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Cambridgeshire Flood Risk Management Strategy survey
Submission deadline: 23 January 2022
Responses compiled by Dr David Cobby on behalf of the Broughton Flood Action Group

Executive Summary and Section 1 – Introduction

• Is the reason for having a strategy clear?
• Do you feel there are any key points missing from the executive summary and introduction sections?

Thank you for the opportunity to comment on this flood strategy. As a Flood Action Group, we regard the communication of authorities with individual communities, and building confidence in the professionals effectiveness to deliver support as very important. We are therefore pleased to offer the following responses in the spirit of greater cooperation for the benefit of those at risk of flooding.
 
1.The strategy would benefit from defining upfront the expected audience, and what they are expected to get from it. This may lead to changes in the way the remainder of the strategy is structured. Instead of adding to what is already a lengthy document, we suggest below that some existing material is replaced with that which more clearly demonstrates the council’s strategy.
 
2.Community resilience, carbon net zero, biodiversity (and environmental) net gain, supporting economic growth and other significant aspects of the changing context for delivering flood risk management are mentioned lightly and not developed much further throughout the strategy. The introduction could signpost that much of the current content of Sections 2, 4 and 6 is in appendices for the interested reader, leaving more space to further develop the local detail.
 
3.A clear description of what CCC are going to do, to help manage the risk of flooding and improve community resilience. The majority of flood meetings will come back to the simple question of ‘what are they going to do about it?’. This strategy should recognise upfront this heart-felt cry of those who have been flooded and set out an appropriate response.

• If yes what do you believe is missing and why do you feel it is important for inclusion?

In the early days of the F&WMA, these strategies were arguably produced for the benefit of the LLFAs, so they and partners could understand the new roles and responsibilities. Ten years on, I believe these are now better understood and this strategy refresh instead presents an opportunity to set out how CCC will manage future flood risk in the manner best suited to local risk and requirements. 
It is important that this strategy is relevant to those at risk of flooding, as well as to those who are managing flood risk. What can those at risk of flooding expect from CCC, and what aspects of delivering flood risk management (e.g. reducing carbon, enhancing the environment etc) will CCC be particularly promoting in its working with other Risk Management Authorities?
As a flood action group representing a typical community at risk of flooding, there is little in the strategy to help or provide encouragement. Although not intended, the lay-reader may take away messages of ‘no funding’, ‘riparian owners are responsible’, ‘too many organisations involved’ etc. Although this political situation is not of CCC’s making, this document is an opportunity to present a more positive and proactive picture of ‘a strategy’ to make the best of the situation that exists. We recognise that the action plan introduces many important projects which will be undertaken, but suggest that these should not be consigned to an appendix which may be overlooked, but should be incorporated more centrally into the main body to demonstrate the strategic direction of the council.

Section 2 – Policy, Legislation and Guidance

• Is the background of the drivers and influencing factors for the strategy concise and clear?
• If not, where would you require clarity?

Table 2 appears to come from the updated Anglian Flood Risk Management Plan which is not yet published. It would be helpful to see the boundaries of flood risk areas marked on a map. In particular, we are interested in the extent of the Alconbury and Alconbury Weston areas.

• Are there any key influencing factors that you feel are missing?

Regarding the National Strategy, Section 2.2.1 states that it has incorporated a step change in language in relation for responding to flood risk. This step change in language could be more strongly represented in this CCC strategy. Section 2 lists most of the important strategies and plans which have influence, but not in a manner which is readily accessible. The list is useful for background context and would sit well in an appendix, but does not tell a story for those seeking to understand where the CCC strategy fits in, or how the many strategies could influence flood risk at their land, property or community. If the National Strategy, and strategies like the CCC strategy which cascade from it, wants to drive community resilience, then communities must be recognised as key audiences that require appropriate communication.

• If yes please advise on those and their connection

Section 3 – Cambridgeshire Background

• Do you feel the summary in this section helps to set the scene for Cambridgeshire?
• If not, are there any key points you feel are missing?

Should the unitary authority of Peterborough City Council be listed in the introduction to Section 3, or the relation of the strategy to the Peterborough area be clarified? It is later mentioned in relation to the Cambridgeshire and Peterborough Local Resilience Forum (CPLRF), but it is not clear whether this flood strategy is also designed to cover Peterborough.

​Section 4 – Roles and Responsibilities

• Does the strategy clearly explain who is responsible for managing flood risk?
• Does the strategy clearly set out what each of the organisations does?

It is perhaps worth clarifying in Section 4.2.1 that CCC Highways have budgets to maintain their drainage assets and that developers should have maintenance budgets for their drainage assets. The drainage authority or LLFA presumably have not put in any assets which it is responsible for, but others have and there is a line of accountability for the maintenance of these. This section could then link to later sections about enforcement, if drainage assets owned by others are identified not to be operating as designed and causing flood risk.
As noted above, much of the information on roles and responsibilities has not changed in over 10 years. It is not, therefore, a core element of a forward-looking strategy, but reads as a re-statement of legal positions. Much of this material could be put into an appendix and the main body could instead concentrate on how CCC will interpret these to manage flooding.

