Removal of Melbourne Park Weir by Eden Rivers Trust?

 To

Cumberland Council

Planning Application 23/0225 – Removal of Melbourne Park Weir by Eden Rivers Trust.

Objection from Carlisle Flood Action Group

We write further to our initial comments of 4 April 2023 having now had a meeting with representatives for the Applicants, their principal sponsor (the Environment Agency) (EA) and Cumberland Council (weir owners). This meeting took place on 20 April – names can be supplied if required.

The meeting was very helpful for us in focusing upon the intent of the Applicants project and allowing discussion in respect of potential impacts upon our wider concerns to lower flood risk and how such issues may be mitigated. It was however clear to us that there was insufficient detail and control being exercised for us to withdraw our objection.

On a procedural front we are concerned that the main sponsor for the project is the EA ie. the same agency that the Authority (LPA) looks to for independent consultee advice on such matters to check the Applicants submitted reports and calculations. We have called Philip Carter (planning consultee at the EA) regarding this aspect but he has not returned our calls. There is clearly a conflict here which concerns us considerably. Whilst Cumberland Council, itself, is both asset owner as well as being the presiding statutory Planning Delivery Authority we have seen no particular strength of feeling to suggest the same level of conflict however taken together it is also less than ideal. Fundamentally it is inappropriate to base an important decision judgement upon the advice of the Applicants own sponsor. As we, as a group, are not sufficiently funded to instruct independent advice ourselves, particularly within a planning application time frame, it seems entirely appropriate that the LPA delays any decision until a suitably qualified independent expert can supply an opinion. Such an opinion we believe should include the matters raised here in our objection, not just the documents submitted due to the sensitivity of the location and the potential impacts including another Storm Desmond scale event.

Use this link for the full PDF 

https://drive.google.com/file/d/1OJBKIIMALDJVcCcovb1G8f5ZHdmMM7X-/view?usp=sharing

If you missed the ActionFlood meeting .....

 We covered all the issues surrounding the Carlisle catchment area. We also covered our general dissatisfaction with the Environment Agency, Local Councils , Ministers.

What surprised us most on the evening was the fact that the EA have been in discussions with the allotment holders at the top of Melbourne park as they are indicating that this area will become part of a storage area if there is a flood. 

They are also intending to hold a consultation on this on the 15th February at Greystone Road Community Centre. 

The weir removal at Melbourne park is subject to a Eden Rivers Trust consultation in March. 

We have serious concerns that the correct procedures have not been followed and we will challenge their methodology.

We showed the slides which clearly demonstrates the build up of the river bed from the 1960s to the present day.

We also discussed the vulnerability of the bridge itself and the potential catastrophic effect it would have on the city.

We then discussed Holmehead weir and again those present were very concerned about the ERT proposal to remove the weir. Listed status was discussed and riparian responsibility and luckily residents and owners adjacent to the weir were present .

We also discussed the Phase 3 measures for Carlisle which seem to have been put on the back burner due to a lack of finance.

The actions from this meeting are as follows:

1. Attend Feb 15th event at Greystone Road. EA consultation.

2. Follow up on the recommendations from the 2016 DEFRA select committee. We should contact the secretary to find up if the recommendations have been followed up.

3. Attend the ERT consultation in March on the Melbourne park weir removal.

4. Speak to local councils re planning applications.

Flooding , Wont happen? 26 January 2020 6.30pm Botcherby Community Centre

 

Flood Action, still in action

 John Kelsall, an observer representing CRAGG, Carlisle FLAG and Board member of the Cumbria Strategic Flood Partnership spoke in summary of the focus presentations

JK recalled when he was last at Brockholes he had given a talk on the experiences of Carlisle during and after Storm Desmond and the potential for how the planning system could reduce flood risk. He had advanced the idea of making all natural flood plains distinct areas of limited development to counteract the legal effect of ‘precedent’ which allows infilling of these areas where development of a traditional nature should be receding from them further to protect from flooding. The concept is yet to see support from the RTPI and Government.

Of the presentations, Andrew Egerton’s will resonate with CRAGG’s own experiences. AE had emphasised particularly the aspect of losses in community trust when experiencing repeat events without effective and timely positive actions. JK suggested Carlisle was a particular case in point when 1600 houses were badly flooded in 2005, resulting in extensive EA investment in protection only to have 2200 houses flooded at least as badly in 2015 – community trust remains very low.

JK agreed with Andrew’s need to measure success by ‘outcomes’ however with much of flood alleviation being seen coming from Nature Based Solutions (NFM) ‘outcomes’ will be difficult to measure and way into the future. Actions that have early, positive, measurable outcomes are what is needed.

