Select Committee on Agriculture Sixth Report


APPENDIX 8

Memorandum submitted by The Chartered Institution of Water and Environmental Management (F13)

1.  INTRODUCTION

  1.1  This evidence is submitted by the Chartered Institution of Water and Environmental Management (CIWEM), a learned body whose origins in the water industry extend back for more than 100 years. Comprising over 12, 000 members, the Institution includes a number of Special Interest Groups, providing a forum by which members having similar interests can meet to discuss and learn about matters of mutual relevance.

  1.2  One of these groups is currently known as the Rivers and Coastal Group. This originated after the major 1947 floods in England and Wales, and its members are drawn from all organisations with an interest in river and coastal works. It has a large number of Environment Agency staff, predominantly but not exclusively from the Flood Defence function, and an equal number of consultants working on flood defence and coastal protection schemes. In addition the group's membership includes significant numbers from government and public authorities; from contractors; and from environmental organisations.

  1.3  The evidence presented here has been drawn together by the Rivers and Coastal Group, and represents views from a wide spectrum of the Flood and Coastal Defence industry. Four key issues are addressed, namely:

    —  Economic Appraisal

    —  Funding

    —  Organisation

  1.4  These issues are examined in detail after comments on the background to flood defence have been given.

2.  BACKGROUND

  2.1  A totally natural UK river can be expected to flood out of banks once every two or three years on average. However, the most fertile land for agriculture is usually found in the floodplain, or on the flat reclaimed areas of the Fens or Levels. Equally, the flat floodplains have historically been the preferential areas for development, as the infrastructure is easier to construct and hence less costly.

  2.2  Most UK rivers (a figure of 96 per cent has been quoted) have been altered by man in some way, often, in more recent times, to reduce the incidence of flooding, but in earlier periods they were altered to provide power and perhaps transport.

  2.3  The influence of man has resulted in rivers that have to be positively managed and cannot be left to stabilise to their "natural" size, or flooding of property and infrastructure, constructed in the natural floodplain over many centuries, will occur with unacceptable frequency. Equally, the rivers running through the Fens and Levels are often at a much higher level than the adjacent ground, and if these were to revert to their "natural" carrying capacity the consequences for much of the UK's prime agricultural land would be disastrous.

  2.4  Similarly sea walls and embankments have allowed farming and development to be undertaken in areas well below high tide level, and the result of failure of sea defences would be economic ruin for many areas, in addition to serious risk to life and/or injury.

  2.5  The extensive investment in flood and coastal defence works that have been constructed in England and Wales over the past decades and even centuries requires ongoing management to maintain their integrity, to ensure that the existing infrastructure and development protected is not abandoned. Abandonment, or in some cases a reduction in standards, would lead to considerable loss to the nation in terms of industrial and agricultural production, in addition to the increased risk to human life. Thus ongoing investment is required for replacement capital works, as well as for maintenance of all works—new and old—to maximise their effective life.

  2.6  The major national fluvial and coastal flood events have been in 1947 and 1953 respectively, and a great deal of highly effective flood defence work has been carried out subsequently. However, there is no cause for complacency, since a proportion of works are always nearing the end of their useful lives, and there is a need for a constant cycle of renewal, in order to continue to safeguard areas defended from flooding.

3.  KEY ISSUE—ENVIRONMENT

  3.1  In the past there was concentration on the basic functionality of flood defence engineering works. Environmental considerations were perhaps typically limited to counting the number of trees felled for a scheme, and planting a similar number on completion.

  3.2  Over the last twenty years, however, engineers have become much more aware of the environment in which they are working, and of the influence which flood defence schemes can exert. This awareness includes not only mitigation measures to reduce the adverse impact of schemes, but positive enhancement features to be incorporated within a scheme, in addition to good engineering practice which works with nature rather than against it.

  3.3  Schemes are now proceeding which attempt to compensate for the sometimes very severe adverse effects of earlier flood defence works. These earlier works were usually carried out with Grant Aid funding from MAFF, yet no similar funding is currently available when an operating authority wishes to redress the environmental balance. Indeed, even on new "economically viable" flood defence schemes Grant Aid is limited to environmental mitigation and compensation for that scheme alone. Environmental enhancements are left to the operating authority alone to fund.

  3.4  One reason for this refusal by MAFF to fund enhancements is perhaps the difficulty of placing an acceptable monetary value on environmental features, whether they be types of flora and fauna, landscape aspects, or habitats. A change of attitude is urgently needed in order that environmental aspects of a scheme may be considered in a structured way, and that their benefits and disbenefits may be added to the economic benefits (flood damages avoided) and costs (capital and maintenance) of a scheme.