• Do you feel there are any organisations or bodies which have not been adequately covered?

As above, the legal positions have been adequately covered, but this is not likely to be of primary interest for those needing to practically manage flooding; other Risk Management Authorities will already be aware, and the language will not mean much to communities. Instead, the section could be presented with a focus on ‘what their roles/responsibilities mean for you’.
This section, or Section 7, provide opportunities to describe the CCC LLFA team, it’s current and potential future roles and how this team structure will help deliver the strategic direction. The constraints to delivery can be noted through limited staff time available, but provide an indication of how staff currently spend their time and how this could change in the future.
In section 4.9, the distinction between Local Flood Forums and strong community groups is not clear. It would be useful to know whether LFFs have a stronger recognition by local government, and what qualifies a group to be a LFF.

• Do you feel the community roles are adequately represented?

The basic outline of different community groups is covered, and the various guidance documents and establishing of community support groups is welcomed. However, this section could be greatly expanded over time with more information on the strategic direction the council wishes to take with communities. If the national strategy is to be embedded in this CCC strategy, then this section on communities should be central.

• Please advise of any information you feel is missing or areas in section 4 which could be made clearer

Section 5 – Risk to Cambridgeshire

• Does the strategy clearly explain what is meant by the term risk?
• Does the strategy clearly describe the different types of risk and their interactions?
• If you feel this section of the strategy is not clear please advise us where you feel changes may be required

It is suggested that climate change and its impact on flood risk could be strengthened throughout this and other sections. Little indication is provided as to the scale of increased rainfall and surface water flooding, or to the recent peak river flow projections for major rivers published by the EA/CEH. The river flow projections are not straightforward, often showing no change, or even decreases in risk to the middle of the century compared with today, before rising towards the end of the century. It would be interesting to know CCC’s view on how these complex projections will be used in managing flooding.
The converse risk of reduced summer rainfall and the need for greater collaboration between flood risk management and water resource sectors is only lightly covered. Demonstrating strong links with Water Resources East, Anglian Water and organisations promoting nature-based solutions could be an important component of a successful strategy to manage excess and deficit of water in the future.
The risk of particular developments (e.g. Alconbury Weald by Urban and Civic) on flood risk to others (e.g. Broughton) was noticed by a number of people as not being mentioned in the strategy. The concerns include what's going to happen to the water run off, and who is going to ensure that the standards are maintained in perpetuity. For such major developments as this which could impact flood risk, it may be appropriate for the strategy to emphasise that CCC will enforce their requirements and seek betterment where possible.  
It was noted that the map showing Main Rivers on page 27 is too small to understand where watercourses change responsibility from CCC to the EA. This is a key piece of information which would be useful to highlight in a useable level of detail. Connected to this is the suggestion that the interactions between different authorities is elaborated on. For example, the Bury Brook is an Ordinary Watercourse to Kings Ripton, after which it is Main River to Ramsey where it feeds into the Middle Level Commissioners district. It would be useful to understand how CCC, the EA and MLC will work together to ensure Broughton, stuck in the middle, are not put at greater flood risk.

Section 6 – Partnership funding

• Is the explanation of different funding sources clear?
• Let us know if you believe we have missed out any funding opportunities or any of those described are unclear

The section lists the key funding sources and provides a brief overview. It is also good to demonstrate where grants and other opportunities have been applied for, both successfully and when not successful. However, it is suggested that the language of this section could be made more ‘active’ to communicate the proactive way that CCC is seeking greater funding. For example, the following is a typical statement: ‘To make the most of these opportunities the county council and its partners need to be prepared to respond, this can be best achieved by…’. Re-writing as ‘We will make the most of these opportunities through being ready to respond by…’ will provide a much better sense of strategy and purpose. It would be good to summarise this section in simple terms by explaining why funding is limited, but what CCC are doing to maximise funding opportunities. Simply listing the different sources does not effectively convey this important information.

Section 7 – Management and Action Plan

• Are the activities and actions in the strategy clear and concise?
• If no, where do you feel better explanation is required?

It would be of interest to people to learn more about what it planned in the Community Flood Action Programme (CFAP).

• Is there a clear enough distinction between business as usual in Section 7 and the measures that go beyond this in the Action Plan?

Having the action plan tucked away as a separate appendix does not give these important actions the prominence they deserve. These provide a useful picture of the many activities that the LLFA is involved in, and a good indication of the strategic direction being pursued. It is suggested that these actions could be better integrated into the main body of the strategy, to replace many of the ‘business as usual’ activities which will not change from year to year. 

• Do you feel there any any activities or projects which are not represented here? Please provide advice on those

References, Appendices and additional comments

• Are there any details referred to in the strategy where you are unsure of the source? If so please advise using section numbers as references.
• Is there any information, research or details you feel may be missing and could be better signposted?
• Please use this section to provide any additional thoughts or comments you may have in relation to the strategy, its format, layout, wording or content.  Using section numbering to guide feedback.