Select Committee on Environment, Transport and Regional Affairs Sixth Report


Visit to the South-West, Thursday 13th/Friday 14th January 2000


Mr Andrew Bennett MP (Chairman) Dr David Harrison (Clerk)
Mr Hilary Benn MP Mr Huw Yardley (Clerk)
Mrs Louise Ellman MP Mrs Susan Morrison (Assistant)
Mr James Gray MP Mr Stephen Tromans (Adviser)
Mr John Randall MP


Somerset Levels and Moors

The Somerset Levels and Moors covers 60,000 hectares and is the most important remaining lowland wet grassland in England. Its drained marshes are subdivided by ditches and rhynes, with communities located on higher land. Some 10% of the area is considered to be a wetland of outstanding ecological importance in a European context.

The Levels lie just above sea level and form a barrier of land between the Moors and the Severn Estuary, which has the second highest tidal range in the world, with tidal levels up to five metres above the lowest land. The Moors, which lie further inland, are low-lying peat moors, overlaid in some areas by clay. Surrounding the Moors are a series of hills including the Mendips, Blackdowns, Brendons and Quantocks. Water from these high areas has to pass through the Moors and Levels on its way to the sea. The area is thus prone to large-scale flooding which has to be managed through a system of defences and drains.

The Environment Agency, in consultation with Internal Drainage Boards (IDBs), operates and maintains 21 pumping stations and hundreds of sluices on the Levels and Moors. These manage both winter water levels, in the face of high tides and flood flows, and summer levels for irrigation and wet fences for livestock.

The Agency's management of the Somerset Levels and Moors is conducted in consultation with a number of other bodies with interests in the area. The Agency brought representatives from a number of these groups together to form a Steering Group to provide guidance on a new Water Level Management Strategy and Action Plan for the Somerset Levels. The Strategy and Action Plan, which was published last year, identifies key issues for water level management outside flood situations and sets out a programme of actions to implement changes. The changes have been driven primarily by the need for additional measures to restore and safeguard the conservation and biodiversity interests of the wetland yet retain sustainable agriculture in the area.

Following a visit to Burrow Mump, a vantage point on the Levels near Burrowbridge, the Sub-committee were taken to Curry Moor Pumping Station, where one of the pumps which the Agency operates is situated. There they spoke to a number of Agency staff and others about the production of the new Strategy and Action Plan in particular, and the Agency's management of the Levels and Moors in general. A particular issue which arose was the extent to which the Agency takes the interests of wildlife into account in its control of water levels on the Levels and Moors.

Roger Martin, Director of Somerset Wildlife Trust and a member of the Steering Group, told the Sub-committee that the problem with the internationally important wetland which was the Levels and Moors was that - despite the deep flooding which was affecting the area at the time of the Sub-committee's visit - it was too dry. In six months time, he said, the Levels would be largely covered in intensively managed rye grass, effectively wildlife sterile. This meant that most of the area could no longer be considered a 'wetland', and the wildlife of the area was suffering - breeding snipe, for example, were more or less extinct outside designated nature reserves.

The reason for this situation, in his view, lay with the Agency's operation of the pumps and sluices which control how much water remains in the wetland. The basic management of these pumps and sluices had remained unchanged for some twenty years, since the introduction of the Wildlife and Countryside Act. At that time, he said, water levels had been set explicitly for agricultural drainage, with the aim of increasingly agricultural productivity, albeit at the expense of wildlife. The Agency could ensure a better wetland, and hence a better habitat for wildlife, by simply changing its own pump and sluice settings. However, it did not do so for two reasons. Firstly, in traditional local political culture, the Sub-committee was told, the Agency was the 'servant' of the Internal Drainage Boards, which represent agricultural land drainage interests. Secondly, the Agency did not act from fear that it would be liable for compensation in the event that it took action which, in making agricultural land wetter, thereby affected its value. Internal Drainage Boards thus wielded an effective veto, he suggested, over any change in the Agency's management of its own pumps, a veto which they used in order to maximise the incomes of the farming community.

David House, a local farmer, member of the Stanmoor Internal Drainage Board and Association of Drainage Authorities representative on the Steering Group, disputed Mr Martin's view that the Internal Drainage Boards held any power of veto over any change in the Agency's management of its pumps and sluices. However, he was of the opinion that the current powers of Internal Drainage Boards over water levels on their particular moors should not be restricted. The Somerset Levels and Moors were very diverse. Only those who lived and worked in a particular area could understand its unique character and problems, and therefore only the local Internal Drainage Board was in a position to make decisions in the best interests of the people and the environment of the area. He made the point that the Somerset Levels and Moors were created by human activity, and that their continued existence likewise relied upon continued management by local people. For this reason, it was important to ensure that the farming industry, currently in decline, was supported. The Environmentally Sensitive Area grant payment scheme had helped, but much more had to be done.

