Consultation outcome

Summary of responses and Environment Agency response

Updated 14 April 2023

Introduction

In 2012, the Environment Agency and our partners published the Thames Estuary 2100 Plan. The Plan is a long-term strategy to manage the increasing risk of tidal flooding due to climate change throughout the estuary.

We regularly review and update the Plan using the latest scientific evidence and data. This allows the best decisions to be made at the right time.

As part of the 10-year review of the Plan, we engaged with stakeholders to co-develop and update the Plan. As part of our engagement strategy, we organised:

• various workshops with stakeholders
• subject-specific working groups to develop key products and studies
• an advisory group of key partners who provided expertise and advice
• a public survey
• other engagement activities

This consultation was the final stage of our engagement strategy. It aimed to ensure all other stakeholders and local residents had received an opportunity to have their say.

In this consultation, we asked for views on:

• new descriptions of what we want to achieve for people and the environment through the updated Plan
• a new structure for the Plan
• proposed additional content

We will publish an updated Thames Estuary 2100 Plan in May 2023, informed by responses to the consultation.

How we ran the consultation

We ran the consultation for 8 weeks, between Monday 26 September and Sunday 20 November 2022. To do this, we:

• hosted the consultation online, using the Citizen Space platform
• provided an email and postal address for responses
• held five public drop-in events around the Thames Estuary, at which paper copies of the consultation questions were available
• posted paper copies to members of the public upon request
• publicised the consultation through a variety of methods

Summary of key findings and actions we will take

Respondents told us they want more clarity and guidance to help them to understand, work together and implement the Thames Estuary 2100 Plan.

In particular, respondents said they want to see:

• how we can deliver wider benefits and enhance sustainability
• the actions for which each stakeholder is responsible, with timescales
• how the Plan will be funded, and options for accessing funding
• plans to protect west London from flooding
• good communication and engagement between all groups and organisations involved in implementing Thames Estuary 2100
• active participation of local communities in developing proposals for their area
• guidance, advice and case studies to help plan for flood defence upgrades
• guidance on managing areas where flood risk will increase over time with climate change

We have used feedback from the consultation to improve the updated Thames Estuary 2100 Plan. The benefits we can create together for the Thames Estuary are a major focus of the updated Plan. We will publish this in May 2023.

We will also use feedback from the consultation in other related projects. For example, we:

• are developing outcome delivery plans to set out actions needed to implement the Plan
• will publish an investment strategy by 2025
• have launched a project to engage with communities in west London on managing flood risk
• will continue to refresh and improve our approach to engagement

The Thames Estuary 2100 Plan is a long-term strategy, and we will continue to work with partners and communities to achieve its aims.

Responses to the consultation

We received 57 responses to the consultation. Of these, 33 were from organisations and 24 were from members of the public. Among the organisations responding, 10 were local authorities and 3 were utility and infrastructure providers. The annex of this report shows a full list of responding organisations.

This document provides details of the responses we received to the consultation, along with the Environment Agency’s responses.

Understanding and awareness of Thames Estuary 2100

Questions 1-3

These questions asked for details about the respondents.

Question 4: how does rising sea level within the Thames Estuary impact you?

We asked respondents to select one or more options in response to the question ‘What is your relationship to the Thames?’.

Table 1: responses to the question ‘What is your relationship to the Thames?’

Relationship to the Thames	Number of responses
I own a home, business or land in the Thames Estuary floodplain	21
I live within the flood zone	13
I work within the flood zone	12
I use the river for recreation or commerce	12
I use the river to commute to work	2
Other	34

In comments, respondents told us they were concerned about:

• potential flooding in areas they live in or manage
• risks to people and assets
• disruption to daily life
• being asked to pay for repairs to the river wall

Question 5: do you feel equipped to prepare for impacts of sea level rise in the estuary?

Out of 46 responses:

• 20 respondents said ‘no’
• 15 respondents said ‘yes’
• 11 respondents said they were ‘unsure’

Respondents asked for:

• works to improve flood resilience of buildings and communities
• advice and resources to protect and insure homes
• plans to evacuate and recover from flooding
• action to raise public awareness of flood risk and what to do in a flood
• predicted river levels for the coming decades
• information on options to mitigate flooding in west London, and who will pay
• resources to protect historic assets
• advice for riverside planning proposals

Question 6: how do you benefit from the Thames Estuary 2100 Plan?

Respondents said they benefit from:

• protection from flooding that would affect lives, homes, businesses, ecosystems, heritage, London, and society
• access to monitoring data
• the information and peace of mind the Plan provides
• opportunities in the Plan to enhance or protect the environment
• using the Plan to understand how to protect people, to coordinate between organisations, and as an example of climate adaptation

Some respondents told us that they do not benefit from the Plan. People living upstream of Teddington Lock highlighted that they are affected by the tide but are outside of the Plan area. Another respondent mentioned needing to pay for river wall repairs and insurance because of the Plan.

Question 7: how important do you think it is to mitigate and adapt to sea level rise?

Most respondents (45 out of 49) said that mitigation is very important. Most respondents (45) also said adapting to sea level rise is very important.

In comments, some respondents said that it is too late to rely on mitigation to prevent sea level rise. Because of this, adaptation is now more important.

Outcomes in the updated Thames Estuary 2100 Plan

An ‘outcome’ refers to what we (the Environment Agency) and our partners need to do to manage tidal flood risk in the estuary.

Question 8: what level of detail do you think the updated Plan should include?

We asked respondents to select as many options as they wanted in response to the question ‘what level of detail should the Plan include?’.

Table 2: responses to the question ‘what level of detail should the Plan include?’

