Consultations on both the draft river basin management and flood risk management plans give CaBA partnerships the opportunity to provide their views on long-term objectives for the water environment and measures to achieve them, and to help inform plans and actions to manage flood risk. These resources provide an overview of both consultations and provide guidance on responding.
The deadline for the FRMP is 21st January 2022. Find out more here.
The deadline for the RBMP is 22nd April 2022. Find out more here.
This webinar provided an overview of both consultations and provide guidance on responding. Hear from the EA, the CaBA Support Team, and Blueprint for Water.
This section is based on questions from our January webinar.
It’s great coordinating FRMP and RBMP’s but plans, strategies and overall direction of travel needs to go across all government policies and departments. How is this going to be addressed?
Good point, but we have multiple strategies all running in parallel, DWMP’s, WRMP’s, Regional Water Management Plans and, as you, say government polices in development all working against each other. (EA)
Where can we see the economic appraisal of proposed and additional measures in draft FRMP and RBMP and how can we comment on them to ensure good value for inevitably constrained money?
RBMP applies economic appraisal to inform the setting of water body objectives, under Regulation 17. It is the different objectives that are appraised. To appraise objectives, the Environment Agency assessed whether the benefits to society of an improved water environment are greater or less than the costs of the most cost-effective (i.e. cheapest), technically feasible solutions required. If there is sufficient evidence that costs are greater than benefits then Ministerial guidance on river basin planning says there is sufficient justification for setting a less stringent objective, on the grounds that costs outweigh benefits. This is known as the default objective being disproportionately expensive due to an unfavourable balance of costs and benefits. These account for around 1% of the proposed water body objectives that are currently being consulted on in the draft river basin management plans.
Summary programmes of measures are presented in a number of ways and locations in the draft river basin management plans. The guide to the draft plans and the programmes of measures section of the summary document describes this. In terms of ensuring value for money for specific projects, this is something that is not part of drafting the updates to the RBMPs; rather it is about how they are implemented and how the agreed objectives in the RBMPs are achieved. Objectives should be achieved in the most cost-effective, cost-beneficial way – the RBMPs do not constrain the measures that can be implemented, so more cost-effective and/or cost-beneficial solutions can always be proposed as better ways to achieve objectives as evidence and understanding of projects improves. In some cases, although a less stringent objective has been set, action will still happen to improve the water body to the best possible status, as required by regulation 17(3) and (4). You are encouraged to contribute to project design and appraisal by working with local catchment coordinators, catchment partnerships or other stakeholders responsible for delivering measures. (Vicki Betts, EA)
There is a massive mismatch between the timescales for approval of RBMP (which will presumably drive WQ improvements for the next 6 years) and WINEP (for which we are already doing development work and in respect of which the EA guidance is still not – at least officially – available). Can we have some insight into how this mismatch is being addressed?
At the moment what we have for the current WINEP is in there and the future WINEP that will go into the final plan I believe. If the detail isn’t available to go into the final plan then they’ll be a sort of overview. I believe that’s how we are going to deal with that, I don’t think we know yet what the timeframe is on getting the detail. (Claire Reece, EA)
In the last cycle we got many of the over abstracted chalk streams into the WINEP via the CaBA process. However it appears these are now are 100% owned and delivered by Anglian Water and there isn’t a process to share delivery across partnerships. So my question is really does the current WINEP process allow a partnership approach for investment in green recovery?
The water industry national environment programme (WINEP) process follows the UK government’s 5 environmental principles for building a greener future with the aim of offering the best opportunity to achieve environmental improvement.
The WINEP methodology sets out the overarching process for designing, developing, and delivering the water industry national environment programme (WINEP) for England. There is a collective ambition for the actions within the WINEP to enable greater delivery. More for the environment, for customers and for communities, reflecting society’s high expectations and the UK government’s own ambition to leave the environment in a better state for the next generation.
We expect water companies to engage with partners throughout the WINEP process on co-designing, co-delivering and/or co-funding the WINEP actions. (James Cope, EA)
Is there a guidance document that outlines why some measures are in the summary programme and others are in the potential additional list, and others are not included at all? I understand the high/low confidence distinction, but there are some measures in the ‘potential’ list that are fairly certain to happen, and others (including regulatory measures) which are missing completely. It would help to understand the logic for this.
I don’t know if you’ll remember when you were doing the catchment partnership pages, they were set out at two different levels. So the confident measures, which are those ones for question three are more around where there is an action that has been identified or location has been identified for it to be delivered, some funding has been identified and a way of delivering has been identified. So they’re things that are definitely going to happen in the next six years. So, unfortunately a lot of those are relatively restricted but they’re the only ones that we have absolute certainty that they will be delivered. That they are in the plan and they have got everything they need and those additional ones, they might be fairly confident, they might have a great plan, they might have funding proposals in, but maybe that funding proposal, has not yet been excepted. Or it might be with land owners where land owner permission hasn’t yet been agreed, something like that. So, although they are very likely to happen, they’re not definitely going to happen. That’s why they haven’t then been used to improve the objectives of those water bodies with the timeline for those water bodies. (Claire Reece, EA)
Also, I’ve noticed that the measures on the catchment pages are not listed in the full measures list. Can you advise how the catchment level measures fit in to the overall plan if they are not included in the ‘master’ list?
The WFD regulations require the draft RBMPs to provide a summary of the Programme of Measures, rather than detailed ‘full lists’ of measures. Within this summary, the key programmes that catchment partnerships utilise to deliver projects are given at an RBD level (e.g. Environment Programme, FCERM Programme and Heritage Lottery Funding Programme). Within the draft RBMPs we have a few locations where measures are reported, these include 2 spreadsheets of measures within the programme of measures section, but also include the Catchment Partnership Pages measures. The programme of measures sign-post to other sources of information where more detailed measures information can be found, particularly via the ‘Catchment Pages’ and associated hyperlinks to Catchment Partnership action plans. All these lists are valid measures for the plan, there is no master sheet. (EA)
Overall latest government data shown in the State of Our Rivers report put agriculture and water companies relatively equal contributors to pollution. I would consider manures management use and storage as well as slurry is a key measure to reduce risk. Key is also the management and health of agricultural soils.
