
Q.8 Do you agree with the principles set out in Section 4.5 on assessing risk from
multiple sources and scoring by Lower Super Output Areas (LSOA)? Do you have any
comments or suggestions?
X
Strongly agree
Agree
Disagree
Strongly disagree
Neither agree nor
disagree
Comments: Please refer to earlier comments regarding the limitations of adopting
Lower Super Output Areas (LSOA) as the bedrock of a Flood Risk Index in rural areas,
and of producing one index to reflect the risk from multiple sources of flood risk.
Notwithstanding the concerns above, the concept of grouping like areas together based
on the individual area score would still label those areas as potential flooding hot spots
.The repercussions on insurance costs and property values for both domestic and
business premises would require detailed consideration if this procedure were adopted.
As acknowledged in section 4.5 of the consultation document the groupings would be
based on scores produced from generalised modelling which do have considerable
error margins.
Q.9 Do you have any further comments on the presentation or development of the
proposed Flood Risk Index?
Comments:
The FUW partially supports the use of the Flood Risk Index within the programme
as it will facilitate the gathering of all Risk Management Authorities around a table
to discuss possible interventions and the publication of flood index maps online.
The Union would welcome the opportunity to contribute to the public debate and to
support partnership working. Through this participation our members’ expertise
could identify at risk areas, and identify measures to mitigate the consequences of
flood events.
In particular the Union, through its members has expertise on land management
issues which would help reduce the flood risk of communities’ down-catchment,
and provided the voluntary work conducted by members was adequately financed
through habitat schemes flood prevention advances could be realised.
Indeed, a case could be made for the redirection of some of the Welsh Government
capital Flood and Coastal Erosion Risk Management budget towards land users
who might actively reduce the flood risk index of the highest grouped LSOAs.
However changes to the land eligibility rules for the Basic Payment Scheme, where
areas of trees forming a canopy or as scattered trees are excluded from support
payments will inevitably mean that woodland schemes become less attractive for
farmers.
Q.10 Do you have any comments or suggestions on the application process?
Comments:
Further to comments submitted to question 9 the FUW would like to reinforce the
potential contribution that the agricultural community could make to demonstrate
innovative interventions to the application process.
The FUW support the multiple benefits of reducing flood risk to homes, business
and infrastructure and consideration should be given to economic, social and
environmental aspects. A reduction in flood risk will help the resilience of the rural
economy, reducing economic disruption, and contributing to the development of
sustainable tourism, economic growth and climate change adaption.
Q.11 Do you have any comments or suggestions on the programme board or
governance of a Flood and Coast Investment Programme?
Comments:
The Farmers’ Union of Wales supports the need for a programme board to review
applications and to monitor outcomes and believes that this could lead to a
streamlined system with cost savings. The Union would welcome the opportunity to
be represented on the board in a genuine partnership working venture.
As outlined above, the Union has a significant Welsh membership distributed
across all land sectors, from which considerable experience and expertise is
available on land management issues. If representatives from the membership
were sitting on the Flood and Coast Investment Programme board this would help
develop a balanced approach to managing the risks of flooding.
Q.12. Do you have any other comments that you would like to put forward?
Comments:
The Union has no further comments.
Thank you for taking the time to let us have your views. We do not intend to
acknowledge individual responses unless you place an 'X' in the box below.
Please acknowledge this reply.
E-mail address for acknowledgement: bernard.griffiths@fuw.org.uk
Thank you for taking time to respond to this consultation.
Completed responses should be sent to the address shown below by the 6 th March
2015. The response form should be completed electronically if possible and sent to
FloodCoastalRisk@wales.gsi.gov.uk Alternatively, postal responses can be sent to:
David Sargent, Flood and Coastal Erosion Management, Flood and Water Division
Welsh Government, Cathays Park, Cardiff, CF10 3NQ.
X