Roger Martin similarly praised the Environmentally Sensitive Area scheme, but believed more had to be done by the Agency to protect the wildlife of the area. He noted that the Wildlife Trust had commissioned an independent legal opinion in an attempt to identify the legal complexities of the Agency's relationship with the Internal Drainage Boards, particularly in view of the Agency's responsibilities in the area under international law for wildlife and habitat conservation. He also suggested that Parliament could affirm the Agency's right to overrule the Internal Drainage Boards when necessary in the public interest. Given the powers, and the willingness to use them, he said, the Agency could negotiate with the Internal Drainage Boards from a position of strength, rather than its current weak position, and ensure that the necessary changes in main river management and engineering were made such that proper regard was taken of the internationally important wildlife interests of the area.

On leaving Curry Moor Pumping Station, the Sub-committee went to the Agency's Area Office in Bridgwater, where they had the opportunity over lunch to speak to local Environment Agency staff. They were then taken up the M5 towards Bristol and the Cribbs Causeway Regional Shopping Centre. During the journey Agency staff pointed out a number of sites where the Agency had played its role as a statutory consultee on planning matters to ensure that environmental considerations were taken into account in new developments. This included ensuring that flood defence, conservation and recreation objectives were integrated into such developments.

Cribbs Causeway, South Gloucestershire and Blaise Castle Estate, Bristol

The Hazel Brook rises north-west of Bristol, close to the M4/M5 motorway interchange and Filton Airfield. The Hazel Brook/Lower Trym valley is a unique green corridor in North West Bristol which permits relatively uninterrupted access to the river from its source to its confluence with the tidal River Avon. The landscape and headwaters were, until 15-20 years ago, principally rural in nature. The area is now dominated by urban developments, the M5 motorway, commercial trading estates, leisure facilities, and Cribbs Causeway Regional Shopping Centre, the largest development of its type in the South West.

From its source, the watercourse passes through the post-war residential neighbourhoods of Brentry and Henbury via large areas of public open space: significant sections of the river channel are in engineered straight-line-channel intended to reduce the risk of flooding. Immediately south of Henbury the Hazel Brook flows through the Blaise Castle estate. This is a historic landscape designed in the late 18th century by Humphrey Repton around the most dramatic component of the catchment, a steep-sided natural limestone gorge which bisects the estate. Finally, the watercourse joins with another principal tributary and the River Trym then flows through a series of wooded glens and areas of open space contained in a relatively narrow valley again bordering residential development. Originally, there was a strong tidal influence on the lower reaches, but the extent of this is now checked by a man-made concrete weir/sluice gate structure.

The biggest influence on the character of the Hazel Brook and Lower Trym has been the massive developments adjacent to Junction 17 of the M5 motorway. Construction of the motorway and associated road network opened the once rural Cribbs Causeway area to development potential, which has continued since the mid 1970s. Rapid surface water run-off from the developments, with the associated car-parking areas for 12500+, has adversely affected the watercourse, despite the incorporation of significant mitigation measures. Greatly increased surface run-off volumes and 'urbanisation' pollution impacts have combined to limit establishment of marginal vegetation and silt deposition particularly in the Blaise Castle on-stream lakes.

The Bristol Avon Local Environment Agency Plan identifies four issues which are relevant to this catchment:

  • the impact of new development on drainage;
  • the impact of urbanisation on water quality;
  • river rehabilitation and channel management;
  • recreation pressure and opportunities.

These issues tie in with the Agency's duties in a number of areas, not least as a river basin manager, as a statutory consultee on planning applications, and in promoting recreation. As a result, the Agency has contributed to a collaborative project with Bristol City Council to produce the Hazel Brook/Lower Trym Action Plan, intended to improve the conservation and recreation value of the river valley through the City of Bristol. The plan was commissioned in 1998 and produced for the partnership by Nicholas Pearson Associates, Environmental Planning and Landscape Architecture Consultants, and formed the basis of a successful £2.7 million Heritage Lottery Fund grant bid. Other parties who have been involved in the Development of the plan include the Forest of Avon, Green Networks SRB and community group The Friends of Blaise.

The Sub-committee was shown around Cribbs Causeway shopping centre, and saw the impact which the development had had on the local environment. They then proceeded down the Hazel Brook valley to the confluence of with the River Trym at Coombe Dingle, where they were met by Jim Hardcastle, Bristol City Council Heritage Estates Officer, and David Robertson of 'Friends of Blaise'. They were shown around the site and discussed with them and with Agency staff issues related to the Agency's management of the Hazel Brook catchment.

Rio House

Finally on Thursday the Sub-committee visited the Environment Agency's headquarters, at Rio House in Bristol, to see a presentation on the work of the Agency's National Centre for Environmental Data and Surveillance (NCEDS).

