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Flooding Bombshell

Flooding BombshellThe Queensway Inquiry has thrown up some shocking information about flooding - and quite possibly about the withholding of information by Fylde's officers.

We'll begin with a review of flood prevention measures along the coast, then look at Fylde in particular.

Back in 1993, Blackpool produced a strategy to address flooding concerns. That strategy was updated in 2004, and we've all seen the works that Blackpool has undertaken to improve its sea defences, and address concerns about flooding and predicted sea level rise.

In 2010, that strategy was updated again, and this time, Fylde was included within the study area.

This 2010 study was commissioned from a expert company called Royal Haskoning. The strategy was published in August 2011 and was opened to public consultation until November 2011.

It's a very technical and solid piece of work which, in essence, concludes that the centre of Blackpool is now more or less OK but there are some concerns - especially about Fylde and also about the areas north of Blackpool.

The aim of the plan is to look forward 100 years and see what sort of risks will arise and what sort of management of coastal defences will be needed.

As a result of the plan, Blackpool and Wyre councils have set aside a budget of £70-£100m for the rebuilding of sea defences at Anchorsholme and Rossall, and have just gone out to tender for that work. No doubt officers at Blackpool and Wyre have collaborated to quite some extent to reach this stage.

There are also some recommendations made in respect of Fylde Council's area and we've no doubt these have also been prepared in discussion with technical officers at Fylde who have responsibility for planning and coastal defence

As with all comprehensive plans, the report includes a 'What happens if we do nothing' scenario, and that's quite a frightener.

You can click this link to see a graphic we've extracted from the report.

At present, you can also see the various parts and appendices that make up the whole report if you Google "Blackpool And Fylde Coast Protection Strategy"

(The report was on Fylde's website, but now the consultation period is over, it seems to have been removed).

If you do look at the flooding graphic above, please remember that it's based on nothing being done to the existing flood defences for the next 100 years or so; it uses the results of an extreme tide; and it takes account of global warming and sea level rise (and there are folks - including us - who are sceptical about the extent to which that will happen)

We make those caveats so as to set the graphic in context. The 'do nothing' option would introduce a lot of flooding into residential areas in Lytham St Annes and South Blackpool, but, as is often said, in this case, doing nothing is not going to be an option, so there will almost certainly be coast protection works to prevent the situation in the graphic from arising.

Our message here is that it's important, but there's no need to panic.

Our point of reproducing the graphic above is to show where the most vulnerable areas are likely to be, and to show that Fylde's officers have been working with Blackpool and the Consultants (as they should have been doing) in the lead up to the publication of this latest study.

We're quite happy about that.

What we're less happy about, is what we believe to be some of the 'spin-off' from that study apparently being held back until after the Queensway inquiry.

As part of their evidence to the Queensway Inquiry, local campaign group QED  submitted a 90 page technical objection to the Queensway scheme. We found it on their website at www.queensway.org.uk.

Toward the end of that report, (at paragraph 6.105) is a section on flooding, and it refers to a revised draft Fylde Borough Strategic Flood Risk Assessment (SFRA).

It seems that this assessment has been prepared for Fylde by officers from Wyre Council (by whom the previous, and indeed current, SFRA was prepared). But we also think that Fylde's officers will have had a hand in this assessment being produced, as they will  with the Blackpool report.

QED's report reproduces a map from Fylde's draft SFRA report, and we've reproduced that below.

Map from Draft SFRA report

It shows in red the areas that were included in Fylde's Strategic Housing land Availability plan for Lytham St Annes.  According to QED, the draft SFRA report  makes changes to the boundaries of the floodzone areas. QED quote the following changes from the draft Fylde SFRA report

“As at July 2011, taking into account the changes to the flood map -

  • Site 15 in Warton, Site 17 in Freckleton, Site 6 in Newton-with-Scales and Sites 31 and 32 in Lytham Moss are now all within Flood Zone 3, after previously being within Flood Zone 1.
  • Sites 23 and 24 at Marton Moss are now within Flood Zone 1, after previously being within Flood Zone 2.
  • Site 26 at Pontins is now in Flood Zone 1, after previously being within flood zone 2.
  • Site 21 at Whyndyke Farm is now within Flood Zone 2, after previously being within flood zone 1.”

