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
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
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
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
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.
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
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
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
- understand the needs of the public and the environment
- are prepared to enforce authorisations firmly
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.