Level of detail	Number of responses
The outcome required to be delivered	10
Who is responsible for delivering it	10
The deadline for when it is required	7
The steps required to achieve it	11
Who else needs to be involved to deliver it	8
All of the above	37
Other	11
Not answered	9

Respondents told us they wanted to see:

• annual milestones for each outcome to track progress and provide accountability
• costs for each outcome with information on who will pay, or potential sources of funding
• details of legislative frameworks to ensure work is done
• plans for engagement

Environment Agency response

We are developing outcome delivery plans to set out actions needed to implement the Plan. These will include regular milestones. In the updated Thames Estuary 2100 Plan, we have provided more clarity on the timing of activities within the outcomes.

Working together with partners, we are developing an investment strategy. This will outline funding options, and legal roles and responsibilities. We will publish this by 2025.

Tidal defence network

Questions 9 to 12: do you support outcomes 1a to 1d?

Outcome 1a: flood and coastal defence owners continue to maintain and improve defences across the Thames Estuary. Defences will be adapted, raised, realigned or replaced as required by the flood risk policies of the Thames Estuary 2100 Plan, ensuring resilience to climate change whilst demonstrating best value for money. This should be integrated with development of the riverside where possible, and always seek to deliver multiple benefits.

Outcome 1b: flood walls and embankments will be raised to prepare for sea level rise:

• defences downstream of the Thames Barrier will need to be raised by 2040 – refer to the relevant policy unit for specific requirements, deadlines and opportunities
• defences upstream of the Thames Barrier will need to be raised by 2050
• further defence raising across the estuary will be required towards the end of the century

Outcome 1c: the Environment Agency will maintain our major barriers in the estuary and adapt to sea level rise by optimising their operation, ensuring resilience to climate change and creating long-term plans for upgrade, replacement, realignment or decommissioning.

Outcome 1d: flood and coastal defence owners will maintain all gates, outfalls and pumping stations across the estuary and adapt to sea level rise by optimising their operation, ensuring resilience to climate change and creating long-term plans for upgrade, replacement, realignment or decommissioning

Table 3: Support for outcomes 1a to 1d

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
1a	31	16	1
1b	20	23	5
1c	33	15	0
1d	32	16	0

Some respondents mentioned concerns about:

• the fairness of charging riverside landowners for defence work
• what legal powers are available to compel defence owners to carry out upgrades
• ensuring all new developments meet the Plan’s requirements
• impacts of defence upgrades on the historic environment
• the need to include local communities in any proposals
• the risk that outcome 1a could limit how much defence raising is achieved through new development
• the need to upgrade some defences upstream of the Thames Barrier before 2035 to mitigate flooding in West London

Respondents told us we should:

• set out priority areas and develop a plan to raise defences
• prioritise defence raising based on level of risk to communities
• bring forward the cut-off date by which we require developers to raise defences rather than demonstrate that future raising will be possible
• refer to ‘relative sea level rise’, instead of ‘sea level rise’, to take account of ground motion
• refer to delivering multiple benefits rather than focus on flood defences in outcome 1b
• add ‘working with key stakeholders where these barriers have an impact on their location and operation’ to outcome 1c
• consider other stakeholders, refer to other key plans and ensure they are compatible with outcome 1c
• carry out work to identify those owning and responsible for maintaining river walls

Several respondents asked for detail and guidance on:

• how much defences need to be raised to enable developers to plan
• how these outcomes will be enforced
• how defence raising should proceed for historic buildings on the river front
• whether the Environment Agency or lead local flood authorities should identify gates, outfalls and pumping stations in an asset register

Environment Agency response

We have:

• improved clarity of the actions required
• included more detail on the steps required to raise defences, when this must be done and by whom
• clarified that defence owners can raise their defences early if they wish to do so

Thames Barrier

Question 13 to 15: do you support outcomes 2a to 2c?

Outcome 2a: the Environment Agency will maintain the Thames Barrier to ensure it operates reliably and effectively as part of the wider flood defence system, working alongside the Port of London Authority to enable navigation.

Outcome 2b: the Environment Agency will seek to improve the accuracy of tidal forecasting in the Thames Estuary, to reduce the number of precautionary closures of the Thames Barrier and other major barriers in the estuary.

Outcome 2c: the Environment Agency will use the Thames Barrier, alongside the other defences in the estuary, to manage tidal surges and more significant fluvial events. The Environment Agency will work with partners to identify areas that currently benefit from closing the Thames Barrier during fluvial flow events. In these areas, the Environment Agency will work with local communities and partners to agree and put alternative flood risk management measures in place for smaller fluvial events, to reduce the number of Thames Barrier closures for fluvial flow events by 2035.

[Note: More significant fluvial events are fluvial flows of 600 cubic metres or higher in combination with mean high water spring tides]

Table 4: support for outcomes 2a to 2c

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
2a	36	8	4
2b	41	5	1
2c	33	12	1

Respondents said we should:

• make our modelling publicly available
• work with local authorities to manage flood risk from all sources
• involve communities and local stakeholders when deciding options for managing flood risk (outcome 2c)

Residents in west London want to understand how we will reduce flood risk after 2035. They want to know whether mitigation measures in west London will be paid for by existing funding, or where alternative funding will come from.

Environment Agency response

We have introduced an outcome to improve how risk management authorities collaborate to address multiple sources of flood risk. As part of the roadmap to selecting an end of century option for the Plan by 2040, we will further engage communities, partners and government.

You can request modelling outputs by sending an email to [email protected].

We will consider the comments from residents in west London as part of the west London communities project, mentioned previously.

End of century options

Questions 16 and 17: do you support outcomes 3a and 3b?

Outcome 3a: take a decision by 2040 on the end of century option for adapting to sea level rise, using the latest data and evidence. The Environment Agency will create a roadmap of the actions required to improve confidence and understanding of selecting an option.

Outcome 3b: by 2030, the Environment Agency will review the end of century option ahead of the next Plan update. This may involve altering or discounting options that are no longer viable or value for money.