  3.5  The effects of climate change may require new flood defence schemes, or alterations to works that were previously thought to be adequate, in both fluvial and coastal schemes. It is important to consider all impacts of the current MAFF policy of allowing for such changes in current designs. Will there be a time when it is not viable to continue to "chase the change" in certain situations? If so, perhaps that should be recognised at an early stage, and an appropriate strategy developed for an ever-decreasing standard of protection until failure occurs. For coastal and tidal works the current MAFF policy of allowing for a defined rate of sea level rise throughout the life of the works may be too simplistic.

4.  KEY ISSUE—ECONOMIC APPRAISAL

  4.1  Economic justificaiton is the overriding criterion upon which capital investment is made, and against which MAFF Grant Aid is provided. The previous key issue has already addressed the concerns that this has raised over environmental matters, and there is an urgent need for a change in appraisal criteria for scheme justification, which goes further than considering just those economic effects that are easily measured—sometimes known as "tangible" damages (or benefits).

  4.2  The lack of full consideration of environmental issues in the economic appraisals that determine whether or not a flood defence scheme can proceed is echoed in the MAFF approach to social issues. It has been known for some time that floods—or even the ever-present threat of them—can lead to physical and psychological ill-health to those affected or at risk. In addition there are the non-monetary losses sustained by owners of property affected by flooding (for example memorabilia in residential property, damaged records in business properties).

  4.3  While studies on the social disbenefits of flooding have been commissioned by MAFF and the Environment Agency, to date there have been no guidelines on how such disbenefits may be incorporated into a project appraisal alongside the economic (and environmental) aspects of the project. This has meant that certain flood defence projects cannot be implemented because the costs exceed the assessed economic benefits, despite the fact that some members of the public are living in fear of the next flood. These may be older or low-income families with small houses, where the assessed damage would be much less than if luxury houses, with high-income occupiers, were at risk of flooding.

  4.4  Such an approach often leads the operating authorities to be accused of bias towards the well-off, and being unwilling to help those who are less able to help themselves, yet these authorities are simply implementing government policy.

  4.5  One further area in which a purely economic appraisal is inappropriate as the determinant for a flood defence scheme is in respect of sustainable development. The current Treasury discount rate of 6 per cent means that even significant future recurrent expenditure may have little effect on the present cost of a proposed scheme. Thus a scheme which has a greater initial cost, but minimal future input, may be rejected on economic grounds in favour of one which requires significant ongoing input from future generations.

  4.6  Alternatively a scheme comprising elements which lead to sustainability may well have a greater direct economic cost than a similar scheme which has not been designed on sustainable principles. This could be the use of cheaper timber from a non-sustainable source, or more complex issues such as constructing new flood defence works on a "greenfield" site to avoid the cost of remediating a "brownfield" site. Current economic appraisal would favour the "unsustainable" option in each case, and could even preclude the implementation of works if sufficient economic benefits could not be demonstrated.

5.  KEY ISSUE—FUNDING

  5.1  There are several funding issues that tend to affect the implementation and maintenance of flood defence works. One that can be significant in certain areas is the high percentage of MAFF Grant Aid provided for flood defence capital works, whereas none is provided for maintenance of such works. It is possible that an operating authority can procure capital works to the value of three or four times its own contribution, yet has no assistance with activities classed as "revenue" work.

  5.2  In times of financial restraint such an anomalous situation is bound to lead to reduced funding being available for maintenance, whether preventative or reactive, in order to have sufficient available to obtain the "geared" central government contribution to capital works.

  5.3  A situation can (and has) occurred where an ordinary watercourse (non main river) requires works to alleviate flooding. As the local authority can obtain a higher rate of MAFF grant aid than the Environment Agency the works would be carried out prior to enmaining, rather than after.

  5.4  A further funding aspect, which can work against making the best overall use of funds, is the annuality of the funding cycle. A specific budget (MAFF Grant Aid or operating authority flood defence) is made available for a financial year, and it is important to spend exactly this and no more. As funds unspent in one year cannot be carried over into the next financial year this can mean pressure to commence construction of schemes in the winter period in order to spend money by 31 March. Alternatively overspend on one scheme can defer another from its programmed start year.

  5.5  The current arrangement is that funds for flood defence schemes are raised from local levies (Environment Agency), council taxes (Local Authorities) or drainage rates (Internal Drainage Boards). However, flooding is a natural phenomenon that knows no organisational boundaries, and the Easter 1998 floods, for example, showed that the very severe flooding in the Midlands was not reflected in other parts of the country.

  5.6  The local funding arrangements mean that if there was found to be a greater need in one part of the country than in another there could not be a transfer of funds to meet the greater need. In fact, the "local" description of the funding is largely artificial, since most of the levies, taxes and rates are funded indirectly for central government.

  5.7  It would therefore seem appropriate to remove all local funding, and ensure that central government funds were made available for all flood defence work, which could then be prioritised on a national basis. This could also avoid a great deal of bureaucracy in the interfacing of the current funding arrangements.

