Southend-on-Sea Borough Council Agenda
Item No.
Report of Corporate Director of Enterprise, Tourism and
the Environment
to
Cabinet and all Members of the Council
on
th
6 November 2007
Report prepared by: Viv Burdon and Roy Hunt
Managing Flood Risk: South Essex Catchment Flood Management Plan
Consultation Draft Plan - June 2007
Economic & Environmental Scrutiny Committee – Executive Councillor: Anna Waite
A Part 1 Public Agenda Item
1. Purpose of Report
1.1 The purpose of this report is to inform members that the Environment Agency
(EA) has recently published for public consultation their draft South Essex
Catchment Flood Management Plan.
1.2 This report highlights the issues raised by policies, action plans and supporting
text within the document and proposes a set of detailed comments to the
Environment Agency for member‟s consideration and endorsement.
1.3 The Council‟s response is intended to ensure that all appropriate and possible
action is taken by the Environment Agency to protect areas of the Borough
affected by the catchment areas of the Rivers Crouch, Roach and Mardyke, as
well as other relevant and applicable water courses.
1.4 These recommendations reflect an initial response made to the Environment
Agency under Standing Order procedures in order to meet the consultation
deadline of 26th September 2007. This initial response was made subject to any
other comments that Members may wish to make.
2. Recommendation
2.1 To agree the formal response to the Environment Agency on their draft
South Essex Catchment Flood Management Plan as set out in Appendix 1
to this Report.
3. Background
3.1 EA is preparing Catchment Flood Management Plans (CFMPs) throughout
England and Wales to set future policies for flood risk management. The
South Essex CFMP is a river and water course plan and therefore considers
flooding from all sources except the sea. It includes water courses within the
catchment of the rivers Crouch, Roach and Mardyke and smaller water
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courses that flow directly into estuaries or the sea (including Prittle Brook and
Eastwood Brook).
3.2 It is important to emphasise, however, that the CFMP excludes the risk of
flooding from the sea, and more specifically from the River Thames.
3.3 The Draft document provides an overview of the natural and physical
characteristics, land use and land management of the area. It also highlights
initiatives and policies that may provide opportunities or constraints on how EA
manage flood risk. The key characteristics of South Essex CFMP area are:
low lying catchment with low annual rainfall; some good quality agricultural
land; significant urban areas; and major proposed development along the
Thames Estuary.
3.4 The CFMP then provides information about current flood risk to people,
property and the environment in terms of flood damages, the population at risk
and the environmental features that could be affected.
3.5 It also describes how the EA are managing flood risk in South Essex then
looks at possible changes in urban development, land use and climate in the
future CFMP catchments could affect the current level of flood risk. Finally the
document sets out what the CFMP objectives are. These objectives relate to
health, life, property, material assets, social infrastructure, biodiversity, water
quality, cultural heritage and landscape. The objectives have then assisted in
developing effective polices to manage flood risk and allocate these policies to
different parts of the CFMP area to which a series of actions are then
ascribed.
4. Key concerns and detailed issues
4.1 As far as can be ascertained, Southend on Sea falls within Policy Unit 4 –
„Urban‟ to which the following acceptable policy would apply “to take further
action to sustain the current level of flood risk into the future, responding to
the potential increases in flood risk from urban development, land use change
and climate change”
4.2 However, the main issue with the Draft CFMP is that there is a degree of
ambiguity about whether Southend is within this policy unit. This is due to the
main Policy Unit Map showing the Borough as „Upland‟ where the policy
approach would be unacceptable, i.e. “continue with existing or alternative
actions to manage flood risk at the current level. Accepting that flood risk will
increase over time” which is considered unacceptable. Appendix 1 sets out
the more detailed consideration of these concerns, and this forms the basis of
the initial response.
4.3 It is important to emphasise that Appendix 1 is a technical response. The
nature of the language used in it will be specific, and be delivered principally
for a specialist, professional audience, who will have a detailed understanding
and comprehension of the subject matter; and who will be expecting a
consultation response of this type.
