Protecting Sheffield, Flooding Consultation
1.1 As Member of Parliament for Penistone & Stocksbridge I would like to make observations and raise some concerns I have in relation to Sheffield City Council’s consultation document ‘Protecting Sheffield’.
1.2 As a Member of Parliament whose constituency was badly affected by the floods of 2007, I have first-hand experience of the devastation flooding causes. It is not just the initial flooding that is stressful; this is just the start of a process that can take years to fully recover from. Indeed, you didn’t even need to be flooded to feel the effects of that day in July 2007, as the people of North West Sheffield found when the A6102 collapsed and was closed for a considerable length of time, due to the very complicated engineering challenge presented by the incident.
1.3 First of all, and in the context of the 2007 experience, I acknowledge the need for a scheme that protects Sheffield and mitigates the impacts of flooding on residents and businesses. A scheme is long overdue and, as your document notes, the city had a lucky escape from a further major flooding incident in 2012.
1.4 I fully welcome the focus, in part, on softer measures, such as water storage, which could make a contribution to keeping homes and business safe from flooding. This focus on preventing flooding with ‘soft’ measures takes on board the latest thinking and evidence on water management and accepts that while hard defences certainly have their place, these alone are necessarily limited in their impact. This latter point is best illustrated by the awful flooding of York last winter.
2 Limited scale and ambition
2.1 While I appreciate the work carried out by SCC, ARUP and the Environment Agency, I am concerned that the overall scheme is too limited in scale. Present scientific opinion is that as a country we can expect many more extreme weather events and there is now a growing and extensive body of evidence which indicates that flood risk management planning needs to be at catchment scale. Given this evidence, the physical boundaries of the proposals presented by Sheffield City Council are disappointingly limited in scale.
2.2 For example, the River Don, which runs through my constituency, has its source in the moorland to the north west of Barnsley, making its way through western Barnsley before its appearance in Sheffield just north east of Deepcar. As currently presented, the scheme fails to define adequately what is the overall catchment scale for this river. The consequence of this is likely to be that the scheme will be limited in impact, because it fails to develop a comprehensive and coherent package of proposals that maximizes flood management potential across the whole catchment for the river.
2.3 This criticism can also be applied to the schemes proposed in the document for other rivers in the city. I consider a better approach would be a flood management scheme, which takes more account of possible upstream measures, and by that, I mean as the river develops from its headwaters. This is also a view the government endorsed in its ‘National Flood Resilience Review’ report.
2.4 In addition, any measures implemented in the city could have effects to flows further downstream, as the river Don makes its way through Rotherham and Doncaster. At the very least, the consultation should offer an assessment of impacts downstream.
2.5 Because of this failure to consider a strategic approach to flood risk management by developing a scheme, which works holistically across the whole catchment, the consultation represents a missed opportunity. The scheme presented may also not deliver the results hoped for.
2.6 I would therefore recommend the council consider opening up its partnership approach in order to develop a more meaningful catchment scale scheme. Such a scheme would include as key partners the Peak District National Park, Barnsley Council, Rotherham Council, and Doncaster Council, as well the Environment Agency. It would also need to involve numerous other stakeholders, such as farmers and landowners.
3 Identified upstream solutions
3.1 While I have concerns about the ambition of the present formulated scheme I do acknowledge that the scheme makes an attempt to deploy a range of measures, all be it limited in scale.
3.2 The scheme, however, does not seem to have been developed in detail and certainly will need further work before I could be confident they will have the desired effect in reducing flooding. For instance, the report states officers have identified some potential 760 sites in the Upper Don area for floodplain and storage features, but there is no information available as to the nature of these sites or what revenue considerations have been made for their use, both in terms of compensation for uninsured losses and maintenance of the land for flood purposes.
3.3 I suspect many of these sites involve farmland and surly a question must be whether or not it will be possible to use them; the council will certainly need permission to do so. I do not suspect for a minute that Sheffield City Council would want to use all these sites, but has any measurement been made of how many sites would be useful as an addition to the scheme currently under consultation? In addition, what assessment has been made of the impact on the scheme’s proposed effectiveness of not using any of these sites? On the other hand, if some of these sites are included in the final scheme, how will compensation be paid and from where? At the present moment CAP funding could be used for compensation as far as farmland is concerned, but even then such an arrangement would need to be brokered in liaison with Natural England and the Environment Agency, in the context of the agri-environment principle. A further consideration is the question of what will replace this funding after exit from the EU; currently this is very unclear.