Now, what our readers really need to know is  - what does all this this mean?

Well in crude terms, a site in floodzone 1 can have more or less anything built on it. It's at low risk of flooding.

A site designated floodzone 2 is at medium risk of flooding and shouldn't usually have domestic residential property, but some sorts of residential property (typically institutionalised residential property), and non-residential property can be built on it.

Floodzone 3 is subdivided into (3a) which is at high risk of flooding and can have very limited property built on it, and floodzone (3b) which is classed as the 'functional floodplain' and, by accident or design, is routinely allowed to be flooded to prevent the flooding of other land.

The full descriptions and definitions of floodzones are in Annex D: toward the back (P21) of the Government's Planning Policy Statement 25.

For Fylde, these changes mean that some sites (those going from zone 2  to zone 1) will be reclassified as suitable for building, but some parts of Warton, Freckleton, and Newton-with-Scales (we don't yet have those maps) are moving from 'can have anything built on it'  to become, in effect, 'no housing should be built here'

Crucially, for the Queensway Inquiry, it means that site 31 on the map above - which is approximately half of Kensington's planned housing scheme - is also about to be re-classified as probably 'not suitable' for residential development and needing further and more detailed studies to arrive at a final decision.

From what we can see it will also mess up plans for LCC's road across the moss.

So, if Fylde and Wyre's officers have been working on a strategic plan for flood prevention in Fylde over for the last 12 months or more, and they knew that the Queensway Inquiry was about to start,  why didn't they announce the revised floodzone plans so that they could be formally taken into account at the Inquiry?

Well, the report also said that some changes to the SFRA have been requested by the Environment Agency (to make it more clear when further and more detailed risk assessments need to be carried out on sites in Fylde), and some other changes described as 'minor amendments' were also necessary.

It's just possible someone thought: "Well there's no point in making the changes widely known at this stage because there are going to be other alteration made" - albeit quite small ones, "So we're better not encouraging people to read it now" - even though they were being asked to approve it.

We quite accept that's a possible scenario, but to us, the whole situation has a different feel.

One of intentional withholding of information.

That's because at this point,  the plot seems to get even thicker.

We know they haven't made it public yet.

But in fact, quite the opposite seems to prevail.

Not only have they not published it. They seem to have tried to hide the details it from their own Councillors as well, whilst at the same time asking them to endorse the assessment.

Yes, really.

In November 2011, the revised and updated Strategic Flood Risk Assessment for Fylde was reported to Fylde's 'Local Development Framework Steering Group'

These are the folk who Fylde's officers consult about their work as they go along the path of preparing the new local plan. The Group is made up of Councillors, officers, and Bernard Whittle - (Chair of the Local Strategic Partnership).

The officer's report of 21 November reminded Councillors that the first SFRA had been published in June 2008, but it was now out of date because the Environment Agency had revised its flood maps, so it had been necessary to update Fylde's SFRA in line with the updated flood maps.

So far, so good.

The report presented to Councillors gave even less description of what a floodzone was than we have given readers above.

That's not a good start - because it doesn't give Councillors the details about floodzones that they need  to make informed decisions. And at this point, you start to wonder of they're not being told the whole story.

It also said "The SFRA identifies a number of potential sites which may have some future development potential. To provide guidance for developers, the SFRA sets a framework for development of the sites in relation to the flood zone they are situated in. However, as the flood maps have changed, some of the sites are now in different flood zones. This has meant that the document has had to be updated so that the sites correspond with the correct flood zone."

It goes on to say "the updated Flood Zone Map for the [Fylde] borough is now included in the SFRA."

But that map wasn't provided to Councillors. So whilst the report said things had changed, it doesn't seem to have given the details of those changes to the Councillors who were being asked to endorse the changes.

The Officer's report concluded "The updated SFRA provides an up to date assessment of flood risk in the borough, taking account of the updated Environment Agency Flood Maps."

And the recommended action was "That the updated SFRA is endorsed by the LDF Steering Group"

But amazingly, it appears that the actual Strategic Flood Risk Assessment report itself was not presented to Councillors.