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4.4 In summary, however, the main concerns with the documents are as follows:
Map 6-02 „Policy Units‟ needs to be amended to identify the Borough of
Southend as „Urban‟ to which Policy 4 applies
Southend as the unitary authority is the Planning and Highway authority,
as such where action is proposed in the Borough, it should be cited as
the lead organisation not Essex County Council,
The Council should also have a position on the Steering Group
There are a number of omissions and factual errors in the plan and
suggested amendments are put forward.
5. Corporate Implications
5.1 Resource Implications
a) Finance implications – There is an existing and future role within the
Council as the lead authority in taking forward action plans in
partnership with the Environment Agency in matters relating to flood risk
management options
b) Personnel Implications – In addition to existing flood risk management
operations, there is a need to consider officer representation on the
Steering Group for development of the Final Plan as requested in the
report. There will also be a role for the Council on any future
Implementation Group that will be set up to review and monitor
management and implementation of the Final Plan.
c) Property implications –none
5.2 Contribution to Council‟s Vision & Critical Priorities
The Environment Agency‟s Catchment Flood Management Plan (CFMP) and
associated Actions are critically important to the safety and well being of all
residents and businesses in Southend. The CFMP objectives relate directly to
health, life, property, material assets, social infrastructure, biodiversity, water
quality, cultural heritage and landscape. The objectives have informed the
proposed polices to manage flood risk and allocate policies to different parts of
the CFMP area to which a series of action are then ascribed. Protection from
flood risk will be particularly relevant to supporting the Corporate Priority CP4.
Improve the economic well-being of Southend.
5.3 Consultation
The Environment Agency has consulted widely on this plan including a public
exhibition on the 19th July 2007 at Essex County Hotel.
5.4 Equalities Impact Assessment
The recommendations in this report do not in any way discriminate or
differentiate between members of the community in respect of their age,
gender, sexual orientation, disability, race or religion.
5.5 Risk Assessment
It is not considered that there are any risks associated with the
recommendations made in this report.
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5.6 Value for Money
The recommendations seek to encourage an alignment between the Council‟s
operations as Highways Authority and responsibilities for flood defences and
that of the Environment Agency. In particular it seeks to ensure close
partnership working is targeted in to support the Council‟s Corporate Priorities.
5.7 Community Safety Implications
The CFMP objectives relate directly to health, life, property, material assets,
social infrastructure, biodiversity, water quality, cultural heritage and landscape.
The objectives have in turn informed the proposed polices and action plans to
manage flood risk and allocate policies to different parts of the CFMP area.
5.8 Environmental Impact
The recommendations in the report are based on the principles of sustainable
development now and in the future and considers Flood risk management within
the context of protecting biodiversity and cultural and landscape heritage.
6. Background Papers
6.1 Core Strategy Development Plan Document– Southend on Sea Borough
Council August 2006
7. Appendices
7.1 Appendix 1 – Southend-on-Sea Borough Council‟s Comments on the
Environment Agencies „South Essex Catchment Flood Management Plan‟ –
Consultation Draft Plan - June 2007
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Appendix 1
Southend on Sea Borough Council‟s Comments on the Environment Agencies
„South Essex Catchment Flood Management Plan‟ – Consultation Draft Plan
June 2007
1. Main Issues
Map 6- 02 Policy Units indicates that the Borough of Southend on Sea is „Upland‟
rather than „Urban‟. This is particularly significant because of the differences in policy
approaches proposed for Upland and Urban policy units. For your information
Southend has a population of 159,3001 living in a densely built up area that extends to
its administrative boundary. It is acknowledged that the text of the main document
reflects this, for example Page 12 Section 2.1 states that “the CFMP area lies entirely
within the County of Essex and includes the major urban areas of Southend on Sea,
Basildon ….etc” and Page 70 para Section 3.1 “that the highest risks to people,
property and infrastructure occurs in the towns of Basildon and Southend on Sea”. It is
also noted that Table 6.3 on Page 148 actually includes Southend within Policy Unit 4
– „Urban‟. The issue seems to be, therefore, simply one of map annotation. However,
Table 7.2 „Action Plan – Policy Unit 1 Upland‟ has two specific Actions relating to
Southend and Rochford.
