Water Bill

Written evidence submitted by Ewan Larcombe (WB 12)

1) The Water Bill Part 4 relates to the regulation of flood insurance provision by statutory instrument where the premises are household premises subject to high flood risk.

2) I am concerned that insurance and planning issues exacerbated by a lack of drainage maintenance are resulting in the steady decline of my village over time. I do support the view that risk should be shared, but I believe the regulation of flood insurance by statutory instrument may lead to resentment by those having to pay extra when not at significant risk of flooding.

3) I live in a village on the River Thames flood plain downstream of Windsor. In addition to the River Thames there are three further designated main rivers that pass through my parish. The lead local flood authority is RBWM.

4) The availability and affordability of flood insurance is already an issue in my area. In addition here are some examples of current planning anomalies associated with flooding as follows:

a) The conversion of existing redundant 1st and 2nd floor offices over shops (Connections House, Slough Road) into residential has been refused by RBWM due to flood plain issues.

b) The demolition of the old and derelict building at 138 Horton Road and replacement with 8 one bedroom flats is currently recommended for refusal due to flood plain issues.

c) Ten new gypsy pitches on both green belt and flood plain have been approved by RBWM (in fact the plan has just been called in by the Minister).

5) The £250m Lower Thames Flood Alleviation Scheme downstream of Windsor is in the planning phase. On completion this project may reduce the probability of flooding locally but today there are unresolved funding and technical issues.

6) In particular I am concerned that there is no legal duty on the authorities to maintain the conveyance capacity of existing land drainage infrastructure. I believe that maintenance and/or improvement of land drainage reduces the probability of flooding thus reducing associated insurance costs.

7) Bearing in mind the possibility of climate change resulting in greater intensity of precipitation I believe that there should be a duty on the authorities to demonstrate that existing land drainage infrastructure conveyance capacity is maximised prior to the design and construction of new flood defences.

8) The planning system, flood insurance and flood defences are inextricably inter-dependent. Consequently the hydraulic and financial performance of newly constructed defences should be compared against original plans and forecasts with variances identified and analysed.

November 2013

Prepared 11th December 2013