Comments on: How is this a Strategy, exactly?

By: Steve Bottoms

Steve Bottoms — Mon, 23 May 2016 08:14:39 +0000

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)

By: Mark Young

Mark Young — Wed, 18 May 2016 19:45:53 +0000

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!

By: Mark Young

Mark Young — Wed, 18 May 2016 19:40:33 +0000

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.