6.  KEY ISSUE—ORGANISATION

  6.1  Floods are a local issue, but have national importance, and their magnitude requires a national overview, with the setting of national priorities. In addition, a nationally consistent approach to dealing with flooding problems is needed, as currently the standard of protection provided to property at risk can depend as much on who the operating authority is, or its Region, as on any guidelines or economic appraisal.

  6.2  Perhaps the main reason is that flood and coastal defence in England and Wales is a very fragmented business. The Environment Agency is a structured national organisation, but is only responsible for designated "main river" watercourses, and for sea defence (work to reduce the risk of flooding by the sea or tidal rivers). It is therefore not able to use its permissive powers for flood defence to address all types of flood risks.

  6.3  Other watercourses may be the responsibility of Internal Drainage Boards, where these exist, but in all other areas such "ordinary watercourses" are the responsibility of the local authority, for whom flood defence is not usually part of their "core business". If there were to be a single Flood and Coastal Defence Authority the need for "main river" designation, and its sometimes arbitrary application, would be obviated. However, if such a designation of watercourses is to remain then guidelines are needed, agreed by all parties, on the criteria for "main river" watercourses.

  6.4  Coastal defence responsibility is just as fragmented, as the Environment Agency is only responsible for sea defence, with coast protection (prevention of erosion and encroachment by the sea where this is deemed necessary) being the responsibility of the relevant maritime authorities, of which there are many. A good interface between all coastal operating authorities is essential, as the effect of works on one shoreline can have severe effects some distance along the coast. Such interfacing and co-ordination of works is not always possible, perhaps because of individual funding constraints, or alternatively local pressure to carry out works independently.

  6.5  The involvement of MAFF in flood and coastal defence originates from the days when the nation needed to produce greater quantities of food, and so agricultural production was increased by draining large areas of wet or marginal land, and improving the drainage of existing farmland. However, the emphasis has now changed from land drainage to flood defence, where reducing the risk of flooding to people and property is the prime aim. The main operating authority is now the Environment Agency, a regulatory body, reporting to the Department of Environment, Transport and the Regions (DETR). We believe the continuing role of MAFF and the Environment Agency in flood and coastal defence should be critically examined, with a view to moving responsibility from MAFF to DETR.

  6.6  The MAFF approval process tends to duplicate those of the operating authorities, especially the Environment Agency, and it must be questioned whether it is appropriate to have a government department vetting a large part of the expenditure of another government agency. This is especially pertinent as the Treasury take an overview of all Environment Agency expenditure.

  6.7  The issue of local funding has been addressed above. In the Environment Agency flood defence funding is mainly the responsibility of individual Regional Flood Defence Committees (RFDCs), who approve where the (ostensibly) locally raised funding is to be spent. (There are, however, differences between Regions). The RFDCs comprise a majority of local authority members, in order to safeguard the proper usage of levy funding raised by those local authorities as part of the council tax. The RFDCs have a statutory role, but their boundaries, and possibly their policies, are no longer always coincident with those of the Environment Agency.

  6.8  If central government funding were to be instigated for a national Flood and Coastal Defence Authority the RFDCs would become advisory bodies, albeit with a wider remit than their current limit of "main rivers". However, as such an authority would be responsible for the flooding problems currently addressed by local authorities the current membership would still seem appropriate.

  6.9  In areas of the country where there are special drainage needs Internal Drainage Boards (IDBs) have been set up. In many cases these provide the means of drainage for areas below adjacent river levels, or below sea level, either by pumping or by intermittent gravity discharges. These are locally run and obtain most of their revenue funding locally, although significant proportions of capital funding are from external sources such as MAFF.

  6.10  IDBs are generally seen as carrying out excellent work, and are locally accountable to the residents and businesses in the area that they cover. It is suggested that no change is needed to the organisation of the IDBs, although their relationship to other bodies, and their sources of funding, should be reviewed.

7.  CONCLUSIONS

  7.1  CIWEM welcomes the opportunity to present evidence to the Agriculture Committee, and considers that while the flood defence and coastal protection of England and Wales has been successfully implemented in the past, a review of the current structure and funding of the business is appropriate.

  7.2  CIWEM considers that social and environmental aspects of flooding and flood defence works should be given much greater recognition in project appraisal, to complement the current emphasis on an economic analysis that only measures the more tangible aspects of flood damage.

  7.3  CIWEM recommends that a national Flood and Coastal Defence Authority should be considered, with central government funding for all flood and coastal defence capital and maintenance works, and that this Authority should have Executive Committees with local accountability. Internal Drainage Boards should remain, but their relationship with any new body, and their funding sources, should be reviewed.

  7.4  CIWEM further recommends that the national Flood and Coastal Defence Authority should have powers to oversee all watercourses, thus obviating the need to designate some as "main river", as at present, and thereby providing a "one stop shop" for problems of flooding from natural watercourses.

April 1998


 
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