3.4 Even where sites have been identified for water storage, such as those in Wharncliffe Side, Oughtibridge and Beeley Wood in my constituency, there is still no indication in the document that officers have considered whether or not the Council would be in a position to pay compensation for uninsured losses to the owners of the land. If compensation agreements with landowners cannot be reached, what impact will this have on the assessed effectiveness of the scheme? And what alternatives exist to these identified sites?
3.5 Given that any flood storage scheme, large or small, implies a long-term arrangement with the landowner, arrangements will need to be put in place for the long term and in such a way that even if ownership changes the arrangement survives intact. The consultation gives very little information on how this may work in practice and how this may affect landowner’s rights. I believe therefore that more work is required as to how this land usage will work in practice, principally because water storage is a key component of the scheme under consultation and it is therefore essential that the Council plans and implements such measures in a robust manner. My constituents will expect nothing less, if they are to have confidence that flood risk in their areas is being effectively managed for the future.
3.6 While I fully appreciate that the named water storage areas, if adopted, may well help reduce flood risk in the city, I am concerned that they are being too heavily relied upon to store and slow down floodwater in the lower reaches of our river network. Current thinking is that a comprehensive catchment approach is required to maximize the effectiveness of flood risk management; given that the scheme being consulted on has materialized a full nine years after the 2007 floods, it is deeply disappointing to see that it is so limited in scope and ambition.
4 Other Catchment concerns
4.1 The document rightly states that tree planting could and should be used to complement other measures to slow flow rates. Again, however, the proposals do not appear to have been developed sufficiently. Suitable sites are not identified, suggesting that there has been no rigorous assessment of where tree planting would have the most impact in terms of slowing the flow downstream for rivers such as the Don. Neither is there any indication of the funding available for such work, or indeed whether the proposals to plants these trees would be funded by the capital grant being sought by government. Issues relating to land ownership are also pertinent to this part of the scheme. I believe therefore that further work needs to be carried out as to how a tree planting strategy would fit in with a more comprehensive, catchment scale approach to flood risk management. This work would also need to be able to reassure members of the public that it is deliverable, both in funding terms and in relation to the ownership of the sites chosen.
4.2 Worryingly, there is no reference in the consultation documents as to how the scheme proposed might dovetail with the restoration work currently being undertaken by ‘Moors to the Future’. This important work project is supported by both the Environment Agency and Natural England and promises a wide range of biodiversity benefits. It is also designed to contribute to reducing pollution of our water supply, hence it is supported by Severn Trent Water, Yorkshire Water and United Uitilities. The project, which is supported financially by the EU LIFE Programme, is also being measured for positive impacts on water flow and early indications from the evidence gathered are promising in this respect.
4.3 The moorland of the Dark Peak contains habitat, which is precious in biodiversity terms; upland blanket bog is internationally rare. Moors for the Future is effectively working to reverse over 200 years of pollution and other forms of degradation. It is also increasingly recognized, however, that such projects have a real role to play as an integral part of catchment scale flood management schemes. I would therefore recommend steps are taken to open up a dialogue with Moors for the Future as soon as possible, as part of a major piece of work to broaden the Sheffield scheme so that it is transformed to become a potentially much more effective catchment scale scheme, as outlined earlier.
5 The use of Reservoirs
5.1 The consultation document also considers the use of local reservoir capacity to help alleviate floodwaters in the city. I have a number of concerns about this and worry in particular that the scheme is overly reliant on third party co-operation, which, for a range of perfectly valid reasons, may not be deliverable.
5.2 The primary purpose of reservoirs is to provide adequate drinking water for customers, both domestic and commercial, and any discussion about their potential use for flood management must appreciate this point.