Clearly Southend is urban and being in the Thames Gateway a focus for regeneration
and growth it must fall within the remit of Policy 4 which is “to take further action to
sustain the current level of flood risk into the future, responding to the potential
increases in flood risk from urban development, land use change and climate change”.
It is, therefore, essential that Map 6-02 „Policy Units‟ identifies the Borough of
Southend as „Urban‟ to which Policy 4 refers and that the two actions in Table
7.2 „Action Plan Policy Unit 1‟ should be moved to Table 7.5 „Action Plan – Policy
Unit Urban 4‟.
Also, for your information, the area covered by the CFMP comprises the County of
Essex and the 2 Unitary Authorities of Southend on Sea and Thurrock (Page 12
Section 2.1 refers). This has implications for the proposed Lead Organisations
element of the Action Plan tables in Section 7. For example in Table 7.2 „Action Plan
Upland‟ the proposed lead organisation in cited as Essex County Council Highways
department. Also In Table 7.2 „Action Plan – Policy Unit 1 Upland‟. Southend
Borough Council is the Highways and Planning Authority for the town and should,
therefore, be the lead organisation for all actions within the Borough.
In addition I note that this Council has not been included in the Steering Group
(Appendix D para 3.1 refers) along with Essex County Council and Thurrock Unitary
Authority. As a Unitary Authority with Highways responsibility the omission of
Southend Borough Council from the Steering Group should be rectified. Particularly
as it is the intention to split the urban policy unit further to make sure you have the
1
ONS 2005 mid year estimates
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correct policy for the specific flood risks in each urban area before the final plan is
published. Clearly Southend Borough Council has a role to play in this.
Southend Borough Council as a unitary Authority with Highways responsibilities
should be included within any steering group from now on and identified within
the proposed lead organisations columns in the Action Plan.
2. Detailed Comments
Executive summary
Page 1: Last paragraph
It is noted that EA “have used the results from the Southend watercourse flood risk
study in this CFMP. As far as we know, relatively few properties are affected by sewer
flooding or flooding from groundwater”. – the Borough Council would be interested in
obtaining a copy of this study for or records.
On a similar point it is noted that EA are currently managing tow flood risk studies in
South Essex which will allow a greater understanding of flood risk in Southend on Sea
(Main Document Page 97 Section 6.6.3) The Borough Council would also be
interested to see the results of these studies.
Main Document
1.4 Links with other Plans
On Page 7 there is a list of existing and future plans, strategies and programmes.
Southend is located within the Thames Gateway Regeneration and Growth area and is
a key zone of change and growth. This reinforces the need for adequate flood risk
management of this large urban area. It is noted that there is evidence within the
CFMP that it has been informed by Government policy for the Thames Gateway
Regeneration and Growth Area as set out their 2003 document „Sustainable
Communities: Building for the Future‟ and its daughter document „Creating Sustainable
Communities: Making it happen: Thames Gateway and the Growth Areas‟ (Section 2
page 30 and 31 refers), however, it would be useful to list The Governments
Sustainable Communities Documents within Section 1.4.
On Page 8 there is a list of plans and strategies that have been reviewed in preparing
the CFMP. For your information, the Council submitted its Core Strategy in August
2006 and it has since been subject to independent examination by the Spatial Strategy
accommodating the East of England Plan target an Inspector, including an
examination in public during March and May 2007. The Council received the
Inspectors Report on the 7th September 2007 and, subject to certain changes, the
Inspector has found the Plan to be „sound.‟ The Core Strategy consists of 6,500
additional homes and 13,000 new jobs by 2021. The Core Strategy proposes that the
planned growth should be accommodated within the existing urban envelope. This
has implications for the application of the sequential test in the Borough, in so far as
there is little alternative available greenfield land in the Borough to accommodate
growth other than renewal of the existing urban areas, some of which could be at risk
of flooding.