NCEDS is the Environment Agency's focus for environmental data collection and interpretation, and for the development of environmental monitoring techniques. It addresses these core requirements:

  • collation of the Agency's internal environmental monitoring data in order to fulfill its various statutory obligations;
  • creation of an integrated picture of the state of the environment and the pressures placed upon it, by relation of these data to other internal and external data sets;
  • application of a consistent level of quality control across all the Agency's environmental data;
  • delivery of supra-Regional environmental monitoring and surveillance programmes;
  • conversion of data into meaningful information for the Agency, the Department of the Environment, Transport and the Regions, the European Environment Agency, other international bodies, and the public;
  • development of better and more effective environmental monitoring techniques; and
  • management of relevant research and development programmes.

The Sub-committee received presentations on two particular systems which NCEDS uses to collect its own data: Light Detection and Ranging (LIDAR) and Compact Airborne Spectrographic Imager (CASI). LIDAR is an airborne mapping technique which uses a laser to measure the distance between the aircraft and the ground. The information thus produced is used for a number of purposes, including to fulfill the Agency's statutory duty to monitor the flood plain and to examine land being set aside for managed retreat of sea defences. CASI is used to help the Agency in its duty under the Environment Act 1995 to form an opinion on the general state of the pollution of the environment. The imager, installed in a small aircraft, collects information from the visible and near infra-red regions of the spectrum which is built into coloured images and used for, for example, land classification; inter-tidal vegetation mapping; contaminated land assessment; or pollution detection and monitoring. The Sub-committee were shown how these techniques were used to build up a picture of what happened in the Sea Empress oil spill case in Milford Haven.

The National Centre's Environmental Data Management System (EDMS), which facilitates reporting on the state of the environment, was also demonstrated to the Sub-committee. To aid the task of reporting on the state of the environment, the National Centre has to gather significant amounts of detailed environmental data. The bulk of the data are sourced from the Agency's eight regions and Central Functions, which use a variety of computer systems and databases, primarily for local operational purposes.

To avoid transferring and maintaining large quantities of data, a central database containing detailed index data (meta-data) describing all the distributed data has been established. This meta-database contains all the information necessary to build queries which extract the latest data from the local master databases. The central meta-database (ORACLE) is updated regularly from these local databases. The Sub-committee was shown how information relating to, for example, Parliamentary constituencies could be drawn out of the databases to produce maps or tables of environmental data relating to, for instance, bathing water quality; fish stocks; chemical releases; or types of habitat.

Finally, the National Centre's responsibility for a section of the Environment Agency's website known as "Your Environment" was demonstrated to the Sub-committee. This responsibility includes development of Internet technology to promote the world wide web as a national resource for improving accessibility to environmental information. The main means of achieving this is the "What's in Your Backyard" feature, within which users can zoom in to any area of England and Wales by entering a postcode and access details of any Pollution Inventory site or designated bathing water. In addition, the site includes the "K-Zone" and "Pressure Point" features, targeted at children and youth respectively, with the intention of promoting environmental issues and awareness; the site is also used to carry out surveys of the public and to present the Agency's Environmental Strategy; and it carries environmental information on topics such as water resources and energy consumption which form a holistic representation of the state of the environment in England and Wales.



The Sub-committee was met on Friday morning by Tony Owen; Ian Legge, Area Environment Protection Manager; Steve Chandler, Environment Planning Manager; and Mick Smith and Jim Pagington, Process Industry and Radioactive Substances Regulation (PIR/RSR) Inspectors, for the visit to the Avonmouth industrial estate.

The Agency's work at Avonmouth includes the regulation of 12 Integrated Pollution Control (IPC) sites. IPC is the term used for the regulation of the most complex and potentially polluting sites. Detailed applications are required for all potential IPC sites demonstrating compliance with Best Available Techniques Not Entailing Excessive Cost (BATNEEC) and Best Practicable Environmental Option (BPEO). For each approved site a detailed authorisation is produced identifying all emission points and containing an programme of improvements which will lessen the site's impact on the environment. Regular inspection and monitoring of adherence to the authorisation conditions is carried out by Agency inspectors.

The Agency is also, along with the Health and Safety Executive, the joint 'competent authority' for the Control of Major Accident Hazards (COMAH) Regulations, which cover those sites presenting the highest human and environmental hazards. 'Upper tier' (the most hazardous) sites, of which there are eight at Avonmouth, must submit a comprehensive Safety Report explaining the potential hazards, and how they are eliminated or mitigated. Safety Reports are assessed in detail by the Agency and the HSE, and inspection takes place on at least an annual basis.

Fourteen sites at Avonmouth have waste management licenses issued and enforced by the Agency. These licenses cover waste treatment and disposal (where not covered by IPC authorisations). The operator is required to produce a detailed Working Plan for compliance with the licence conditions, and the Agency undertakes frequent inspection of the highest risk sites as assessed under OPRA (Operator Performance Risk Appraisal). In addition, the industrial estate contains some 16 sites which the Agency regulates under the Radioactive Substances Act; and the Agency has responsibility for monitoring discharges to waters in the area, including the Severn Estuary.