Table 5: support for outcomes 3a and 3b

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
3a	31	13	2
3b	29	13	2

Respondents said we should:

• decide on the end of century option earlier than 2040, and identify a preferred option in the 2030 Plan review
• identify works that could be brought forward under all remaining options, such as raising of upstream flood defences
• look at how to create wider benefits beyond flood risk through the end of century option during the next Plan review
• avoid using the term ‘value for money’, as it implies that flood protection might be compromised if it is too expensive
• involve local communities and organisations in deciding on the options
• consider tidal energy generation in the end of century options
• ensure that calculations do not undervalue aspects that are hard to measure financially (for example, community engagement and heritage)

On the timing of decisions, one council said that waiting until 2030 could mean good options are no longer available because of development projects in the interim. The remaining options may be worse or cost more. However, another respondent said we should not rule out any options in 2030, as they may be financially viable by 2040.

A council asked whether we would hold a consultation should the end of century options change.

Environment Agency response

We will create a roadmap for selecting an end of century option that will map out the steps and approval required. This could result in a decision being made before 2040. By 2030, we will undertake a more thorough assessment of all options. This will inform any decisions. We will engage with other stakeholders as part of the roadmap development and options assessment.

We have considered benefits beyond flood risk management in updating the Plan’s aims, strategic objectives and outcomes. We will now work to identify those who will benefit from the plan, and responsible partners, to achieve the benefits of the Plan. We have removed the phrase ‘value for money’ from the outcomes in the Plan.

Tidal flood protection beyond 2100

Question 18: do you support outcome 4?

Outcome 4: a barrier with locks will be required to adapt to further sea level rise. This is expected by 2120 based on current climate change projections, but this date may change as new evidence emerges.

Table 6: support for outcome 4

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
4	35	9	0

Respondents said:

• a barrier with locks would have major impacts on ships using the river
• migrating aquatic species must be able to pass
• the design could incorporate tidal power generation
• we should provide more information on the proposed location
• we should be thinking about relative sea levels at the end of the expected lifespan of a new barrier with locks, to inform longer term land-use and marine planning

Environment Agency response

We will carry out further work on options beyond the year 2100 as part of future Plan reviews.

Other sources of flood risk

Questions 19 to 21: do you support outcomes 5a to 5c?

Outcome 5a: the Environment Agency and lead local flood authorities collaborate to improve management of the interface between tidal, fluvial, and surface water flood risk.

Outcome 5b: the Environment Agency and lead local flood authorities collaborate to better understand and manage the flood risk caused by tide locking of outfalls and other defences.

Outcome 5c: the Environment Agency and lead local flood authorities and water companies manage tidal and other sources of flood risk more effectively by embedding Thames Estuary 2100 outcomes in Local Flood Risk Management Strategies, Flood Risk Management Plans, Drainage and Wastewater Management Plans, Surface Water Management Plans and other relevant plans.

Table 7: support for outcomes 5a to 5c

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
5a	35	13	0
5b	36	12	0
5c	40	8	0

Respondents said we should:

• be collaborating as described in outcome 5a independently of the Plan
• engage academics to address evidence gaps and research needs
• refer to water companies in these outcomes
• include Transport for London (TfL), other transport providers, water companies and utility providers in discussions
• include the full extent of the Thames that is affected by tides in these outcomes
• collaborate with the River Thames Scheme, and the Canals and Rivers Trust
• include groundwater flood risk in outcome 5a
• undertake modelling work to better understand tidal locking mechanisms
• consider whether we need formal powers to ensure these outcomes are not ignored or bypassed

A utility provider said that raising defences could further disconnect groundwater and river or sea levels. This increases the risk of groundwater infiltrating sewers, putting pressure on sewers and greater demand on wastewater treatment works.

Environment Agency response

We have:

• included specific reference to other infrastructure providers such as water companies and transport authorities
• referred to groundwater as a relevant source of flood risk
• clarified work required to better understand multiple sources of flood risk across risk management authorities

Community resilience

Questions 22 and 23: do you support outcomes 6a and 6b?

Outcome 6a: increase resilience to the impacts of flooding by raising community awareness and the ability to adapt, respond, and recover, particularly in areas where flood risk will increase over time with climate change. See the section ‘policy unit specific outcomes’ for details on where this is expected.

Outcome 6b: people living and working in the Thames Estuary 2100 Plan area have an increased awareness and ownership of tidal flood risk and are empowered to build resilience within their communities.

Table 8: support for outcomes 6a and 6b

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
6a	35	12	0
6b	37	10	0

Respondents said:

• these outcomes rely on local authorities understanding flood risks and engaging with communities through emergency planning
• funding is a key issue: who will pay for personal flooding resilience measures?
• building regulations and conditions on landlords should make personal flooding resilience measures compulsory
• heritage can engage communities in thinking about climate change and the risk of loss and damage
• resources should be targeted at areas most at risk
• funding, community engagement and education are all needed; who will do this and how will communities be empowered?
• communities need to be involved in discussions early, rather than having solutions prescribed to them

Question 24: to what extent do you agree with the statement ‘My community is resilient to flood risk and the impacts of climate change’?

Of the 31 responses to this question, most responses were split between strongly disagree (12) and somewhat agree (11).

Table 9: responses to the statement ‘my community is resilient to flood risk and the impacts of climate change’

Response to statement	Number of responses
Strongly agree	2
Somewhat agree	11
Neutral	3
Somewhat disagree	3
Strongly disagree	12
Not answered	26

Respondents who disagreed mentioned:

• seeing tidal flooding
• construction of new housing in inappropriate places
• a lack of published emergency plans
• constrained finances of councils and individuals
• low awareness of causes and consequences of flooding

Of those who agreed with the statement, respondents mentioned:

• flood defences on vulnerable properties
• residents reliably informed of surges or other high-water events

Some respondents said they do not live in a flood-prone area.