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The primary focus for regeneration and growth within Southend is the town centre
(including the central seafront areas). Shoeburyness and the existing industrial areas
also have a key role to play. A key driver of economic regeneration in the town will be
the regeneration of London Southend Airport and the proposed and existing
employment areas in and around the Airport. It is noted in Table 3.1 that the Hanger
at Southend Airport was flooded in 1981 and Eastwood Brook was the affected river.
Clearly particular importance needs to be given to the Airport and its expansion plans,
including plans to improve surface access and provide for additional and improved
quality employment sites in the area.
It is considered, therefore, that the Southend on Sea Core Strategy DPD should
be reviewed as part of this study and cited within the list of documents rather
than the Adopted Borough Local Plan.
2.6.2 Urban Development
The Housing figures for Southend in Table 2.7 „Future development – proposed
additional housing in South Essex‟ Page 30 are incorrect.
They should read as follows:
Within Outside
Thames Thames
Area 2001-2021 2001-2011 2011-2021 Gateway Gateway
South South
Essex Essex
Southend BC 6,500 3,350 3,150 6,500 0
On Page 31 there is a summary of the focus of development within the complementary
regeneration hubs in the Thames Gateway for which Local Development Documents
will need to provide for. As stated above the Core Strategy sets out the spatial strategy
for the Borough based on the Sustainable Communities programme. The primary
focus for regeneration and growth within Southend is the town centre (including the
central seafront areas) this includes the provision of 6,500 new jobs and 2,000
additional dwellings. The regeneration of the town centre is therefore more than just
the University Campus.
It is recommended therefore that the 1st bullet point should just read Southend
Town Centre.
To the north of Southend and in Rochford is the London Southend Airport. This
Council supports the expansion plans for the Airport and this is stated within the Core
Strategy DPD. Work has also started on preparing a Joint Area Action Plan with
Rochford to plan for this expansion and associated employment land and improved
surface access. Tenders for the initial phase of the work have recently been
completed and Halcrow Group Ltd. appointed.
Given the Airport‟s proximity to Eastwood Brook and previous flooding
incidences it is considered appropriate to include an additional bullet point for
Southend and Rochford as follows:
Regeneration of London Southend Airport
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2.8.7 Tourism and recreation
Within Southend there are two SUSTRANS National and Regional Cycle Routes. The
Thameside Route (NCN route13/16) from Rainham to Southend (following the seafront
to Shoeburyness) and Bishop‟s Stortford to Southend (Town Centre) (NCN Route 1).
In addition, the Council has recently received approval to progress a significant cycle /
walk route along Prittle Brook from Belfairs Park to Priory Park.
The above significant cycle and walking routes should be described in this
section. In addition Cherry Orchard Jubilee Country Park in Rochford should be
included in Table 2.22 Country Parks.
2.9.2.1 Southend on Sea
It is considered that the first paragraph describing the „past‟ of Southend is
extraordinarily negative and that there is very little information about the current and
planned growth and regeneration in the town.
It is considered that the first paragraph should be reviewed and that the
following text be inserted between the first and last paragraph which details
London Southend Airport regeneration plans.
“Southend is now is a key centre of Development and Change within the
Thames Gateway regeneration and growth project. The focus in Southend is
on cultural and intellectual activities where a great deal of change has
already occurred. The Town Centre is the home of a thriving and expanding
HE/FE campus comprising the University of Essex and South East Essex
College and this has generated a growing cultural and entertainment „buzz‟
around the town and also resulted in new architecturally stunning buildings.
