How is this a Strategy, exactly?

So yesterday I popped into Kirkgate Centre in Shipley, where a drop-in consultation session was being held by the City of Bradford Metropolitan District Council (CBMDC – or “Bradford Council” to most of us) on its new Local Flood Risk Management Strategy. To read the document in question, click here

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These are some of the lovely people gathered at the consultation to chat with people popping in — Vicki and Karen from Yorkshire Voluntary Flood Support in the foreground, as well as reps from Bradford Council and the Environment Agency. When I popped in shortly after the session started, though (it ran from 2.30 to 6.30), there was a bit of a shortage of public being consulted. Maybe it picked up later on.

The personal advice and support being offered, on the day, seemed to me to be rather at odds with the very impersonal, rather unhelpful contents of the actual strategy document. I’ve read through it all now and I’m actually struggling to know what the strategy is, to be honest. And I don’t think this is just me being dense.

Let’s break it down. The document, nicely illustrated by pictures of floods, is in 9 sections, plus appendices. These 9 are:

1. Introduction. Which tells us that there have been floods and will be more floods and that this is natural, as well as caused by climate change (which is caused by us). It also tells us that Bradford Council is designated by law as the Lead Local Flood Authority for the district (and lists the laws in question). So. No strategy yet then.

2. CBMDC Powers and Duties. A list of statutory duties for Bradford Council. Still no strategy.

3. Risk Management Authorities. A list of authorities with a remit on flooding in the area — mostly Bradford Council, plus ‘strategic oversight’ from the Environment Agency (which, confusingly, is placed at the top of the diagram above CBMDC, as if they have ultimate responsibility, even though CBMDC is the “Lead Local Flood Authority”… Is someone passing the buck here…?). Btw, still no strategy…

4. Spatial Extent of Strategy. Which means, “here is a map of Bradford District”. The River Aire is named, as is the River Wharfe at the northern edge of the district. Mysteriously, no sign of Bradford Beck or any other river in Bradford itself… And still no sign of a strategy.

5. Sources of Flooding. A list of ways to get flooded and things in the district that are likely to flood. Thanks for that.

6. Historic Flooding within Bradford District. Tells us about flooding that has happened before. Mostly since 2000. Which, again – thanks for that – but this is not a future strategy.

7. Climate Change and Flood Risk. One paragraph on climate change being risky. “It is imperative,” it says here, “that plans and schemes are developed to better manage and adapt to any increased risk of local flooding.” Good. Where are they?

8. Objectives and Measures for Managing Local Flood Risk. This seems to be the bit that comes closest to any kind of strategy objectives. But everything here is couched in maddening generalisations which don’t appear to add up to very much of anything…

CBMDC wants to “improve understanding of flood risk”, we are told. It wants to “communicate flood risk to partners and stakeholders” (although many of the people at risk already know they are at risk, given that we just had Bradford’s worst flooding in living memory). CBMDC also wants to conduct “targeted maintenance”, but it doesn’t say where this maintenance should take place, and you would have hoped that they were doing targeted maintenance anyway..?

The crux of the matter is that they want to “reduce the impact of flooding”, “ensure appropriate development in Bradford District” (e.g. not building on flood plains), and “improve flood response and post flood recovery”. All of these are admirable goals, but they are just that — broad goals. There is absolutely no detail in this so-called “strategy” about how any of these generalised ambitions might be developed or pursued in future, in relation to specific locations or communities in the district.

9. Funding for Strategic Measures. A list of funding sources for when things need to be done, even though we have no idea what things might need to be done from this document.

So to sum up… there is no strategy here. There are lists of basic facts and existing circumstances, and there are some vague generalisations about intentions that could have been written any time in the last 20 years. None of which gives this reader any confidence at all that Bradford has anything resembling a plan to tackle flooding.

In my day job, at present, I am marking a lot of student essays. If I were grading this strategy document, it would get a very poor grade. Somewhere in the low 2.2 zone, perhaps, or maybe even third class. There’s a recitation of some basic facts, suggesting (as I often say to students in this area) “a very limited amount of research”. There’s also “a serious lack of critical thinking” in response to the facts gathered.

Go back. Revise. Resubmit.

 

 

3 thoughts on “How is this a Strategy, exactly?

  1. You make a very pertinent point regarding the term ‘strategy’, but I think it important to make the point that the fault lies not with the local authority, but with the Flood and Water Management Act which sets out the requirements.

    Indeed, as soon as the Act was published, local authority flood risk professionals recognised that statutory elements required in the ‘strategy’ we’re not in the least bit strategic. This error was then compounded by the lack of formal guidance from the Secretary of State on the content, which might have encouraged the inclusion of more strategic content (but that would constitute a ‘new regulatory burden’, and DEFRA aren’t in a position to fund the existing ones, let alone create new ones).

    So Bradford’s document does what it is required to do, and indeed it does it very competently. But insofar as it is not a ‘strategy’, one must address that point to DEFRA.

  2. What I perhaps should have added, to carry on your essay marking analogy, is to say that the ‘strategy’ answers the question posed by the legislation perfectly, and should receive a high grade.

    That the wrong question was asked of them is not their fault!

  3. Thanks, Mark, for this helpful insight into the statutory process involved here. But even so, I would never (to extend the metaphor further) award a high grade to a submission that simply did the bare minimum required of it. You’re saying, essentially, that anything not specified by the act isn’t something the Council needs to be responsive to. But surely the Council is also responsible to its constituents, especially those at risk. More than that, though — why even hold a public consultation if there is really nothing for the public to consult on? Is this just a box-ticking requirement too? (and thus a waste of everyone’s time and money?) On the “Consultation Questionnaire”, no less than six of the questions listed begin with the words “Do you think the measures proposed…?” How was anybody supposed to answer this meaningfully, when no measures had been proposed? (strategic or otherwise)

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