Question 25: are you aware of any initiatives to improve resilience to flood risk or the environment in your local area?

13 respondents said they were aware of initiatives. Some initiatives mentioned were:

• increased surface water drainage
• sustainable drainage systems (SuDS)
• ground level raising
• community programmes that raise awareness
• Environment Agency plans for various parts of the Thames

Environment Agency response

We acknowledge the need for greater community engagement, with the involvement of local authorities. We have included an enabling activity for this in the updated Plan.

We will work with partners who have objectives to support resilience. Together, we will create an approach to engaging with communities, with the aim of increasing resilience to climate change impacts, including resilience to flooding.

Delivering the Thames Estuary 2100 Plan

Question 26: do you understand your responsibilities to deliver the Plan?

We received a range of responses. One respondent said they are unsure of any responsibilities, beyond their personal actions to tackle climate change. Another said that they are expected to pay towards improved flood defences but feels this is unfair, as the improvements will protect many others. Some people said they were proactively engaging with the Environment Agency.

Some councils said they were clear about their responsibilities, while others were unclear about specific actions required of them. One was unsure what should happen about sections of riverside where an owner cannot be traced.

One organisation said they were clear about their responsibility as a riverside landowner. However, several organisations were unclear about their role or how they could play a part.

Question 27: what are you already doing to deliver on these responsibilities?

Individual respondents told us of the actions they are taking to inform and protect their communities, as well as to reduce their carbon footprint.

Local authorities are contributing to carrying out the Plan through their roles as lead local flood authorities and local planning authorities. They are developing and incorporating the aims of the Plan into:

• community flood plans
• riverside strategies
• local flood risk management strategies

They are also working with the Environment Agency on the maintenance and repair of flood defences.

Other organisations told us of their work to help communities understand and adapt to climate change, and to maintain their flood defences.

Question 28: what kind of guidance and tools do you need to support you in achieving these responsibilities?

Councils and other organisations told us they want information, including:

• data on the condition of flood defences
• guidance on upgrading defences with heritage constraints
• guidance for land-use planning to ensure development is appropriate
• an action plan setting out what is needed, with timescales and information about who is responsible
• clarity about the roles of different organisations, and information about which assets they are responsible for
• case studies showing potential designs and estimated costs for raising flood defences of different types
• what help is available to fund flood defence upgrades, and what the Environment Agency is (and is not) able to pay for

Councils asked for engagement tools they could use, and training for planners and politicians on how to engage others and enact the Plan. They also asked for ongoing dialogue with the Environment Agency and other stakeholders, including through workshops and events.

West London residents requested:

• a forecast of water levels for west London in the coming decades combining tidal levels and river flows
• information about future flood mitigation options post 2035, when the Thames Barrier will no longer used to protect the area from river flooding
• details about how future flood protection in the area will be funded

Question 29: what are the biggest challenges to delivering the Plan, and why?

Key challenges identified were:

• funding, resourcing and skills
• engagement with the public and key stakeholders, including riverside landowners
• enforcement, delivery mechanisms, and associated legislation
• the scale and long-term nature of the Plan
• protecting and enhancing the environment

Question 30: do you understand why the deadlines in the Plan change as new data and evidence becomes available?

A large majority of respondents that answered this question (41 out of 44) said they understand why the deadlines change. 3 said they were unsure. No respondents answered ‘no’.

Question 31: what plans and strategies should align with, or be embedded within the updated Thames Estuary 2100 Plan?

Respondents said the Plan should align with:

• the local plans developed by councils
• the London Plan
• the plans of individual stakeholders, such as the Port of London Authority’s ‘Thames Vision 2050’
• plans relating to climate change and nature recovery
• plans for growth, development and housebuilding in the Thames Estuary
• other flood plans, including strategic flood risk assessments (SFRAs), multi-agency flood plans (MAFPs), Local Flood Risk Management Strategies (LFRMS), and shoreline management plans (SMPs)

Question 32: to what extent do you support the outcomes proposed for managing other sources of flood risk?

We received only 22 responses to this question. Of these, most responses were split between ‘strongly support’ (9 out of 22) and ‘neutral’ (8).

Table 10: support for outcomes proposed for managing other sources of flood risk

Support for proposed outcomes	Number of responses
Strongly support	9
Somewhat support	4
Neutral	8
Somewhat disagree	1
Strongly disagree	0
Not answered	35

Question 33: how could we improve the outcomes proposed for managing other sources of flood risk?

Respondents said we should:

• engage with local communities at all stages
• improve collaboration between stakeholders
• monitor and communicate outcomes effectively
• involve residents’ associations, which are responsible for funding work in some areas

Environment Agency response

We acknowledge the challenges presented by stakeholders, and the gaps in guidance required to achieve the aims of the Plan. We will continue to work with communities and partners to improve guidance available.

We have clarified roles and responsibilities in the updated Plan. We have worked with stakeholders to define their own role in implementing the Plan. The updated Plan will include case studies, to show the roles of individual organisations and to support others.

Place-making and climate resilient growth

Questions 34 to 37: do you support outcome 7 and outcomes 8a to 8c?

Outcome 7: new and existing development within the Thames Estuary 2100 Plan area is resilient to tidal flood risk caused by sea level rise. Inappropriate development in flood risk areas is avoided.

Outcome 8a: councils, communities and other local organisations take a proactive approach to managing future climate risks through place-making (improving public spaces), by developing visions for how their riverside will adapt to sea level rise and become more climate resilient.

Outcome 8b: the riverside strategy approach and Thames Estuary 2100 requirements are embedded in the statutory spatial planning framework, increasing opportunities, efficiency and effectiveness of delivering defence upgrades and multiple benefits through development of the riverside.

