COMMENTS
ON INLAND
(FLUVIAL) FLOOD
DEFENCE
1. This paper complements The Wildlife Trusts'
national response. It is based primarily on 10 years involvement
with the Somerset Levels, during which I was the first ministerial
environmental appointee for the Wessex Regional Flood Defence
Committee and the only non-farmer on the 1991 Water Level Strategy
steering group. I am now a member of the Environment Agency's
South-West Regional Advisory Committee.
Priorities: Life and Built Property
2. I support over-all Environment Agency/MAFF
priorities for flood defence: with top priority to the protection
of human life; and second priority to the protection of "property",
provided this is defined as the public built environment. I have
no particular criticism to make of the way in which these priorities
are pursued.
Agricultural Land Drainage and Flood Defence
3. My disagreements have long centred entirely
on the area of land drainage for agriculture. I believe that the
institutions and attitudes of a bygone era, when the aim of national
policy was to maximise food production, continue excessively to
influence MAFF and EA policy in inland flood defence. Public expenditure
on agricultural land drainage now conflicts with the whole thrust
of agricultural policy, reinforced by Agenda 2000 whose emphasis
is on market forces in food supply, and public payments only for
public benefits.
Drainage and Wetlands
4. "Drainage" by definition makes
wet land drier—in "wetlands" it is synonymous
with wetland damage or destruction. Yet wetlands are increasingly
valued, at national and European level, for their wider ecological
functions.
Drainage and Floodplains
5. Most such drainage takes place on floodplains;
in these areas, every additional capital works project for improved
land drainage since the war has had the effect of:
(a) moving a problem of flood storage further
on downstream, causing faster times to peak of downstream floods;
(b) ratcheting up in perpetuity the maintenance
cost of an increasingly artificial fresh water system;
(c) encouraging more intensive farming methods,
with their associated costs in terms of reduced water quality,
(diffuse-source pollution from fertiliser, herbicide and pesticide);
(d) reducing the capacity of local fisheries;
(e) on peat soils, increasing permanent soil
loss through drying;
(f) increasing air pollution and climate
change, by facilitating the ploughing of peat soils and their
oxidation direct into additional CO2 emissions;
(g) representing a double subsidy from public
funds to floodplain farmers, enabling them to increase food production
and hence increase their subsidy level from mainstream CAP commodity
programmes;
(h) reducing natural (cost-free) flood storage;
(i) reducing wetland biodiversity;
(j) reducing the wetland's ability to perform
a water purification function;
(k) encouraging further marginal development
in the floodplain, which in turn constrains the options for later
restoration;
(l) reducing available water resources by
removing heavy rainfall out to sea as quickly as possible.
In an age of "dig for victory" all
these costs were worth paying for more food. They no longer are.
Drainage interests on Flood Defence Committees
6. Yet executive Flood Defence Committees
continue to have chairmen appointed by MAFF, many with a farming
background, many of those with a long-term commitment to "improving"
agricultural land by drainage.
The nature conservation duty; and private property
7. The agency has a legal duty to conservation,
but only permissive powers to protect private property from flooding.
While I support the continuation of a public built environment
flood defence function, the Agency should not run any of its own
flood defence programmes to the detriment of important ecological
interests, because of a mistaken fear that it is otherwise duty
bound to flood-proof purely private properties. Given due notice
of a change in standards of service, there is no more reason why
the Agency should flood-proof private landowners' property than
that the police should burglar-proof them, or the fire brigade
fire-proof them.
Budgetary ring-fencing, and pass-through
8. Furthermore, the presence of elected
Councillors on Flood Defence Committees only achieves control
of flood defence spending when budgets are actually declining.
In periods of stable annual expenditure, the combined effects
of the ring-fencing of flood defence money, and 100 per cent pass-through
the local authority's accounts after one year give local authorities
in practice an incentive to maximise rather than minimise spending.
(Albeit the reduction in budgets in recent years has forced more
rigorous prioritisation, notably in favour of coastal and against
inland flood defence projects).
The institutional paradox—division, not
integration
9. The Agency rightly stresses the need
in all policies, notably its Local Plans (LEAPs) to integrate
environmental issues; but remains itself divided, with roughly
half its budget, covering almost all its physical interference
in the river system, controlled by autonomous FD Committees accountable
to a different government Department (MAFF).
Recommendations for change
10. I recommend:
(a) the transfer of the main Flood Defence
department from MAFF to DETR; so that the Agency can implement
a single integrated budget, embracing flood defence, water quality
and water resources; accountable through a single national Board
to a single government Department;
(b) that the Flood Defence Committees be
abolished as executive bodies, and replaced with regional advisory
committees;
(c) that the Agency's local accountability
be restored and enhanced by a stronger role for the Area Environment
Groups;
(d) that the historic internal tensions between
the Agency and the Internal Drainage Boards (IDBs) be resolved
by making clear that the IDBs are subordinate to the Agency;
(e) that the Agency be reminded of its statutory
duty to conserve biodiversity, contrasted with its permissive
powers to protect properties from flooding;
(f) that MAFF take account of necessary Environment
Agency action on inland flood defence management, and its impact
on farmland in floodplains, when designing their own agri-environment
schemes.
15 April 1998
