Memorandum submitted by Louis Jankel
1. How successful the Environment Agency
has been in its role as enforcer of environmental regulation and
controls, and how well it manages its wide range of activities;
The Environment Agency (EA) is not always master
in its own house and has to endure frustrations from legislators.
A recent example is "Chemicals entering the environment"
where the white paper proposals are seen as economically too onerous
on the industry; meanwhile less ethical elements put our environment
at risk.
In what the EA attempt they manage to achieve
significant impact and effect. Their excellent implementation
of the plethora of EU water quality regulations is an example
to the other national environment management departments across
Europe.
2. Whether the Agency operates efficiently
and provides good value for money;
Within what they do, they have a culture that
is "value" centred. In some areas, they are very efficient
with their use of money. I would recommend River Thames Navigation
section where real initiatives to produce good value are involving
not just all levels of staff but stakeholders as well.
The antithesis of this is the current consultation
on Water Abstraction. Here the EA has been "brow beaten"
by the water companies into removing any element of incentive
charging on annual water consumption. If it is policy to persuade
the public to economise on water use, then why should not the
water companies to do the same? What a marvellous opportunity
to force the water companies into efficiencies by charging them
more for water if they do not improve performance. I would suspect
water loss from leakage might improve dramatically if the water
companies' P&Ls became involved. This Water Abstraction consultation
is not one of the EA's finer works and if enacted in current form
will rebound with considerable bad publicity.
3. The structure, governance and accountability
of the Agency.
See the reply to item 9.
4. Its relationships with Defra, Defra-sponsored
bodies and the rest of Government, including the Agency's role
in the planning system.
The example I offer I have observed over the
past three months. Recently the EA set the annual increases in
navigation charges to be paid by their customers. The "agenda"
was dictated entirely by Defra and this caused serious conflict
between the EA and their customers. The history to the saga is
not uncommon. After some 25 years of under-funding by government
on navigation infrastructure, Health & Safety has demanded
a significant increase in Grant in Aid (GiA) paid by Defra to
the EA to regularise and renovate the assets. The cost has been
a further £5 million extra GiA for each of the years 2005/6/7.
Defra effectively demanded that the EA impose significant increases
on their sorely grieved customers of some 8.5%. [The history,
unknown or unacknowledged by Defra, was that in the 1980s a 25%
license increase was agreed between the NRA and users to generate
a fund to enlarge three small constraining locks. One lock, Hambleden,
was completed but the remaining funds, supposedly ring-fenced,
were arbitrarily absorbed for general repairs and the GiA reduced
by the amount of the fund. This reneged promise still rankles
with users especially as the 25% license increases still apply.
This bad faith has never been acknowledged by Defra and even until
today causes significant difficulties and suspicion for the EA's
relationship with River Thames users.] At the very last moment,
the final 2006 license settlement was grudgingly accepted by Defra
at 6.9%. There is real concern now that Defra may "punish"
users and the EA by declining to continue the extra capital GiA
needed to overcome the past under-funding. There is a compelling
argument that requires a continued GiA at the current level for
another eight years! This capital requirement for navigation is
over and above that needed for flooding protection although both
are inextricably linked. The commitment by Defra to this planning
need seems to be used to imposed conditions when Defra wish to
dictate EA policy.
5. The Agency's relationship with non-Governmental
stakeholders and the general public, and how the Agency monitors
satisfaction with its services.
This is an area that the EA has been active
and successful save for the point covered in answer 9.
The EA, where it interfaces with the public,
has made significant efforts at improving communication and do
try to make sure what they say is what is heard.
6. The Agency's responsibilities for
flood defence and flood mapping, including guidance to the public.
General "ignorance" is endemic among
the public. Living in an area subject to flooding leaves me bemused
by the general indifference by the population to the problems
of flooding, until that is, water appears where it should not.
Flooding happens somewhere else—until! Hold a meeting on
flood precautions in the autumn and nobody will turn up. Hold
a meeting after a wet winter when flooding occurred and the hall
will burst to overflowing with irate members of the public. It
will take a flooding disaster to bring the matter home to the
public. In the mean time, information is available. Further money
spent on advertising the warning system would be of suspect value.
7. How the organisational changes brought
about by the Natural Environment and Rural Communities Bill will
affect the role of the Environment Agency.
Time will tell but it is to be hoped that the
general management of the environment will improve. The committee
will be monitoring this and it must be left there initially.
8. How the Agency's work in improving
wildlife habitats will tie in with Natural England's work on biodiversity.
There seems to be a real desire to co-operate
and, from what I have seen so far, harmony reigns.
9. The Environment Agency's forthcoming
corporate strategy 2006-11.
There are two major items here.
The first covers the item of the strategy that
is described as the "Big Picture" (page 5 of the strategy
consultation document). I use the analogy that this section is
a Vermeer when what we need is a Rubens. The 2006-11 should be
a part of a much greater strategy that covers the next 50 years
or longer. Capability Brown designed his landscape gardens with
the certain knowledge he would never live to see the finished
product. This sort of planning dimension by the caretaker of the
environment is an anathema to political government that struggles
to think as much as five years ahead. A two generation long term
strategy is a missing must.
The second item is another omission and that
is referred to in previous "replies".
The EA has taken a stance that must have been
based on budgetary considerations. If this is the case it is no
less wrong. Defra and the EA have a duty of care for the environment.
They have been charged and assumed the task of preparing government
and the public for the needs to improve the conditions under which
we shall continue to live. The existence of climate change has
introduced a degree of guesswork as nobody knows quite were we
are going. Currently the UK could be facing a general increase
in temperature and a shift into a "Mediterranean climate".
On the other hand there are those that suggest that the Gulf Stream
will cease and we shall experience a significant drop in average
temperatures! Whatever the truth there is uncertainty. It must
be the duty of the EA to cover all contingencies. To do this best
is to educate the public in coping with each and every significant
change that manifests to allow the least impact on the ecology.
Currently, save for a single very successful instance, the EA
has no involvement in any form of formal education. There is no
central education budget nor any form of educational department
or any relationship with any educational body. Certainly some
small local initiatives exist but only with other people's goodwill
and money. However, the mentioned exception, all the more relevant
because of its success, is the learning centre at the Thames Barrier.
The EA should be in the educational lead position,
influencing the Department for Education and Skills to introduce
significant ecological and environmental studies at Key Stage
One, Two and Three. The EA should be closely involved in the delivery
of tertiary degree education, fashioning these course to have
relevance to the likely needs of the industry during the life
of the graduate. A simple cost benefit analysis for the next 25
years covering the benefit of an inclusive education involvement
by environmentalists would show potential savings of billions
over the period. An ingrained attitude to environment and ecology
needs in today's youth and tomorrow's public, must be very beneficial.
The EA consider that others are currently charged with the educational
task, but who is better able to know what to include within any
curriculum? The reality is that currently the EA has abrogated
its responsibility by a presumption of delegation and does not
even bother to monitor any supposed delegation! There is no ecology
or environment lobby of the stature that should exist if the EA
undertook the job. The committee should respectfully ask the EA
to justify such an omission.
One final emotive point. There are some 800
schools within five kilometres of the River Thames. Each year,
a number of children drown in The Thames from preventable accidents.
Every summer the police spend significant time chasing children
jumping into the water from river infrastructure. What is the
cost of a simple video to highlight the dangers of swimming unsupervised
in the river? Even better three videos, one directed at each of
the educational key stages. Such a video should be used at any
school for those PE lessons that are rained off. The cost of such
a video must be worth the money if it prevents the death of just
one child.
Louis Jankel
November 2005
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