CRAGG encompasses the views of many FLAG’s that have gone through the same painful learning curve as South Lancaster. We need to try to short-cut this process with information resources that are more relevant than available through the Flood Hub. CRAGG, in this regard, is several years ahead of SLFAG simply because it started earlier and we need to save the time of, or speed up, duplicate learning so we can pass this experience on to those who need it.

Coming particularly out of the Storm Desmond experiences JK emphasised a clear need to maintain our river systems from their outfall, up through the respective catchments. This would promote early measurable outcomes that would benefit Andrew and many FLAG’s like his. Blockers to this straight forward approach appear to be principally the law in the form of the Wild Life Act and Natural England where serious conversations need to be made to enshrine the compromises now needed within new legislation. This aspect has recently been raised by Keith Ashcroft during discussions last month on the surprising demise of the Cumbria Strategic Flood Partnership.

JK urged the committee to take regard of the points raised. If, as communities, we do not call upon our politicians to account the required law changes will not come forward and our RMA’s will be hamstrung and continue with one off projects unable to initiate the maintenance progress that is long overdue.

Heavy rain is expected in the Eden catchment on 30 Nov/1st

“Heavy rain is expected in the Eden catchment on 30 Nov/1^st Dec but the EA wish all those with power outage not to be concerned of a flood event as flows are expected to remain in channel – any one with power who knows of others close by without may wish to pass on reassurance”.

You now know what we know. 

Vote of No Confidence in Environment Agency Flood Management- CRAGG

 

The EA is failing communities at risk of flooding. Flood risk has 3 main elements, precipitation, water management and flood protection (where management cannot be met). The EA has a responsibility to take a strategic overview of flooding however it operates a strong bias toward individual capital defence projects over management of water resources (water bodies, water ways and above and below ground flows) for which it appears to have no strategic maintenance regime to help reduce flood risk.

Full report in the link below, if you prefer to be emailed a copy, please contact us

https://drive.google.com/file/d/1EqGxr2xcuu55bLumEbDJ3BnTRfZSGs09/view?usp=sharing

Flooding , HoC Forth Report 2019 -2021

 

The full report is in the link to the pdf file below

Our view is 

It appears all the problems with this report can be seen from the Summary – EFRA have simply been looking in the wrong direction in respect of our perspective.

 

Like the EA and like the Government generally EFRA falls into a blinkered “understanding trap” and  makes a tacit acceptance that all in the water-world is currently mostly rosy and the challenge for policy and required action arises from climate change and funding defence deficiencies only ie politically it is easiest to blame the weather  – no consideration as to how our natural water systems can be improved or how to attack flood risk at source (rivers and water bodies not rain!).

i. Experiences of the 2019–20 floods

10. There were some suggestions that the immediate operational response to the floods of the autumn and winter of 2019–20 was less well-organised than in previous years, with some issues around speediness and communication. Regional variation in experience was noted.

11. The importance of support for communities to recover, after the immediate period of flooding has passed, was emphasised. The impact this year of covid-19 was noted, including on the ability of authorities and insurers to contact those affected. The pandemic had also impacted the ability of people to return to flooded homes in a timely manner.

12. The mental health impacts of flooding were particularly emphasised, and some participants vividly described the fear and anxiety that living with flood risk can bring. The uncertainty brought by the coming winter, in the context of a second wave of covid-19, were noted.

ii. Confidence in risk management authorities

13. Concern was expressed at the perceived fragmentation of responsibilities for flooding among various bodies, and a lack of accountability regarding who is responsible for what.

14. Some participants expressed frustration at how long it can take to deliver local flood resilience measures. It was also suggested that flood action groups can sometimes deliver schemes faster and at much reduced cost compared with risk management authorities. It was felt that engagement with local communities should be seen as an investment, not a cost.

15. Riparian ownership was discussed, both the lack of understanding of responsibilities among owners, and a lack of enforcement of these responsibilities by local authorities.

16. It was felt that investment in maintenance of drainage infrastructure is inadequate, and that Ofwat may have a role to play in improving this. It was also suggested that reservoirs could play more of a role in managing flood risk.

iii. Development and flood risk

17. A greater role for local knowledge of flood risk in planning decisions was seen as important. It was also felt that the downstream impacts of development can be ignored in planning decisions.

18. Local groups can feel disempowered by the planning process, which several participants felt was ill-equipped to factor in flood risk and drainage implications in the face of other pressures and a lack of capacity and knowledge within planning authorities.

19. Participants highlighted problems with the delivery of sustainable drainage systems (SuDS) by developers, as well as with their long-term management and maintenance. Some suggested that the approach of SuDS Approval Bodies, envisaged in Schedule 3 of the Flood and Water Management Act 2010, would be an improvement.

https://drive.google.com/file/d/1d0yC7NAvOs3SzZbz10RnzHVjSpQPkuIq/view?usp=sharing