Memorandum by Ian Bonas, Chairman, North
East REPAC (EA 83)
During the meeting on Tuesday 14 December at
which Pamela Castle and I were giving evidence to the Sub-committee
I agreed to send a copy of the NE REPAC's "trial run"
report for the year to April 1999 which includes a section on
the performance of the Agency. This I now enclose. I would like
to mention that it was written by me personally with advice from,
and on behalf of the NE REPAC, not by the Agency staff. Please
also find enclosed the similar report by the Southern REPAC which
you requested on the telephone.
There are also one or two points which we did
not quite have time to cover on Tuesday and which I would like
to make to the committee as follows:—
1. RESOURCES
Our (REPAC's) concern at the shortage of resources
available within the Environment Agency for Environmental Protection
is growing. The 70 or so "Ringfences" referred to in
the Agency's own submission at 4.1 are certainly part of the problem
and we would support the Agency's proposal for rationalisation.
However the Agency needs to demonstrate that
the money it already has is well spent. In our view its prospects
of finding a sympathetic ear for more resources for Environmental
Protection are seriously hampered by lack of transparency eg in
its charging. The current Process Industry Regulation day rate
for an Inspector visit is £1,215. Of this sum approximately
£165 is understood to go to the Inspector himself and the
rest is overhead. This is quite out of line with experience of
what is charged for a similar standard of work by other organisations
eg HSE, but perhaps more important no adequate explanation is
given. This given the Agency a bad name and makes it appear inefficient
whether it is or not.
Next there is a danger that the Agency, finding
itself in a tight funding position, may be tempted to restrict
spending on its proactive or "facilitating" role as
resource is concentrated on what it perceives as its core regulatory
function. This could adversely affect Waste minimisation, conservation,
partnership project work (NE partnership project budget last year
was £250,000, this year £100,000 losing "partner"
contributions of nine times the difference), education, sustainable
development and environmental awareness and recreation. Taken
together the effect of shifting resource from these areas could
be serious. They are all known to be of concern to the AEGs as
well as REPAC in the NE region.
It is not REPAC's job to micromanage. We are
uncomfortable however about the Agency's developing resource problem
and its likely knock on effects. To the extent that external funding
is not available some radical thinking may be required by the
EA management to achieve substantial cost savings.
REPAC's role in this would properly be to give
a view on the "outcome" priorities involved, ie possible
changes in environmental emphasis and the likely public perceptions
of them in the Region, rather than deciding the management mechanisms
to achieve savings (though we have some ideas on possible mechanisms).
At this stage it is unclear as to how much could be gleamed, or
by when, from radical cost saving activities. It would however
be unacceptable for the Agency's proactive non-regulatory work
to be so seriously damaged that the Agency loses credibility.
Flood Defence funding is another major issue.
Historically Local Authorities have generally not passed on to
Flood Defence Committees all the funds awarded to them for Flood
Defence. As you have no doubt been advised already, this has led
to a dangerous shortage of funds for Capital works in an era of
climate change. Without adequate funds there is a significant
risk of loss of life and damage to property in both the short
and long term. There has been at least one specific instance in
the Northern region where such funds have not been so voted by
a Flood Defence Committee (the Northumbrian) against the advice
of both the EA staff and myself as REPAC chair and member of the
Flood Defence Committee and as a result a potentially life saving
scheme has been delayed. After much protest by the Agency and
the threat on my part to resign this particular situation in Northumbria
is being repaired.
Nationally however there remains a major funding
problem in Flood Defence and the public, given the wide acceptance
of climate change, are unlikely to be forgiving if there is a
disaster which was foreseeable and could have been avoided.
2. STRUCTURE
OF REGIONAL
COMMITTEES
During the meeting I suggested that there should
be a review of the structure of Regional Committees and was asked
what my solution would be. I am not aware that I made all of the
following clear: my suggestion (designed to reduce staff load
and improve quality and representation) would be:
— Abolish all the present committees.
It is worth noting that the AEGs are non statutory but invented
by the EA itself.
— Establish a Regional Advisory Board
(RAB) to take over the work of REPAC and the existing Regional
Advisory Panel (RAP). Meetings monthly, members paid.
— Establish two or three AEGs in each
region reporting to the RAB to take on the work of local Environmental
Protection advice, Flood Defence and Fisheries (including conservation
recreation etc). It would be these AEGs which would relate to
the institutions of Regional Government and in our region could
be made (nearly) co-terminous with them unlike the present NE
REPAC. The AEGs would be advisory and not executive which would
mean a change in the National funding arrangements for Flood Defence.
Meetings quarterly, chairman member of RAB.
The above would so far as I understand require
significant primary legislation. Since this is likely to be some
time away (at best), a short term solution might be for the EA
to abolish the AEGs in their existing form since there seems be
some uncertainty as to their present role.
Ian Bonas Chairman
December 1999
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