Memorandum submitted by Colin Green, Flood
Hazard Research Centre, Middlesex University
2ND CONSULTATION
ON THE
WATER FRAMEWORK
DIRECTIVE
This document sets its sights low; it treats
the WFD as an end in itself and does no more than discuss the
minimum requirements to translate it into national law. However,
the WFD effectively embodies the Dublin principles that defined
the criteria necessary to achieve the sustainable management of
catchments. In theory, therefore, the WFD is a great opportunity
to define visions of the sustainable management of catchments,
to establish the means to achieve those visions, and then to set
about achieving those visions. This is exciting, something that
the consultation document manages to avoid. At the same time,
it avoids approaching the contradictions that are embodied in
the WFD ie between economics and public involvement (in neoclassical
economics, values are defined by the individual in personal, subjective
terms whereas public involvement is inherently a social process
out of which values will emerge as a result of argument, negotiation,
and debate); and between public involvement and the pre-determined
objective of good water quality.
Again, although the Commission website on the
WFD refers explicitly to integrated catchment management, this
document focuses on the simpler technical questions (eg the relationship
between the river basin management plans and the periodic review)
rather than on the critical strategic questions (eg what would
be required to achieve good water quality, how are we going to
do it?). A starting point for considering how we are going to
achieve the visions that will be embodied in the catchment plans
is a map of the stakeholders: who has what interests and what
capabilities/powers/money.
I would have expected to see more reference
to alternatives; the economist will insist that there are always
alternatives, and the problem is to select between them (equally,
the document offers the thinnest form of consultation: are you
content with what is being proposed? eg questions at 11.61 and
pretty well everywhere else—Aarhus demands more than this).
On public involvement, the phrasing of the question at 14.5 is
odd since it implies that there is a contradiction between the
information requirements under WFD, under Aarhus, and under the
Freedom of Information Act.
I would have liked to see reference to successful
implementations in other countries of the principles embodied
in the WFD, and of the lessons learnt from the LEAP experience
in England and Wales. The Parrett Catchment Partnership is seen
overseas as the best UK example of catchment management: what
then are the lessons of the Parrett? Is it seen as such in the
UK, and, if not, why not? Equally, some attempts at catchment
management in other countries have been abject failures: what
do we need to avoid doing?
In particular, the institutional framework is
still vague: if the actions necessary to achieve good water quality
are considered, then the co-ordinated actions of a great many
stakeholders are required; who are they, how will they be persuaded
to co-ordinate their actions, what are the barriers and incentives,
how will their actions be co-ordinated?—hence the need for
the stakeholder map. At 11.6, it proposed that the Agency should
be given powers to tell everyone else what to do: there are rather
a lot of obvious drawbacks to this approach. If the stakeholder
map had been prepared, it would be clearer who it is suggested
that the Agency be empowered to require to act in particular ways.
Is it proposed that the Agency be given authority over land use
planning decisions or the implementation of the CAP? If not, what
exactly what powers are being proposed? Will these be sufficient
to deliver the vision?
Since these are quite sweeping criticisms, I
have to put up or shut up; therefore, I attach a couple of background
papers [not printed] prepared for a project that, although focused
on flood management, is set within the context of Integrated Water
Resource Management.
We are running out of time in developing a coherent
framework for implementing the WFD and the consultation document
leaves us a long way to go.
Colin Green
Flood Hazard Research Centre, Middlesex University
28 November 2002
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