The Sub-committee were told that quality of staff was a key issue for effective regulation of major industry. Regulation of complex industrial processes requiring environmental investment of what can amount to millions of pounds requires staff who

  • fully understand process design - what can and can't be done
  • have plant management experience and know how plants should be run
  • are confident and persuasive negotiators with senior management/directors
  • understand the needs of the public and the environment
  • are prepared to enforce authorisations firmly but fairly.

For major multi-functional sites the IPC inspector is also a 'Customer Account Manager'. The Customer Account Manager is the primary point of contact between the company and the Agency. He or she coordinates regulation on the site, ensuring that the Agency does not make conflicting demands, and seeks the Best Practicable Environmental Option (BPEO) for the site as a whole.

The Sub-committee was told that all IPC sites at Avonmouth will shortly come under the new Integrated Pollution Prevention and Control (IPPC) regime. This regime will require staff competencies to be extended to contaminated land, noise and energy efficiency, and the Agency will need to extend the current 'Account Manager' system to form a 'Permit Team'.

Rhodia Organique Fine Limited

Once at Avonmouth, the Sub-committee was taken to the site operated by Rhodia Organique Fine Limited, a speciality chemicals company. Rhodia employs 23500 people worldwide with 104 sites and sales of 5.5 billion euros. Its Avonmouth site has been producing chemicals since 1917. At the present time most of its products are based on fluorine chemistry: these include hydrofluoric acid, anaesthetics, intermediate products for the agricultural and pharmaceutical industries, and refrigeration products. 250 people are employed on the 70 acre Avonmouth site, generating a turnover of £50 million. The Agency's involvement with the site comprises the regulation of seven process authorisations under IPC, one waste management licence, one water abstraction licence, and two radioactive sources; and joint regulation of the site with the HSE in respect of the COMAH Regulations.

The Sub-committee toured the site in two groups, one viewing the Isoflurane Plant, which produces anaesthetics for use in the medical and veterinary sectors, and one the Isceon 22 Plant, which produces refrigeration products. It was explained how the Agency's inspectors get involved at all stages of the process to try, wherever possible, to minimise its environmental impact; the Sub-committee was also told about the steps which Rhodia had taken unilaterally to reduce emissions and waste from its Avonmouth site. As well as controlling emissions, Agency inspectors' interventions can produce economic benefits, for example by suggesting ways in which the efficiency of a particular manufacturing process can be improved.

Finally, the Sub-committee briefly discussed the Agency's work at the site with John Seeley, the site director, and members of his staff. Topics covered included the impact of the landfill tax, cooperation between the Environment Agency and other bodies such as the Health and Safety Executive and the US Food and Drug Administration, and the quality of Agency staff. A particularly important point made was that less experienced and lower-paid Agency inspectors would not benefit industry: whilst it might conceivably be easier for site managers to 'pull the wool over the eyes' of less experienced inspectors, such inspectors could equally be more prone to irrational, erroneous and potentially costly decisions which would not be made by those with more experience.

Allied Metals Avonmouth (Philip Services Europe Ltd - now Simsmetal UK Ltd)

To end the visit, the Sub-committee were shown around another site regulated by the Agency, the Philips Services (now Simsmetal UK) fragmentiser.

Simsmetal UK's core business is the recovery and recycling of end-of-life consumer goods into high quality materials for re-use. These end-of-life goods, typically motor vehicles and white goods, are fed into a fragmentiser, which consists of a rotor containing 16 hammers revolving at a speed of 500 rpm. From this process is produced fragmentised steel (around 72%) non-ferrous debris (around 5%), from which non-ferrous metals are recovered after further processing, and around 23% shredder fluff which at present goes to landfill.

The plant's environmental impact includes airborne emissions and contaminated surface water runoff; the problem of dust is currently being monitored due to localised concerns. That part of the 'frag waste' which cannot be reused and thus has to be sent to landfill is not inert and contains some hydrocarbons. There may be a very low level of PCB contamination from the electronic components passing through the plant.

If the plant, which predominantly receives material from Taunton, Barnstaple, Plymouth and Bristol, were to close, the nearest alternative is in Cardiff, presenting higher environmental and financial costs through the additional transport requirement. Operational procedures include the detection of radioactive sources which prove costly for the operator if discovered after a load of scrap materials has been accepted. The Sub-committee was also told that the introduction of the landfill tax had increased the costs of the operation, reducing the amount which could be paid for scrap; as a result there was less incentive for end-of-life vehicle owners, for example, to pay for the disposal costs to the fragmentiser site, and they would simply be dumped instead.

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