The BFG response to LCC is perceptive and demonstrative of a much deeper understanding of the ongoing flooding problems of Burscough than the so-called “Professional Partners” who are the very cause of those ongoing flooding problems. It is their unfettered and secret “policy” that has normalised the existence of surface water and groundwater flooding affecting Burscough. Why should Victorian standards of sewage and water removal be alive and kicking in 2019?
Mr Rattray writes “Dear Lancashire County Council
“Thank you for responding to my email, let me start by saying that BFG as a group will continue to meet with any of the flood risk management authorities for the benefit of residents, therefore please can you arrange for us to meet with Jacobs in January 2020?
“With regard to the points made in your email, I would like LCC to carefully consider the following comments:
1. “We don’t share the report beyond the professional partners (RMAs) until we are satisfied that the report is of a finished professional standard, this is part of our contractual obligation with the consultant.”
“To enable BFG to accept this argument, could LCC please explain why it previously agreed to share the draft report with us and also provide a copy of the contractual obligation with the consultant which supports the above statement.
2. “They [UU] need to check that the data has been accurately interpreted and shared in a way that meets their professional standard requirements”
“To enable BFG to accept this argument could LCC provide a copy of the professional standard requirements which supports it.
3. “As UU have shared confidential information to inform the report then they need to check that the data has been accurately interpreted”
“As BFG have provided the largest source of information based on the confidential information we hold, why hasn’t the same courtesy of checking the data been extended to BFG? It is not appropriate for LCC, UU or WLBC to check or alter the data provided by BFG without BFG being involved in that process, as we all know the conclusions of a report may be completely altered by the addition or removal of a single word.
4. “The report will be, without doubt, unaffected by political bias, vested or financial interests”.
“An admirable aim but unless LCC has control and auditing processes which verify the above is true and always remains true, then there will be doubt. For example the Police Complaints Commission (PCC) regulations 2012 provide a framework which reduces wrongdoing in the Police force because it roots out and prosecutes wrongdoers. The PCC is able to supply a list of employees who have been prosecuted and/or dismissed or otherwise disciplined. Is LCC able to provide examples of actions, including censure, it has taken against individuals or authorities who have acted improperly because of political bias, vested or financial interests? You have already explained how the drafting process involves your professional partners who have vested, financial and political interests and not BFG who provided the largest source of information.
5. “We have every intention of sharing the final draft with the group, prior to signing the report off as complete. That opportunity will allow for feedback from the BFG”.
“Unfortunately, that isn’t helpful. LCC, by denying us access to the draft documents, ensures that we won’t be aware of the changes that the RMAs have made. Please note that the RMAs are run/overseen by politicians or and/or multinationals which brings into question point 4. LCC has denied BFG the opportunity to influence the report even though BFG seems to be unique as a contributor to the Jacobs report on Burscough in not having any political, financial or vested interests.
“If we were given the opportunity to influence the document, we would like to have the following concerns considered:
• Was the scope of the investigation solely drainage infrastructure and ditches, or was it more holistic and therefore also covering how the actions of the RMAs have affected flooding for the good and bad – BFG were never told the extent (is further work needed)?
• Does the report explain that much of the data provided by the partners was gathered in an extraordinarily dry period. A comparative scenario is the considerable amount of flooding which has taken place this year – has data also been taken in a more rainy period?
• Some of the flooding in Burscough is caused by the expansion of Martin Mere and the neglect of the Alt-Crossens Pumping Network neither of which are in Burscough, how has the report dealt with those issues?
• BFG believes the gathering of external flood reports by the RMAs is virtually non-existent. What does the Jacobs report find? This is important because many people don’t report internal floods because of the effect on the value of their home, therefore external floods provide a truer picture of the functioning of the drainage system and the level of internal floods
• A long term dispute between WLBC and the EA leaves no mechanism to investigate potential Critical Drainage Areas (CDAs) in West Lancashire. What effect has this had on planning and the resolution of flooding problems in Burscough, which has several potential CDAs?
• The SFRA isn’t kept up to date and sequential tests are never undertaken for Burscough, yet new developments usually have or cause flooding problems, are they related?
• The RMAs operate in an environment of obsessive secrecy, for instance there is a shortage of public information about the causes and instances of flooding in Burscough because the LPA was, for a long period, illegally denying all residents FOI information about flooding. In addition, MSFW meetings in West Lancashire are held in secret with no minutes made or published which has reduced informed oversight of the planning process, whereas for example Wyre MSFW meetings are published. Are any of the RMAs for Burscough contravening the 2015 Transparency Code?
• Much evidence of flooding has been provided to the RMAs by residents and by consultants (funded by central government and by Burscough Parish Council) yet little of it ever appears to inform the RMAs for Burscough. For example flooding information provided by BFG to LCC was excluded from the S19 report on storm Desmond, resulting in the report painting a false picture of the flooding. A 2010 consultant’s report on flooding in Burscough went missing on completion until 2016, meaning it was unavailable during the local plan consultation and six years of rapid development. Although things have since changed for the better; WLBC, UU and LCC had all recently stated in public meetings that they wouldn’t accept flooding information from BFG, which we perceived was part of a long term policy not to seek/collect evidence of flooding. Did that policy cause the neglect of the drainage system and explain why Burscough suffers from so much surface water and groundwater flooding?
Gavin Rattray – Secretary Burscough Flooding Group”.
Isn’t it astonishing that the subject of what is visible to any and all of these jobsworth RMAs, as shown below,
has not shamed them into activity for the benefit of residents and out of their talking shops? As a national politician is now repeating “just get it done”, who could disagree with the Burscough Flooding Group?