Memorandum submitted by the Consumer Council
for Water (FL 130)
FLOODING LESSONS LEARNED—RECOMMENDATIONS
TO THE EFRA COMMITTEE
INTRODUCTION
The Consumer Council for Water (CCWater) is
the consumer organisation that represents water and sewerage consumers
in England and Wales. We welcome the opportunity to contribute
to the EFRA Committee's Flooding Inquiry. We have also submitted
evidence to the Cabinet Office's Flooding Lessons Learned Review.
The summer 2007 floods seriously impacted on
peoples' lives. Homes and businesses were severely damaged by
flood water, many people had to leave their homes and the impact
on the local economy was significant. To ensure that future protection
is as effective as possible and that incident response is rapid
and efficient, it is clear that better planning is needed going
forward.
Our key concern about future flood incidents
relates to the need to ensure adequate protection for water industry
assets, to prevent the loss of supply and sewer flooding incidents,
and also the need to improve water companies' response to incidents,
particularly the communication they have with their customers
during these times.
BACKGROUND
During 2007, there have been many flood events
across the country including Yorkshire, Wiltshire, Berkshire and
Gloucestershire. In addition to the flooding of properties, the
Gloucestershire floods in July 2007 also resulted in the loss
of water supply to around 140,000 households.
The loss of supply that resulted from the flooding
was so unprecedented that in response to this, CCWater carried
out qualitative research to explore the views of consumers that
were affected. We did this to better understand their experiences
and their perceptions of how the incident was managed, and also
what they want to see happen in the future. We are currently carrying
out quantitative research to further explore consumers' experiences.
Many of the views expressed in this submission
are based on the findings from the qualitative research. But we
also draw on experiences from our involvement in the Hexham loss
of water supply in 2005, and the floods that affected Hull and
the Thames region earlier in 2007.
SUMMARY
Following are the key recommendations from CCWater:
— Water consumers should not pick up
the bill for general flooding. Flood protection should be reviewed
and funded by the Environment Agency, and ultimately the tax payer.
— There needs to be a clearly defined
communications process in the case of declared disasters, both
nationally and locally. During the loss of water supply in Gloucestershire,
customers considered communication to be a top priority. Key lessons
from the Hexham loss of water supply also highlighted the need
for better communication between the various agencies, and for
those agencies to be aware of CCWater and how it can help, particularly
in respect of communicating with customers.
— Key organisations and their responsibilities
in the event of flooding need to be identified and defined now.
They need to work together to take a strategic approach to flood
risk management including the response to the loss of essential
infrastructure. CCWater needs to be involved in that process where
water and wastewater assets may be at risk.
— National standards on the minimum
amount of water to be supplied in emergencies need to be re-considered
after recent experience showed that Severn Trent delivered 10
litres per head per day more than the minimum requirement of 10
litres per head per day.
— New housing developments must create
space for the water to flow in outside spaces. The creation of
balancing ponds, lagoons and green spaces is essential for protecting
homes against flooding, as well as creating bio-diversity opportunities.
— Water and sewerage companies should
be statutory consultees for planning applications that could impact
on water and wastewater infrastructure. This would allow companies
to inform planners of their capacity to take more sewage and surface
water into their systems. Indications are that the flooding in
Hull was due to inundation of the drainage system during heavy
rainfall.
— Consumers felt strongly that the
loss of water supply in Gloucestershire should not have happened
and more importantly that it should never happen again. However,
the majority did not want compensation for the loss of water supply.
They felt this would reduce the funds available to future proof
the water supply.
— The Mythe water treatment works that
flooded in Gloucestershire had been assessed by Severn Trent as
being at low risk of flooding, its defences being up to the level
of the 1947 floods. CCWater is concerned that other treatment
works may also have been assessed as low risk. We think Ofwat
should therefore review all companies' risk assessments into vulnerability
to extreme weather.
— Customers also need to be reassured
that funds previously allowed in companies' price limits by Ofwat
have been spent appropriately on making water and wastewater facilities
resilient to this and similar incidents.
— The consumers who took part in our
research saw no evidence that Severn Trent had a contingency plan
in place. The Interim Report into the Hull floods by the Independent
Review Body concluded that there had been no contingency plan
in place for the failure of Bransholme Pumping Station. Companies'
contingency plans therefore need reviewing in the light of these
experiences, and their existence communicated to consumers.
ADDRESSING THE
OBJECTIVES OF
THE FLOODING
LESSONS LEARNED
REVIEW
1. Flood risk management and how to adapt
to the risk of flooding
The recent floods across the country have demonstrated
the significant impact floods can have on infrastructure, homes
and ultimately consumers.
Whilst we accept that it is not possible to
accurately predict weather conditions and plan for all eventualities,
there are some fundamental approaches that can be implemented
now that would significantly minimise the potential for flooding
in the future. These are:
— A joined-up approach is needed on
flood management, land drainage, surface water drains and sewers.