Outcome 8c: improve sustainable recreational river use and access, through delivering defence upgrades and multiple benefits in line with the riverside strategy approach.

Table 11: support for outcome 7 and outcomes 8a to 8c

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
7	34	11	1
8a	34	8	1
8b	36	8	1
8c	34	8	1

Respondents said we should:

• clearly set out what we mean by ‘inappropriate development’ and ‘resilient’
• address whether new developments should have to raise defence heights now, or merely show they can do so later.

Several respondents voiced opposition to planned developments. One advised against any approach that could lead to building more homes in flood-prone areas. Another respondent noted the environmental cost of constant growth.

However, others said that growth and development, if done well, can help to adapt to climate change. It can also improve peoples’ access and connection with the river.

Respondents supported the aim for communities to participate in developing visions for their riverside. Some said that beyond walking and recreation, access to the river is important for cultural and heritage reasons, as well as community. Organisations in the heritage sector noted that history is central to place-making (improving public spaces), and useful for engaging communities.

Councils told us:

• their involvement in developing a vision would be subject to resource constraints
• adding a deadline would encourage visions to be developed sooner
• we should make clear whether each vision should cover a whole borough
• we should ensure there is a joined-up approach along the estuary
• the approach should ensure developers and others are not able to bypass statutory planning processes

Question 38: thinking about the Thames Estuary riverside, what do you value the most? What improvements would you like to see in the future?

The features valued most were:

• wildlife or biodiversity (11 responses)
• foot and cycle paths (9 responses)
• access to blue and green spaces (8 responses)

The main improvements suggested were public access to the river, and improvements to habitat, amenities and paths.

Question 39: do you support the principle of a riverside strategy approach to integrate flood risk management with wider improvements to the riverside?

A large majority of respondents (44 out of 46) supported the principle of the riverside strategy approach, with two opposed. Comments added that it would be useful to have guidance for those creating strategies, and for developers to understand them.

One respondent objected because they felt a different approach, known as a ‘wholescape approach’ was more appropriate.

Question 40: what guidance do you need to deliver the riverside strategy approach or to support it in your area?

Respondents told us they need:

• data on flood defence assets and flood modelling
• practical guidance
• case studies
• timescales
• defined roles and responsibilities for delivery
• information about costs and funding sources
• coordination among stakeholders
• advice on heritage issues

Question 41: visions for the future of the riverside could be at any scale. Are you aware of any opportunities to develop these visions?

Respondents told us about opportunities, including:

• reviews of councils’ local plans
• riverside developments
• a refresh of the Thames Landscape Strategies
• various local strategies and plans, such as the Integrated Water Management Strategy

Environment Agency response

These responses have reinforced the need for the riverside strategy approach as part of this Plan. We will continue to work with local authorities to understand their visions for the future of the riverside, which can then be translated into planning and policy requirements.

Land strategy

Questions 42 to 43: do you support outcomes 9a and 9b?

Outcome 9a: secure land across the estuary to enable defence upgrades and realignment for associated riverside enhancements, habitat and biodiversity improvements, and the end of century option to adapt to sea level rise.

Outcome 9b: the Environment Agency will work with partners to develop a land strategy setting out how, when and where to secure land by 2030.

Table 12: support for outcomes 9a and 9b

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
9a	27	13	1
9b	32	9	0

Regarding securing land for future defences, respondents said we should:

• be more specific about the proposed locations for a new Thames barrier
• create wider benefits, including protecting habitats and heritage
• engage with people and organisations
• allow land use for community or environmental benefit in the meantime, where it is secured long before future defences are needed

One organisation said that we need to consider current landowners and collaborate where they have proposals that will provide similar flood protection and environmental benefits. They highlighted the risk of deterring possible development opportunities along the river.

Regarding the land strategy, respondents told us to:

• add provision for lifesaving and rescue
• take advice from heritage specialists
• try to reduce and mitigate the risk of planning blight
• ensure involvement of partners, landowners and local communities, with good communication

Environment Agency response

We have included a map in the updated Plan that highlights potential locations for the land requirements of the end of century options. We will collaborate with relevant stakeholders and landowners to consider mechanisms for securing land for these options, and the interim benefits that could be achieved ahead of implementing an option.

Securing investment to deliver the Plan

Question 44: do you support outcome 10?

Outcome 10: the Environment Agency will work with partners to develop an investment plan by 2025 to deliver the flood and coastal defence upgrades required by the Thames Estuary 2100 Plan. This will include long-term finance options to ensure efficient and effective investments and shall set out the required milestones in the short, medium and long-term.

Table 13: support for outcome 10

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
10	36	10	0

Respondents said the funding plan should:

• be transparent and fair
• not ask property and land owners to pay for defences that benefit a much wider area
• seek a bespoke funding settlement from the government for the Thames Estuary 2100 Plan
• support residents in west London to protect property from fluvial flooding
• require developers to pay a Community Infrastructure Levy
• review legal mechanisms available for enforcement
• identify partnerships to collaborate and save costs
• consider impacts on development of securing land for future defences

Question 45: What mechanisms should we be exploring to secure the required investment to deliver the Plan?

Support was similar for all funding options.

Table 14: response to the question ‘What mechanisms for investment should we be exploring?’

Mechanism	Number of respondents who supported the mechanism
Council tax levy	21
Private investment	26
Business tax	22
Green bonds	27
Insurance or reinsurance levy	22
Other	23
Not answered	16

Respondents suggested funding mechanisms involving:

• sponsorship
• green finance
• a public-private partnership model
• contributions from developers
• public funding through general or local taxes
• the Community Infrastructure Levy
• a levy paid by businesses in central London

Question 46: Do you have any examples of where these investment models have been used before?

