Memorandum submitted by Association of
Drainage Authorities
The Association respond on behalf of the Internal
Drainage Boards (IDBs) which are established in the 1.2 million
hectares of lowland areas which are highly sensitive in terms
of flood risk and land drainage. In some 800,000 hectares, much
below sea level, land use can only be maintained through the evacuation
of water by means of pumping. The land use ranges from supporting
the heavy industry, including oil refineries, and petrochemical
complexes on Humberside, to the grazing areas in North Norfolk
and the Somerset Levels.
The Association recognises the wide ranging
role of the Environment Agency in environmental protection and
since 1995 the awareness to environmental issues has been very
considerably enhanced across the public, business and other sectors.
At the time of its proposed establishment the Association registered
concern as to how the flood defence function, our primary concern,
would, as an operational activity, be embraced within what would
be seen, almost exclusively, as an environmental protection body.
With the experience of 10 years some of the difficulties which
were envisaged have materialised.
The following observations are made in respect
to the Flood Risk Management functions of the Agency.
1. FUNDING
The funding of flood risk management, as exercised
by the Agency, has been enhanced very considerably in recent years
and this is contrary to the position as anticipated by many including
the Association. The increase has unquestionably been, in no small
part, generated by extensive flooding, notably in 2000, by an
acceptance of the increased uncertainty arising from global warming,
and, not least, through the efforts of a highly informed Minister
in Elliot Morley, determined to reduce the impact of flooding
and successfully articulating the case for additional funding.
The Government are to be complimented on this and also in promoting
the Foresight Project which gave greater understanding as to the
possible scenarios within which flood risk would need to be addressed
in the longer term.
Flood Risk Management is a long term business
and sustainability is achieved only through a long term commitment
to the service which must be underpinned by an equally long term
commitment by Government to future funding.
2. RELATIONSHIPS
Since its inception the Agency has increased
substantially in size, and as such appears governmental. This
perception is furthered through a more centralised approach to
the service delivery and the transfer, increasingly, of functions
previously undertaken by the Flood Risk Management Division of
Defra. In its dealings with bodies identified as stakeholders/partners
it consults widely but whether that consultation provides real
benefit in developing the best policies and solutions may not
be easy to demonstrate. A measure would be the incidence when
the consultation provides a constructive input either by promoting
new or amending Agency thinking on issues. The confirmation of
an organisation being more receptive to other views could be improved,
possibly through more selective consultee engagement, or the timing
of the process and style of consultation document such that the
"die being cast" impression is not given.
3. FLOOD DEFENCE
3.1 Awareness
The Agency have been hugely successful in the
raising of public awareness to flood risk, achieved through both
an enormous publicity effort reinforced by the maps of flood risk
areas. That "heavy rainfall" introduced in a weather
forecast is, almost without exception, accompanied by references
to flood risk, demonstrates very clearly the progress the Agency
has made.
This success, and particularly the impact and
public access to the flood risk maps, raised high anxiety among
both householders and insurers and this was inevitable. It is
essential that the flood risk maps are viewed for what they are,
an indication that there is a risk issue to address, which in
planning terms is of great significance, and that the level of
risk may be such that individual property owners could take some
self-help measures. It is essential that interpretation of risk
is retained at a sensible level such that it is controlled in
a way which does not significantly inhibit development and economic
growth.
3.2 Operations
The Association fully recognises the importance
of the aquatic habitat as provided within river channels and adjacent
land, particularly where wetness enhances that environment and
its biodiversity. It equally recognises the need to provide and
maintain adequate levels of flood protection and manage water
levels to sustain land use.
In reality reaching both these objectives in
many situations is not achievable, and whilst in some, sensitive
environmental management for the benefit of conservation is possible
in others this is not the case without increasing the flood risk
to property, land, and, in many situations, environmental assets.
The Environment Agency by its very title face
difficulties when they need to maintain channels to a high standard
of hydraulic efficiency requiring the removal of both channel
and bankside vegetation and the dredging of accumulated silt and
its spreading on the adjacent riverside meadows. Some observers,
without thought of flood risk, would consider this not to be the
actions appropriate to a body charged with environmental protection.
Maintaining channels is a somewhat simplistic operation, carried
out successfully over many decades, but increasing regulation
makes this far from straightforward. Dredging a channel is presently
subject to control under six European Directives.
In the face of regulation and other pressures
it is not surprising that there is evidence that less of this
type of operational work is being undertaken, with the effectiveness
of some work reduced, in a commendable effort to be seen to be
accommodating all of the interests. In the majority of flood events,
resulting in property inundation, local comments/accusations are
made that the river is not as frequently maintained as was the
case in the past. Whilst these lay persons views are not based
on an understanding of river engineering they are not without
foundation and can not be dismissed.
The Agency should make a concerted effort to
demonstrate the crucial need to maintain the channel system to
control flood risk and that this must be done on a regular basis
with the inevitable short term and temporary damage to the environmental
interest. Such impact should be considered not in a strictly local
way but set against the overall position which will demonstrate
that the Agency are making a major contribution to the improvement
and sustainability of county's aquatic habitats.
Without this positive assertion the deterioration
of channels, on which substantial former public investment has
been made, will deteriorate at an accelerating rate and in some
locations flood risk to property will increase in contradiction
of the Government's objectives.
3.3 Flood Defence Committees
The Agency is a national body providing what
is a local flood defence service. Whilst there will be an impact
on the national economy and Government funding the public interest
in the service is exclusively related to the areas in which they
live and work and the level of flood risk which applies.
Since the inception of the concept that flooding
is of national concern and must be addressed by public bodies
the legislation has provided for committees, comprising "local"
members, to oversee the function. In place at the present time
are Regional Flood Defence Committees which are executive and
responsible for ensuring the appropriate flood defence needs within
their area are met. The description of them being "robust
and having a meaningful role" is often quoted and never has
that position been more crucial.
The Committees are ideally placed to demonstrate
that the Agency is not remote, and is accessible at a high executive
level, and that the discussions and decisions incorporate local
interest and knowledge. It is of course crucial that the membership
of the Committee represents appropriate interests to provide that
knowledge and awareness of local needs. Elevating the profile
of the Committee and increasing their involvement, and hence commitment
of the members, must be beneficial to both the public and the
Agency.
Association of Drainage Authorities
December 2005
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