Memorandum submitted by Ewan Larcombe
(FL 128)
SUMMARY
1. The Environment Agency is currently unwilling
or unable to ensure that existing watercourses and flood defences
are maintained, thus increasing the probability of flooding.
2. Create a new independent Flood Defence
Agency (using existing EA/Defra employees whose work is currently
primarily flood related.)
3. Give the Agency the legal duty to maintain
the Thames for flood defence purposes, with appropriate powers
as required.
4. Change the culture and ensure that higher
ranking employees are properly qualified and have a good understanding
of Applied Fluvial Geomorphology or similar. Reintroduce "Flood
Defence".
5. Existing river and flood defence maintenance
to be the priority, with new flood defence schemes taking second
place.
6. The Agency must be honest, transparent
and accountable for their actions/inactions. When things go wrong,
action should be taken against responsible individuals.
7. Ensure that consultations are easy to
understand and receive wide publicity.
8. Create the position of Ombudsman for
Flood Defence.
9. Place a duty on local Parish and Town
Councils to regularly monitor and record the condition of all
elements of their flood defences, to communicate with geographically
adjacent authorities, and report potential problems to appropriate
authorities.
SUBMISSION
1. Over recent years, the Environment Agency
has taken over responsibility for thousands of miles of Critical
Ordinary Watercourse from the local authorities. These watercourses
are not being maintained by the riparian owners or the Environment
Agency, leading to reducing capacity and increasing probability
of flooding over time. Any maintenance that does take place is
cosmetic and superficial. Trees are trimmed, paths cleared and
fences repaired and painted. Local authorities have lost both
the resource and the experience. The Environment Agency appears
unwilling to use their powers to ensure that riparian owners fulfil
their obligations towards watercourses and flood banks. I can
give examples of flood banks that have been eroded or deliberately
deconstructed, subsiding and failing banks, and watercourses with
near zero flow due to bed-rise that the Environment Agency will
not permit to be cleared or re-graded. In my opinion, the Environment
Agency is currently unwilling or unable to ensure that existing
watercourses and flood defences are maintained, thus increasing
the probability of flooding.
2. Today the Environment Agency suffers
from an internal conflict of interest. Previously the National
Rivers Authority would ensure that that watercourse capacity was
maintained, but now the Environment Agency will produce a long
list of reasons why a watercourse cannot be dredged. I believe
we need to create a new independent Flood Defence Agency (using
existing EA/Defra employees whose work is currently primarily
flood related) whilst simultaneously removing the barriers to
flood defence maintenance.
3. The Environment Agency has a duty to
maintain the River Thames for navigational purposes, but only
the responsibility to maintain the Thames for flood defence purposes.
The reality is firstly that the primary purpose of the Thames
for thousands of years is that of a drain, and any commercial
or recreational use is a bonus. Secondly (and more importantly)
nobody else is willing or able to take the actions necessary to
maintain the capacity of the Thames. Over time, the capacity of
the Thames has reduced and the water level has risen. I recommend
a significant reduction in the Standard Headwater Level of the
Thames. There is a need to record the entire catchment existing
watercourse capacities, and to compare actual capacities with
the model capacities required in order to reduce the probability
of flooding. There is a need to give the Agency the legal duty
to maintain the Thames for flood defence purposes, with appropriate
powers as required.
4. The National Rivers Authority (and prior
to them the Thames Conservancy) had employees in Wellington boots
with considerable experience and thorough understanding of the
watercourses. With the arrival of IT, Environment Agency employees
believe they can control the elements from the safety of a remote
keyboard in a warm, dry office. The practice of "Flood defence"
has been replaced by "Flood Risk Management" and the
probability of flooding is increasing. We need to change the culture
and ensure that higher ranking employees are properly qualified
and have a good understanding of Applied Fluvial Geomorphology
or similar.
5. Much existing river and flood defence
maintenance has been abandoned. In my opinion it is pointless
producing new flood defence schemes when existing defences are
not working properly. Water causes flooding because it is trapped
and unable to escape. The ancient watercourses both natural and
manmade need continuous monitoring and regular maintenance. In
particular, the bed of the Thames has risen since dredging for
flood defence purposes was abandoned. Local dredging now only
takes place on receipt of complaints that boats are scraping the
bottom.
6. The £110 million Jubilee River scheme
is still awaiting repair and unable to carry its design capacity.
On first use at only 66% of capacity in January 2003, hundreds
of homes suffered flooding for the first time since 1947. The
Environment Agency had no right to divert floodwater onto undefended
villages. Sub-standard design, construction and operation led
to structural damage, £4 million repairs and a £2.75
million out-of-court settlement. The Agency "closed ranks"
with consultants and contractors (all with incestuous pecuniary
interests and protecting each other) to deny liability. These
people are all paid with public money, and we the public are also
their customers. Environment Agency employees are no longer capable
of determining whether their consultants or contractors are giving
good advice or service. I believe that the Agency must be honest,
transparent and accountable for their actions/inactions, and this
behaviour starts from the top. When things go wrong, and members
of the public are affected or disadvantaged, action should be
taken against responsible individuals.
7. Environment Agency consultations are
very complex and poorly publicised. In particular, the EA will
notify a Borough Council about a consultation, who themselves
then fail to respond or to pass on the information. It would be
easy to notify all parish and Town Councils by e-mail, thus ensuring
that consultations are easy to understand and receive wide publicity.
8. There is a need for an independent authority
to consider complaints against the Environment Agency. Create
the position of Ombudsman for Flood Defence.
9. The local people have a vested interest
in flood defence maintenance. They are best placed to know and
understand local flood defences, to recognise shortcomings and
the need for maintenance, and the implications of changes. We
should place a duty on local Parish and Town Councils to regularly
monitor and record the condition of all elements of their flood
defences, to communicate with geographically adjacent authorities,
and to report potential problems to appropriate authorities.
Ewan Larcombe
October 2007
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