Respondents suggested:

• examples of programmes funded through private investment and levies, such as Crossrail
• the Tideway Tunnel project, which has worked with riverside landowners along the Thames
• Business Improvement Districts

Question 47: do you or your organisation have any expertise in this area and would be willing to contribute to developing the investment strategy for the Thames Estuary 2100 Plan?

Several respondents offered to discuss the investment strategy.

Question 48: what should the Thames Estuary 2100 Plan deliver ?

Respondents ranked the objectives in the following order, with the most important first:

1. Managing the impacts of tidal flood risk and adapting to climate change.
2. Protecting critical infrastructure (transport, hospitals, utilities).
3. Community resilience.
4. Environmental improvements.
5. Enabling economic and commercial opportunity.
6. Enabling river use.
7. Amenity improvements.

Respondents said:

• the Plan should achieve all the objectives listed
• recording, protecting and engaging with the historic environment and heritage of the Thames are important
• Sites of Importance for Nature Conservation (SINCs) must be protected
• economic and commercial opportunities can help to fund flood defence work
• increasing river use for freight has other benefits, such as reducing road traffic

Environment Agency response

We will take these suggestions on board in our work to develop an investment strategy in partnership with stakeholders. We will draw on the expertise and experience of our partners to co-develop this strategy. We will publish the strategy by 2025.

Sustainability and monitoring

Questions 49 and 50: do you support outcomes 11a and 11b?

Outcome 11a: all partners will work together to achieve carbon net zero in our operations and supply chains.

Outcome 11b: all partners will adopt a circular economy approach by improving resource efficiency and minimising emissions and waste, to provide better value for money and improve air, land and water quality.

Table 15: support for Outcomes 11a and 11b

Outcome	Number of respondents supporting outcome	Number of respondents who would support the outcome if amended	Number or respondents who do not support the outcome
11a	39	5	1
11b	35	8	0

Respondents told us we should:

• develop agreed baselines, definitions and metrics for these outcomes
• be more ambitious and aim to reach net zero carbon within five years
• recognise the importance of upskilling to achieve a circular economy
• support other projects along the estuary that help to decarbonise other sectors, such as shipping
• do more to achieve a circular economy than outcome 11b describes – particularly reusing existing material, not just reducing waste or consumption

Some respondents interpreted the outcomes to mean the Environment Agency would refuse to work with partners that did not support net zero carbon or a circular economy. They objected to this.

Question 51: Is your organisation aiming to achieve carbon net zero?

A large proportion of those responding said ‘yes’ (27 out of 35), while just 2 said ‘no’. 13 organisations said they aim to reach net zero by 2030, including 9 councils.

Question 52: do you have any feedback on how we could improve or align the roadmap to net zero with your organisation’s ambitions and approach to achieving net zero carbon?

Respondents told us we should:

• discuss opportunities to work with councils
• consider carbon in procurement decisions
• be bold in our ambitions to cut our carbon emissions
• collaborate and coordinate with others to support developments and habitats that mitigate climate change

Question 53: are you or your organisation currently working towards (or planning to work towards) a circular economy approach?

Of those responding:

• around half said their organisation was working towards a circular economy approach (18 out of 35)
• 6 said their organisation was not
• 11 did not know

Respondents provided information about their current and future plans to:

• design out waste, including single-use plastics
• improve sustainability of supply chains
• reuse materials
• promote circular behaviours among others

An environmental organisation described plans to use material from dredging in the Thames Estuary to create or enhance habitat for wildlife.

Question 54: what are your priorities for increasing social value within your local community or area of the Thames Estuary?

Respondents selected a wide range of priorities.

Table 16: respondents’ priorities for increasing social value in their local community or area

Priorities for increasing social value	Number of responses
Other	20
Volunteering/charity/internship/apprenticeship	18
Blue and green habitat restoration	17
Recreational and educational blue and green space	17
Attractive, quiet and restful stopping places	15
Diversifying supply chains to new green suppliers	14
Citizen Science involvement	13
Educational training schemes in schools	12
Infrastructure for protected characteristics	11
Cultural and arts space	11
Recreation infrastructure	10
Not answered	16

Many respondents gave examples of their priorities. These included:

• affordable housing
• employability programmes
• tackling social isolation
• encouraging healthy behaviours, such as guided walks

Questions 55 to 57: do you support outcomes 12a to 12c?

Outcome 12a: the Environment Agency will work with partners to enable nature recovery and develop biodiversity resilience, by delivering biodiversity and environmental net gain and minimising adverse environmental impacts. This includes creating new habitat to compensate for coastal squeeze in advance of projected losses.

Outcome 12b: flood and coastal defence owners ensure defence upgrades and realignment create continuous or semi-continuous blue and green habitat corridors in line with local nature recovery strategies, to maximise biodiversity benefits, and create educational, volunteering and recreational opportunities.

Outcome 12c: the Environment Agency will work with partners and communities to monitor habitats. Monitoring should include quality as well as quantity, changes in fauna and flora, blue and green habitat connectivity, and the habitat’s contribution to natural flood management, to ensure the success of biodiversity improvements across the estuary.

Table 17: support for outcomes 12a to 12c

Outcome	Number of respondents of support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support outcome
12a	36	11	0
12b	36	9	0
12c	37	7	0

Respondents said that plans for nature recovery and habitat creation should:

• protect the historic environment
• involve natural flood management
• ensure that no more species and habitat are threatened or lost
• include steps to reduce water pollution
• be done in coordination with local authorities, local nature recovery strategies
• be included in local plans and other guidance or policy, ensuring organisations understand their responsibilities and comply
• be coordinated strategically at the national and international scale to create the greatest long-term benefit

Respondents told us that monitoring should:

• consider impacts on designated and non-designated heritage
• use an open platform to share information and data
• incorporate observations from communities and interest groups, such as birders and archaeologists
• be carried out with partners and communities, and aligned with councils’ biodiversity monitoring reports and nature recovery strategies

Question 58: are you or your organisation involved with creating or maintaining blue and green spaces, increasing biodiversity or improving habitats in your community or area?