This statement agrees with what is in the draft RBMPs, Section 5.5.2 Summary document on Rural Land Management measures, which highlights the importance of soil measures saying:
• “improving soil management to reduce the loss of soil, phosphate and nitrogen
• “improving management of animal slurry and manure to reduce pollution from phosphate, nitrogen and faecal organisms” (EA)
What about asking about future opportunities to delivery as well as risk to delivery?
The draft Plan consultation does try to elicit responses from stakeholders on future opportunities to improve delivery, particularly in relation to:
• The Implementation principles. These set out key principles we hope stakeholders can adopt when implementing water management initiatives (e.g. collaborative working, source to sea, adopting nature based approaches and building resilience etc.). We ask partners for views on these principles and hope to identify opportunities for improved working
• We also ask for views on the Programme of Measures, and associated potential additional measures which are currently unfunded. We ask for views on these and any other measures (i.e. opportunities) they may be aware that might help deliver the plan objectives.
• Similarly, the Catchment Partnership Pages question requests responders to identify new measure opportunities where additional support, resource, funding or ideas can be identified as well as ways to remove the barriers identified by partners. (EA)
Having looked at Flood Plan Explorer, there are no plans covering the Broads. Where are the outcomes from the Broads Futures Program, which was set up to deliver a plan for the Broads. What has the £1.2m investment into BFI actually delivered, if they are not part of the overall FRMP?
There is a long term proposal to identify an appropriate strategy for future management of the Broads. When the flood risk management plan (FRMP) measures were being developed, the Broadland Futures Initiative (BFI) was in its initial phase, but proposed measures were included to be able to track progress of the project during the lifecycle of the FRMP and update measures as the project developed.
In preparing the draft Anglian flood risk management plan, a number of relevant plans and strategies were reviewed, including the evolving BFI.
There are 3 proposed measures associated with the BFI included in the draft Anglian FRMP, and within the Broadlands Rivers management catchment.
These proposed measures can be found on the new online mapping tool Flood Plan Explorer (FPE) which forms parts of the FRMP consultation. The BFI proposed measures have these IDs (0200605030, 0200605029, 0200605028), which you can type into the search function on FPE (select the ‘Measures’ tab after searching to select the measure).
To note: Not all proposed measures have precise locations. Sometimes measures relate to the whole scale boundary. Sometimes specific locations can’t be shared for privacy or confidence reasons. To see all measures associated with the Broadland Rivers Management Catchment, click the ‘Broadland Rivers’ link on any of the above measure pages, or click here to go to the page directly. (EA)
Importantly, the plans can support strategies to reduce climate change.
Measures have been developed in flood risk management plans and river basin management plans to support both communities and the wider water environment to adapt to the impacts of climate change. Working together provides the best opportunity to protect and enhance the water environment and leave it in a better state for future generations.
For FRMPs, climate change was taken into account when developing the proposed measures to achieve the objectives for managing flood risk. The objectives are consistent with the National FCERM strategy ambitions of:
Is it helpful through the consultation to have a few examples where the approach of FCRM vs. RBMP teams in the EA do not marry up in terms of approach to delivering benefits and how much flexibility FCRM are willing to allow to meet RBMP targets?
The Environment Agency works with lead local flood authorities and other risk management authorities to develop joint measures to reduce flood risk and improve the wider water environment. Measure feasibility and design will endeavour to maximise flood protection and environmental enhancement. We’re always looking for solutions that, are the most cost-effective, efficient and that deliver the most benefits for nature and people in the catchment. We welcome partners’ help in designing the best projects possible.
On 17 April 2020 Defra announced a number of changes to further improve the way government funding is allocated to flood risk management schemes. This includes a recognition of the wider benefits that flood alleviation projects can bring. On 2 September 2021, Defra and the Environment Agency also published new guidance on partnership funding for flood and coastal erosion risk management (FCERM), to reflect these changes. This includes improved payment rates for environmental benefits to better capture the wider environmental benefits achieved by some flood schemes and encourage environmentally beneficial design
FCERM capital funding eligibility is determined by the FCERM partnership funding calculator and associated guidance. The economic benefits used to justify FCERM funding must mainly relate to avoiding flood/coastal damages, but other benefits, including environmental benefits, may make up a ‘reasonable proportion’ of benefits claimed by a project.
Changes have been made to Outcome Measure 4 (OM4) in the Partnership Funding calculator for the FCERM investment programme that started in April 2021 to enable environmental benefits to be more easily integrated into FCERM projects. These changes include a new OM4b which attracts payments for physical improvements to river environments and is intended to help FCERM projects to deliver river basin management plan outcomes. (EA)
“What organisations are prepared to do…?” has been asked a couple of times.
Surely the questions should be “What needs to be done…?” without involving any individual organisations’ willingness and/or abillity to deliver?
The draft RBMPs set out what needs to be done in terms of the environmental objectives that should be achieved, and summarises the Programme of Measures needed to achieve them, including potential additional measures. Within the consultation questions we endeavour to determine which of these actions partners are prepared to help take forward, as not all the required action is currently funded.
The draft FRMPs set out what needs to be done through the objectives for managing flood risk and the measures proposed to achieve those objectives.
The Environment Agency and other risk management authorities will work with partners and communities to carry out the measures. We ask a question within the consultation on ways in which consultees think they could support the delivery of the measures as set out in the draft FRMPs.