Shropshire Council is consulting on its flood risk strategy.
This a good piece of co-working with Staffordshire County Council. But I am not sure that it will allow us to tackle growing flood risk effectively.
I’m sceptical that its guidance on planning will be followed in practice. I’m more disappointed that greater attention hasn’t been given to using woodland to alleviate flooding and that farming practices are virtually ignored.
The flood strategy needs to be greener and more ambitious.
Planning
On planning, the strategy gives sound advice:
Inappropriate development which could increase flood risk will be avoided, as will inappropriate development in areas of significant flood risk.
5.2(4). We will aim to manage flood risk and drainage associated with new development such that no new flood risk is created and, wherever possible, opportunities to reduce flood risk are taken through early engagement with developers.
This a laudable ambition. Unfortunately, such sentiments are too often ignored when planning applications are being considered. The pressure to deliver new housing has been so strong that far too many developments have been built in the floodplain or without adequate regard to their impact on flooding. Objective 5.2.(4) should be given greater prominence in the policy to ensure that current concerns over lack of land supply and worries about appeal costs do not lead to developments being approved even when they increase flood risk.
The strategy pays no regard to the cumulative impact of developments on flooding and this should be corrected.
Sustainable Drainage Systems
The Flood Risk Management Strategy gives a lot of emphasis to SuDS – Sustainable Drainage Systems. This is right but the strategy gives a definition of SuDS that is too narrow:
A method of drainage design which mimics the drainage characteristics of an area prior to development.
SuDS is more than ponds and swales. It includes green roofs, permeable paving on drives and car parks, and grey water recycling where rainwater is used to flush the loos. Actions like these hold back water easing the risk of flooding in Shropshire and downstream. All of these should be highlighted in the strategy to ensure that they don’t get sidelined.
Environmental measures
Section 9 looks at wider environmental objectives. Its fine as far it goes but the text makes no mention of the role of woodland in reducing flooding. Planting trees on the floodplain, on slopes and on hills can significantly reduce water flow. George Monbiot has argued the case for increased woodland and better farming practices. I largely agree with him on the facts, without necessarily feeling comfortable with his tone of attack.
The flood strategy mentions that removal of ditches, tearing out of hedges and compaction of soil on farmland increases flood risk. There are no policies to address the consequence of these actions. This section should be rewritten to acknowledge and encourage green contributions to reducing flood risk.
Conclusion
This strategy is a good start but it needs to go further and be greener if the growing flood risks in Shropshire and in locations downstream of us are to be tackled.
The consultation closes on 30 June.