Of those responding to this question:

• 25 out of 40 said ‘yes’
• 13 said ‘no’
• 2 respondents said they didn’t know

Respondents told us they were involved in:

• litter picking
• developing sustainable urban drainage systems (SuDS)
• providing community amenities for recreation
• work to increase biodiversity and improve habitats
• encouraging access to Thames foreshore to increase understanding of its archaeology and heritage

Many respondents said they would like to collaborate with us to increase habitats and improve biodiversity. These included respondents already involved and those not yet involved with this work.

Question 59: do you support outcome 13?

Outcome 13: the adaptive approach within the Plan is driven by the latest science and data. Changes in the estuary and climate change effects are monitored by the Environment Agency in collaboration with partner and community organisations to ensure efficient, mutually beneficial data collection that is shared as open data.

Table 18: support for outcome 13

Outcome	Number supporting outcome	Number supporting outcome if amended	Number not supporting outcome
13	41	6	0

Respondents said:

• monitoring should be done regularly, and include heritage assets, the historic environment and community resilience
• local schools, colleges and community groups could be involved in some aspects of data collection
• data related to some infrastructure should be treated as sensitive information, remaining confidential rather than considered as open data
• we should carry out more frequent physical ground surface monitoring, ideally using satellite data, as irregular snapshots could be misleading

Question 60: do you or your organisation monitor changes in the estuary (for example, physical, social, environmental changes)?

Of the 45 respondents:

• 25 said ‘yes’
• 16 said ‘no’
• 4 respondents said they didn’t know

Respondents told us:

• their organisation uses some of data from the Environment Agency
• their organisation conducts surveys of breeding wading birds, which are an indicator of habitat condition
• as a lead local flood authority, they monitor reports of flooding
• local volunteers are working with the Thames Landscape Strategy to monitor hydrology and salinity

Question 61: do you or your organisation use data sharing or collaboration platforms that could be useful for monitoring data?

Of respondents answering this question:

• 14 out of 44 said ‘yes’
• 19 said ‘no’
• 11 said they don’t know

Several respondents mentioned particular platforms and use cases for data sharing.

Environment Agency response

We will continue to work with partners to refine our approach to sustainability. This will include translating strategic ambitions into tangible actions to promote sustainable climate adaptation. We will look to create and share data with partners and communities to drive collaboration and efficiencies.

Policy unit specific outcomes: inner estuary flood defence raising

Question 62 to 63: do you support outcomes 14 and 15?

Outcome 14: flood and coastal defences will need to be raised to prepare for sea level rise by 2050. Defence owners need to work with the Environment Agency, the relevant local council and infrastructure providers to identify and capitalise on opportunities within this policy unit to deliver the upgrades required alongside maximising delivery of multiple benefits. (This outcome applies to all policy units upstream of the Thames Barrier).

Outcome 15: the Environment Agency will work with Hounslow and Richmond Councils to identify areas of the Twickenham and Richmond policy units that currently benefit from closing the Thames Barrier during fluvial events. In these areas, the Environment Agency will work with local communities and partners to agree and put alternative flood risk management measures in place for less significant fluvial events, improving resilience before Thames Barrier operation changes.

Table 19: support for outcomes 14 and 15

Outcome	Number supporting outcome	Number supporting outcome if amended	Number not supporting outcome
14	32	8	4
15	32	7	3

Respondents told us:

• they are concerned about plans to stop using the Thames Barrier to reduce the risk of fluvial flooding in west London from 2035
• we should ensure local people are aware of changes in use of the Thames Barrier and the maximum flood level that could be expected in a less significant fluvial event
• defence raising in the inner estuary should include flood protection for west London, with clearer timelines and policies, more transparency about the impacts of our policies, and a list of the actions needed
• discussions about west London should include Elmbridge Council and the London Borough of Kingston
• they wanted to know how flood defence work would be funded, incorporated in local policy, and enforced
• the Twickenham policy unit should be renamed ‘Hounslow and Twickenham’

Organisations asked to be involved in discussions, as there may be impacts on their assets and operations.

Environment Agency response

We have included an outcome in the updated Plan about how the Environment Agency, councils and communities will address fluvial flooding in west London. We are currently exploring new and innovative mechanisms for funding flood defence upgrades, which we will present by 2025 in our investment strategy.

Policy unit specific outcomes: outer estuary flood defence raising

Question 64 to 65: do you support outcomes 16 and 17?

Outcome 16: flood and coastal defences will need to be raised to prepare for sea level rise. Defence owners need to work with the Environment Agency, the relevant local council and infrastructure providers to identify and capitalise on opportunities within this policy unit to deliver the upgrades required alongside maximising delivery of multiple benefits.

(This outcome applies to all policy units downstream of the Thames Barrier with a P4 policy. A P4 policy says “ensure flood defences keep pace with climate change so that flood risk does not increase”).

Outcome 17: flood and coastal defence owners and infrastructure providers are aware of increasing tidal flood risk with climate change and plan to realign flood defences and improve resilience accordingly. Within each policy unit listed below where there is a P3 policy to accept increasing risk with climate change, the Environment Agency will work with the relevant local council and community to ensure appropriate resilience measures are implemented.

(This outcome applies to all policy units in the outer estuary with a P3 policy. A P3 policy says “maintain flood defences at their current level accepting likelihood and/or consequences of a flood will increase with climate change”).

