I was prompted to express my concern regarding an apparent shift to hard engineering solutions on the basis of my role as Fishery representative on the drainage council. I have a desire to work towards sustainable flood management whilst ensuring fisheries and their ecosystems are protected to provide future value to community fishery and ecosystem goals.
My concerns include a potential weakening of synergy between Water Framework Directive and Floods Directive targets, in light of the potential disengagement from Europe. Although legally binding, European agreements will remain in place at least for duration of transition to Brexit, if it happens. I feel that the Brexit agenda may threaten the dual goal of flood management and the achievement of good ecological status in the context of the Water Framework Directive goals and the local programmes of measures. On the other hand it may provide an opportunity for a more holistic, catchment based view of flood management beyond the reductionist agency approach to flood management. However without a locally democratic facility such as that provided by Stormont there may be a temptation for the departments to push ahead with their own agendas without the wider consultation approach provided by a locally operating legislative assembly.
Consequently there may be an emphasis on hard engineering solutions to symptomatically fix flooding problems to encourage development on flood plains as opposed to treating the cause of flooding which includes neglect of catchment wide approaches to flood management.
I agree that all flood issues impacting on people’s lives and livelihoods need to be taken seriously. Hard engineering solutions such as walls, sheet piling and culverts provide essential solutions to flooding problems. However, consideration of full catchment wide analysis including upper flood plain management as a means of holding back water and slowing down run –off needs to be fully evaluated in addition to hard engineering schemes implemented at the problem location.
Catchment wide softer approaches such as effective use of upper flood plains, bog re-instatement, deciduous tree planting to hold water back are likely to maintain or enhance ecological potential. Softer solutions may be beneficial when they provide for wider ecological/ environmental value considerations and key water Framework Directive goals. The role of Climate change on catchment wide processes also needs to be more fully investigated. Understanding current data gaps and a consolidated data collection process to inform decision-making needs continual development.
From a fisheries point of view routine maintenance can often work against ecological needs of an in stream fishery. Rapid structural change over-layered on slow ecological processes can have ecological impacts on fisheries. Salmonid abundance in particular can be severely impacted by hydro-geomorphological changes. However it is agreed that the risks and benefits need to be appropriately evaluated.
It is relatively straightforward to quantify the impact on those directly affected by flooding both economically and socially. It is more challenging to evaluate the potential opportunity to local and wider communities of the ecological potential gained form solving a flooding problem holistically and at a catchment wide level.
Shimna Scheme as an example
The Shimna Environmental statement included the following paragraphs below in italics
The FRMPs focus primarily on areas which have been identified as being at potential significant flood risk. As these are predominantly urban areas, any reduction in flooding as a result of implementing measures, may also reduce the risk of pollution incidents given the fact that flooding often results in pollution problems from oil tanks, sewerage overflows, etc. The development and implementation of measures proposed under the FRMPs also provides potential opportunities for more natural flood risk management (e.g. improving floodplain storage, re-establishing connectivity, fish passage, sediment continuity, morphological and other enhancement of watercourses etc. during capital works). Collaborative working by personnel and stakeholders implementing the FRMPs could potentially both reduce flood risk and help to manage the adverse consequences that flooding has on the environment, human health, cultural heritage and economic activity, thus satisfying the requirements of both Directives. Where the sites of such measures overlap with ‘Natura 2000’ sites (under the Habitats and Birds Directives), or are hydrologically connected, there are opportunities to seek benefits through liaison and information sharing.
Measures within the RBMPs highlight the need for multi-agency working at a catchment level to deliver benefits for water status, morphology, flooding and fisheries through a coordinated, joined-up approach. Similarly, the FRMPs identify the need to achieve the objectives of the WFD in terms of “Good” status through the Environmental Objectives as set out in Section 3.1 of the FRMPs. The coordination of river basin planning and flood risk management planning is therefore important in delivering the objectives and measures of both Directives.
There is an obvious high level of analysis that went into the Shimna scheme and reference is made to alternatives in the environmental statement. However most of the environmental statement focuses on the hard engineering solutions within the vicinity of flooding risk without a communicated analysis of how wider upper flood plain options to reduce rate of water flows were evaluated. The hard engineering scheme as proposed may well be the best option but I ask have wider catchment options been evaluated against appropriate criteria and communicated in the environmental statement? Given the severity of the flooding to the 350 or so homes in Newcastle are the evaluated options the best available? The scheme as proposed is probably the best option in the context of the 4 evaluations based around site of flooding impact
If we can manage to achieve holistic catchment river management, understand the environmental opportunities of upland management, analyse options appropriately and communicate well I am sure the most sustainable solution to flooding can be delivered without the damaging impacts on ecological status of rivers.
Brendan Kerr
Fishery Representative
The Drainage Council for NI
20/11/2019