Leigh on Sea is a thriving arts and cultural centre in its own right.
The primary focus of regeneration is the town centre (including the central
seafront areas) where 6,500 new jobs and 2,000 additional homes are
planned. Preliminary work suggests scope for up to 57,000 sq.m of office
space, up to 6,000 sq.m of leisure space, and over 20,000 sq.m of comparison
retail. The Town Centre is also of regional importance for retail and is a
regional transport interchange.
In addition, 1,500 new jobs are planned in Shoeburyness along with 1,400
new homes. The main site of significance in the immediate term is the former
Garrison, which has been granted planning permission for approximately 450
new homes and 25,000 sq.m of employment space.”
The last paragraph should then be followed by the following text:
“Planned major transport infrastructure priorities, include improved
access to Shoeburyness and London Southend Airport, making provision
for South Essex Rapid Transport (SERT) and potential „park and ride‟
schemes.”
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3.6.5 Flood defence asset management
3.6.5.1 Fluvial flood defences
It is noted that on Page 100 it states that with regard to Prittle Brook, the standard of
protection between the head of the main river and the confluence with Aviation Way
falls to below 1 in 5 years (20 percent AEP) and some parts of the River Roach in
Rochford are as low as 1 in 5. The Borough Council consider that 1 in 5 years
protection is insufficient on both rivers particularly due to the risk to London
Southend Airport expansion and associated business development and potential
impacts on Shoeburyness respectively.
It is not clear but it is understood that these levels of protection were calculated in the
1960s and that it is likely that this flood risk will have increased and will continue to do
so due to climate change. This is highlighted in tables 4.3 and 4.4 which show
increase in the height of storm surge for different emission scenarios - using both 1990
levels and climate change respectively. Furthermore the text on Page 116 goes on to
recognise that the latest guidance in PPS25 indicates higher predicted sea level rises
than used in these assessments.
The Council also notes the following recommendation in the recent Report into the
flooding in Hull
“It appears that there are no statutory levels of protection from rainfall flooding.
Design criteria are based on an industry standard of protection from a 1 in 30
year event. We welcome Ofwat‟s current re-appraisal of the design standards
and appropriateness of best practice and behove them to consider the impacts
of climate change”.
These considerations exacerbate the Council‟s concern about the current 1 in 5
level of flood protection and the impact on climate change on future protection.
3.6.5.2 Tidal flood defences
In paragraph 3.6.5.1 it states that Figure 3-08 shows the location of flood defences that
EA operate. This figure indicates that this includes the sea defences within the limits of
Southend on Sea Borough boundary. It should be noted that Southend on Sea
Borough Council are responsible for most of the sea defences in the Borough, with the
exception of the revetment along the Cinder Path in Leigh which is the responsibility of
Network Rail. Clearly paragraph 3.6.5.2 and Figure 3-08 should recognise
Southend Borough Council‟s role and responsibilities with regard sea defences
and provide information of quality and level of that defence.
3.6.6 Flood incident management
It should be noted that Southend Borough Council have commissioned a „bespoke‟
„Real Time Early Warning System that comprises a computer model that will calculate
risk of flooding using EA severe weather warning information. We notice with interest
on Page 102 that EA are developing National Flood Forecasting Systems (NFFS) to
provide fluvial and coastal flood forecasts. It is considered that the NFFS would have
the potential to impact on the Council‟s system and we would welcome some element
of joint working to ensure the Council‟s system is compatible and able to be enhanced
by the NFFS.
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6.2.1 Policy Units
It is noted that it is the intention to split the urban policy unit before the final plan is
published and replace with the following policy units:
Purfleet
Stanford-le-Hope
Basildon and Wickford
Rayleigh and Southend on Sea
The Unitary Authority of Southend on Sea, as the Planning and Highways
Authority for the town, would wish to be included within the Steering Group to
assist in developing the final policy approach in the Southend Area.
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