Table 20: support for outcomes 16 and 17

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
16	26	8	2
17	25	7	3

Respondents told us:

• outcome 16 should include owners/providers of critical national infrastructure among those with whom defence owners need to work
• the descriptions of certain areas fail to recognise significant features, including critical infrastructure, tourism and agricultural production
• flood defences in P3 areas are likely to fall below their current level as they incur damage from flooding; the policy is not sustainable indefinitely
• innovative alternatives to ‘hard’ defences could be useful to maintain the character of some areas
• we need to consider how the approach to flood defence would integrate with a possible future Thames Barrier in this area
• we should support flood resilient design and work with local planning authorities to make development sustainable
• some policy units should include replacement intertidal habitat (managed retreat)
• of several factual points in need of correction
• there are features in some policy units that could require urgent consideration, and a possible reappraisal of the flood risk policy, including: railway lines, power infrastructure, a gas transfer station, planned new housing, important freshwater habitats, and historic landfills

Several organisations asked to be involved in discussions.

Question 66: do you support outcome 18?

Outcome 18: the Association of South Essex Local Authorities (Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock, and Essex County) will work with the Environment Agency to deliver flood risk management and multiple benefits as part of the South Essex Estuary Park growth opportunity.

Table 21: support for outcome 18

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
18	29	4	0

Two local authorities said they were pleased to see references to the Association of South Essex Local Authorities and the South Essex Estuary Park growth opportunity.

Question 67: do you support outcome 19?

Outcome 19: the Environment Agency will continue to work with Thurrock, Dartford and Gravesham Councils regarding the availability and securing of land for a future barrier option in the lead up to a decision being made by 2040 on an end of century option for adapting to tidal flood risk.

Table 22: support for outcome 19

Outcome	Number of respondents who support the outcome	Number of respondents who would support the outcome if amended	Number of respondents who do not support the outcome
19	31	7	0

Respondents said the outcome should refer to local landowners. In addition to those listed, a further local authority wishes to join discussions.

Question 68: what further information, outcomes or guidance would you like to see for the area of the Thames Estuary you are interested in, or have responsibilities in?

Respondents asked for:

• access to data that is updated regularly
• consideration for active travel
• information for residents to explain what the Plan means for their local area
• an engagement event for stakeholders across disciplines
• a competition to encourage innovative flood protection systems
• cooperation with councils in developing local plans
• more information about and progress towards short-term actions
• a plan to manage heritage in the estuary
• guidance on raising flood defences for various types of existing defence structures
• more information about social value alongside environmental concerns
• information for potential homebuyers on future flood risks
• engagement with residents in west London
• engagement with landowners around sites of a potential future Thames Barrier
• support for councils that must manage policy units assigned different flood risk policies
• engagement with landowners and residents’ associations who are asked to pay for flood defence work

Environment Agency response

We have updated outcomes in this Plan to reflect these comments. We have included interim steps for defence raising. We have committed to working with local authorities, landowners and infrastructure providers to enable defence raising.

For areas where flood risk is expected to increase with climate change (P3 policy), we have set out a clearer plan of how this will be assessed. We have also set out appropriate resilience measures put in place.

Structure of the updated Plan

Question 69: do you agree with the proposed list of section headings for the updated Plan?

Of the 46 respondents who answered this question:

• 27 said ‘yes’
• 13 said ‘no
• 6 said they didn’t know

Respondents told us the updated Plan should:

• put key findings first
• include clear responsibilities of partners and flood defence owners
• include information costs, who will pay, accessing and securing funding
• describe wider benefits of the Plan, including culture, health and wellbeing
• set out clear actions, locations for work and timescales
• refer to heritage and the historic environment
• describe how fluvial flood risk in west London will be managed after 2035
• refer to the river upstream of Teddington
• consider implications of being available only online for user accessibility
• link to information on existing flood defences, showing current height, ownership, condition and future levels required

Question 70: how useful are these additional features when using the updated Plan?

We asked respondents to indicate whether they would find the following useful:

• short video introduction
• links to relevant plans and strategies
• downloadable slide packs on key principles
• interactive map showing outcomes by location
• interactive map postcode search
• downloadable GIS datasets and map layers
• clear signpost to supporting information
• a glossary of terminology
• email alerts for updated content

Generally, respondents welcomed the suggested additional features. Several people noted that some were not clear for all to understand.

Respondents also suggested we could incorporate:

• a searchable feature using post code to find out flood risk for an area
• estimated costs for required improvements
• a description of how the Plan will embrace innovation
• a clear statement that local communities will be involved and included in plans and decision-making, and that the historic environment is included

Environment Agency response

We have used these suggestions and other engagement over recent years to inform the information, structure and presentation of the updated Plan. We will continue to produce improved guidance to accompany this Plan that will enable responsible parties to deliver the actions required.

Annex

List of organisations that responded to the consultation:

• Active360
• Adams Hendry Consulting Limited
• AJEA Products Ltd T/A Quell
• APEM ltd
• Basildon Borough Council
• British Geological Survey
• Castle Point Borough Council
• City of London Corporation
• Ebbsfleet Development Corporation
• Gravesham Borough Council
• Greater London Authority
• Historic England
• London Borough of Hounslow LLFA
• London Borough of Richmond upon Thames, Senior Planner (Policy)
• London Borough of Wandsworth
• Metrotidal Limited, Principal and Director
• Museum of London Archaeology
• Natural England
• Net Zero Marine Services Limited
• River Thames Society (Upper Tideway branch)
• RNLI
• Royal Borough of Kensington and Chelsea
• RSPB
• Southend on Sea City Council
• Southern Water
• Thames Crossing Action Group
• Thames Enterprise Park & Thames Oil Port
• Thames Estuary Growth Board
• Thames Life
• Thames Water Utilities
• The Houses of Parliament Restoration & Renewal
• The Royal Docks Management Authority Ltd
• Transport for London

List of drop-in events held

• 22 September 2022: Canvey Island
• 28 September 2022: Dartford
• 5 October 2022: Greenwich
• 11 October 2022: Grays
• 25 October 2022: City of London