Draft National Flood and Coastal Erosion Risk Management Strategy for England

Reconsider the separation of "main" and "non main" rivers to different authorities. This is confusing to the public; in some cases duplication of effort and an inconsistent approach to works in rivers.
Reconsider which rivers are "main" and "non main" as the historic designation of these rivers (& hence different levels of controls) are primarily based around land drainage. and not flooding .

Measure 1.3.1 - Agree but with care not to provide only "engineered off the peg solutions". eg the best woody debris dams are often those made of what's available on site & mimicking nature rather than formal engineered structures.

Full heartedly agree with enhancing the environment but note that preventing flooding in itself is rarely an enhancement for the natural environment ie mitigation, compensation & enhancement required.

"New sources" suggests simply cut backs on central government funding.

Though noting that avoidance of floodplains, flood flow routes & areas vulnerable to river & coastal erosion should normally be the primary approach.

Biodiversity has continued to be lost over recent decades despite grants and legal constraints. Environmental net gain needs to be fully implemented & enforced.

Agree, provided this is clearly laid out as not enabling new development in floodplains and areas at erosion risk ie this policy would be expensive & not sustainable.

This should include the option for strategic retreat to protect people & businesses.

Agree totally. eg Insurance companies should not be allowed to require like for like replacement of flood damaged property where there are viable & reasonable improvements available that would be more resilient.

Local flood infrastructure management would generally be best within one authority. More efficient with less duplication of expertise; and clearer lines of communication/responsibility for the public & businesses.

"Should understand flooding and coastal change" ie not just "understand the impact" as this leads to wrong solution in wrong place and unnecessary collateral damage to the environment.

Agree provided that this is not just about adverse impacts but includes a wider curriculum of the geography/geomorphology so that flooding and coastal change is understood in its wider context and not only the adverse impacts. Helps to promote better solutions.

Surface water flooding and riverine flooding should be managed by one authority as they are not entirely separate issues and impact on each other. Individuals & businesses are often impacted by flooding from multiple sources and this would be more clearly addressed by a single organisation.

Agree fully with 3.4.2 and 3.4.3.

1) I think everyone in Redacted text hated the 3rd paragraph of the Introduction:
"Flooding of any kind is horrendous. Erosion destroys. They are dirty, invasive, damaging, and they can kill. They can force people to leave their homes and their businesses, cause prolonged mental ill health, and destroy livelihoods, natural habitats and other valued places. Even at their best, flooding and coastal change can be inconvenient and disruptive."
Inaccurate/only partially true.

3rd paragraph - 1st sentence of intro is untrue. Could potentially say "Flooding can be horrendous"?; or "Flooding of homes and businesses is horrendous"? However flooding is a natural process which is essential to many natural habitats and to the "health" of most rivers ie an important geomorphic process. Also flooding in most locations is important in protecting homes and businesses. Flooding out onto the floodplain instead of trying to contain it in-channel also reduces bank erosion. Occasionally flooding can even be beneficial to farming - depending on scale of flood and type of farming (Nile is the most obvious example - but here in Britain - water meadows...)

3rd paragraph - 2nd sentence. "Erosion destroys" - Yes sometimes - but it also creates. Again an important geomorphic process - essential for many types of fish spawning habitat; for many invertebrates and for nest sites for sand martins & kingfishers. Increases diversity of biotopes. Allows river to adjust to changes in flow & sediment supply eg meandering lengthens river and slows flow. Necessary for natural adjustment to climate change.

3rd paragraph - 4th sentence as already mentioned - generally creates/restores & maintains natural habitats - even though some are destroyed eg sandmartin nests can be destroyed by a flood but without floods/erosion they don't have nest sites. Similar for invertebrates of riverine sediments etc

3rd paragraph - Last sentence above also untrue - as per points above.


2) Separate issue - which I indirectly referred to in several questions within my formal consultation response (that appears to be lost). Nobody seems to be looking at the fact that main and non-main river have been divided between the EA and flood authorities. This was a retrograde move. The split has resulted in inconsistency; duplication of effort between organisations; confusion for applicants (particularly where works involve both main and non main river) - because they have two completely different regimes to apply for from different organisations using different critria. .. And of course a need for meetings and coordination between flood organisations that is less efficient than a single organisation responsible for flood schemes (both construction/maintenance & running). Doesn't really take into account that for NFM. flood storage etc work/approvals often needs to be on non-main rivers - even to protect property adjacent to main river. Most/many flood authorities do not have in house fisheries staff/expertise; or geomorphologists & often no biodiversity staff.

3) Something not mentioned (as far as I'd spotted at the time I stopped the main consultation ) - Caravans. Could we please change our approach to caravans in terms of planning response & protection. The idea/pretence that mobile homes/static caravans can/will be moved off the floodplain in a flood situation is generally completely impractical and in Cumbria rarely with sufficient warning. Caravans are extremely vulnerable to flooding; can be permanent homes; can be as expensive as some houses (ie relevant to cost benefit of flood schemes) and are particularly likely to house vulnerable people (physically or financially); and they can increase flood risk to others if washed downstream.