5.3 Yorkshire Water must be allowed the right to put first the provision of adequate and safe water supplies to its customers; if there is any room for flood management via our reservoir network, all well and good, but that cannot be at the expense of our water supply. For instance if reservoir levels are dropped and capacity is not replaced it could mean an artificial shortage is created.
5.4 Yorkshire water manages an integrated network of resources and balancing capacity with demand requires a great deal of skill and expertise. There is no indication in the consultation document as to whether or not the developers of the scheme have worked with the water company on the complicated interface between meeting the needs of customers on the one hand and using reservoir capacity to manage flood risk on the other. Nor is there any detail as to how such an arrangement would work and what the protocols would be. Given that a major plank of Sheffield City Council’s scheme for protecting the city would be delivered by using reservoir capacity, it is imperative that the Council should reveal as soon as possible whether this is a realistic option. If it is not, then the Council has to establish quickly how it will redraw its proposals to make them fit for purpose.
5.4 In addition, if it proves possible to use the reservoir network, there will be revenue implications, as Yorkshire Water would have to be compensated for loss of capacity. Once more therefore the question arises, has revenue funding been identified to cover such costs?
6.1 The document makes the point that SUDs should be used in all new development. There is, however, very little detail on this. In April 2015, government guidance was changed, so that now the installation of sustainable urban drainage systems must be considered for all new developments.
6.2 During conversations with Sheffield City Council planning department I have been informed that while SCC does not and cannot make SUDs a prerequisite for development, it is keen to see SUDs in some form installed on schemes.
6.3 If the Council wants to make sustainable urban drainage schemes an integral part of its flood risk management scheme, then it will have to work harder to ensure that SUDs are used more consistently across the city as development take place. I acknowledge that Government could do more in this respect to make the use of SUDs mandatory, but my question is, what representations have been made by the Council to Government on this? Again, residents in the city will expect clarity on this issue and will want to know just how much of a role the council thinks SUDs can play in reducing flood risk.
7 Protecting Property
7.1 The consultation’s foreword comments that a one of its themes for protecting the city is to encourage the public to better protect their homes. It then goes on to say, however, that the consultation will not be considering that theme.
7.2 Evidence is emerging that making homes more resilient can be better carried out on a neighbourhood scale. Not least because a few residents protecting their own homes can exacerbate the problems elsewhere. I do therefore think some thought needs to be given to organizing the capacity of vulnerable neighbourhoods to secure funding for comprehensive home protection packages.
7.3 I hope the Council will in the future carry out consultations on how individual homes might be made more resilient to flooding.
8 The natural Environment
8.1 The consultation document refers more than once the need to minimize the effects of the scheme on ancient woodland. This seriously concerns me as ancient woodland is irreplaceable and the damage is obviously therefore permanent. As I am sure you will understand, it is not just the trees in ancient woodland that are important, it the soils they grow in and are sustained by that is precious, providing as they do a unique ecosystem.
8.2 Given their special nature and how rare they now are, I would be very interested to know whether either SCC or ARUP have consulted with Natural England on the proposals to create water storage areas when these proposals impact on ancient woodland.
9 General Comments on the Scheme
9.1 The consultation as presented appears to indicate that the consultation represents a series of choices, a sort of pick and mix approach. I feel with such an approach there is a danger that the city will eventually focus on a mix of measures which are much ‘harder’ than they need to be. In addition, the very fact that the consultation is suggesting choices from a range of options suggests absolutely that the proposals are not truly holistic in nature, and are not being designed to provide full catchment protection.
9.2 If we are to protect the city effectively and reduce flood risk we must, I believe, look at a full catchment scale scheme. This will involve a much larger, fully integrated scheme that looks at the whole catchment of the Don, which of course is the ‘spine’ of the water network in South Yorkshire.
9.3 Sheffield City Council needs to be mindful that the science behind flood management policy is developing all the time, just as the science on climate change is indicating that extreme weather events are more likely in the future. It is therefore essential that the Council should work with a wide range of partners across South Yorkshire in order to do its utmost to ensure that any scheme developed represents the very best practice available. Given the increased risk we face, it is important the city should get this right.
Angela Smith MP, Penistone and Stocksbridge
Constituency MP of the Year 2011-12