We've checked with three Steering Group members who told us they were just given the officers report, No SFRA report, no maps, and no details of changes to the floodzones - before being asked to endorse the report they hadn't actually seen!

The minutes of the following meeting (19th December 2011) record....

"7. Strategic Flood Risk Assessment
Matthew Park (Planning Policy Officer) presented an updated report on the Strategic Flood Risk Assessment (SFRA) which was originally published in June 2008.

Mr Park stated that the purpose of the SFRA is to set out the potential levels of risk from flooding throughout the borough. The document formed an important part of the evidence base for the Local Development Framework. He went on to say that since the SFRA was published, there had been changes to the Environment Agency Flood Maps and it had therefore become necessary to update the SFRA in line with the updated flood maps.

IT WAS AGREED to endorse the updated Strategic Flood Risk Assessment."

Now you might think that when a report goes to a Steering Group and asks which option or direction should be followed, the officers are doing what they should do - checking with elected representatives to see that the direction officers are taking is satisfactory to the Councillors.

And you might also think that when a report is presented to Councillors for 'Endorsement' it has reached a stage where it is final - or at least substantially final except for proofing and minor changes, before it is reported to Cabinet or, if it is a policy document, to Council.

That's what we think. We also think that councillors trusted their officers and duly endorsed the report without even seeing it.

So how can that be? How can Fylde's officers get away with something like that?

Well, what might have happened, is that one of the standard 'Document information' tabulation boxes that Fylde uses at the end of all its reports, contained a link to the updated flooding report from Wyre, and said it was available in the Planning Offices, but the officers hadn't included reference to it in the report itself and they hadn't provided the report separately.

Link to information

It can thus be said that Councillors were given access to the information if they chose to follow it up.

Without doubt, officers know that Councillors (and the public) don't generally read those boxes at the end of the reports. Councillors (and indeed most people) regard those boxes as something administrative that are for the officers to use.

So for a while, it seems the SFRA was on Fylde's website, and probably being found in Google by people searching for flooding in Fylde, and maybe that's where QED found it, but it has since been removed from Fylde's website.

If our assumption about withholding is right, then we could have a monumental con-trick being played on the elected Councillors themselves, and you have to wonder why that might have been done?

Where have we seen that sort of thing going on at Fylde before and leading to disaster?

Oh yes, most recently at Melton Grove, and at several Council meetings before that, where we reported one of our readers telling us that Fylde's officers were "out of control" and we had to agree.

So, if it *was* officer chicanery, why would anyone want do that?

Why should the fact that half the Kensington site probably isn't going to be fit to be built on be withheld from the public area when a Public Inquiry is trying to evaluate how important flooding is?

Well, putting aside the obvious 'brown envelope theory' that will probably come to people's minds (That's not as common as people think. In four decades of experience in local Government we only ever came across that situation once - and even then, it wasn't accepted, and the person making the offer was reported the Council's audit department the following day), the more likely reason is that someone thinks they know best as to what's good for the area, and the matter is too complicated to trust to elected Councillors.

We're pretty much appalled when something like that happens. We also figure that if we turn out to be right (in what, on this occasion, we freely admit are mostly unsubstantiated, but fishy-smelling assumptions about motive), the Councillors involved probably won't be best pleased  either.

That was the end of this report until yesterday. But we had asked FBC about a Steering Group agenda for September that was missing from the list that the search engine on their website returned.

Yesterday we had a reply to say that the agendas and minutes we had seen (and downloaded) were not technically those of a 'Committee' and they should not have been published on Fylde's website in the first place - so we can't have the missing one, and they have now removed the others altogether.

That means there isn't even a reference to what's being hidden any more.

But as we said, the agendas were published openly on Fylde's website. We found them there just by a search engine inquiry. We think that makes them public documents and we say Fylde should re-instate them on their website.

Not doing so makes it look even more like a conspiracy than it did before.

So we call on Fylde to come clean to the Councillors it is supposed to be serving, and to come clean on the new Strategic Flood Risk Assessment that could change the face of the Queensway Inquiry

And to so so with a sense of urgency.

Dated:  11 January 2012

See the Queensway Inquiry Mk2 report of 11 January from one of our readers who attended the Inquiry yesterday for an update on this matter.


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