One organisation, perhaps Defra, should have responsibility for
making sure that the other bodies responsible are working together
with well-defined plans.
— Full consideration should be given
to the risk of flooding when new housing is being planned. New
housing developments must create space for the water to flow in
outside spaces. The creation of balancing ponds, lagoons and green
spaces is essential for preventing homes from flooding, as well
as creating bio-diversity opportunities.
— Water companies should be statutory
consultees during the planning process, particularly for larger
developments that will have a significant impact on the capacity
of their infrastructure. This will allow them to tell planners
about their capacity to take the sewage away without the risk
of sewers flooding. Some consultation criteria would be needed
so that water companies are only consulted on applications that
could impact on their business, for example housing developments.
We assume that there would be a large number of applications that
water companies would not need to be consulted on, such as smaller
loft conversions or external changes to the appearance of a property.
— Sustainable urban drainage systems
should be pursued rather than impervious surfaces and car parks,
with responsibility for maintenance clearly defined.
Preventing development on flood plains to allow
the water to flow and flood naturally is a simple solution that
would minimise flood problems. However, we saw in Hull that not
all floods are due to rivers. There, the local sewerage network
was inundated after 110mm of rain fell when soil was already heavily
saturated. Where flooding does happen, householders should have
the option of a grant to help pay for flood defences, such as
air brick covers and door protectors, although this is no substitute
for long term investment and more robust remedial measures.
Stopping flood water and sewage from entering
peoples' homes is very important and just relying on insurers
to clear up the mess is not enough, nor is it acceptable to customers.
Guidance should be given to existing homes which are at risk of
repeated flooding as to what they can do to minimise flood damage—for
example, citing of electrics, practical flooring. When it comes
to refurbishment after a flood they can then consider their options.
2. Vulnerability of critical infrastructure
The impact of flooding on critical infrastructure
can have serious and far reaching effects. In July 2007, Thames
Water was affected by flash flooding that made roads in their
area impassable and resulted in pumping stations and a water treatment
works being inundated. Whilst water supplies to customers were
maintained, customers were still impacted. The company response
times to queries and appointments were impacted as operations
teams were unable to move around the area easily, and customers'
properties suffered repeat sewer flooding because of the strain
on the sewerage assets.
In the case of the Gloucestershire floods, loss
of water supply also took place. On 22 July 2007 Severn Trent's
Mythe treatment works was submerged by rising flood water and
subsequently shut down, cutting off mains water supply to around
140,000 households in Tewkesbury, Cheltenham, Stroud, Upton and
Gloucester. In total this affected around 350,000 people who were
informed that their supplies could be off for 14 days.
Some of the customers involved in our qualitative
research told us that the loss of water supply left them feeling
like they were in "a return to the dark ages". Added
to this were a number of properties which also temporarily lost
their power.
Mythe water treatment works had been historically
assessed by Severn Trent as being at low risk of flooding. Following
flooding there in 1947, they had done some work to protect against
flooding at 1947 flood levels. However, this level of protection
was not enough to cope with the July 2007 floods. Consumers felt
strongly that the flooding and resulting loss of water supply
should not have happened and, more importantly, that it should
never happen again.
We are concerned that other water companies'
treatment works may also have been assessed as low risk. We think
it is vital that in the light of climate change predictions, Ofwat
urgently conduct a review of companies' risk assessments to ensure
that their assessments of vulnerability to extreme weather remain
valid. It is also necessary to ensure that funds previously allowed
in companies' price limits by Ofwat have been spent appropriately
on making water and wastewater facilities resilient to this and
similar incidents.
Respondents to our research want to see action
not just regarding Mythe, but at a national level. These views
were expressed not just as a reaction to recent flood levels but
in the belief that with predicted increases in extreme weather
events, flooding is likely to happen more often, and at significantly
higher flood levels. However, it cannot be assumed that consumers
should automatically fund such improvements to defences and infrastructure.
Affordability remains a serious issue for many water customers
who already struggle to pay their water bills.
3. Response to the emergency
A key message from the consumers who took part
in our research was that they saw no evidence that Severn Trent
had a contingency plan in place for the loss of water supply.
Also, the Interim Report into the Hull floods concluded that there
had been no contingency plan in place for the failure of Bransholme
Pumping Station. It is therefore critical that companies' contingency
plans are reviewed in the light of these experiences and integrated
with other agencies' emergency plans.
"I think all the rescue services and all
these people they did extremely well but what I wonder is, did
they prepare in advance if something like this happened? Was there
anything that was already set up that they could say okay, this
is an emergency. This is what we'll do. That's what they should
have had."
The Interim Report into the Hull floods states
that no single agency accepts responsibility for elements outside
their terms of reference. In Gloucestershire, customers were aware
that there were a number of different organisations involved in
responding to the emergency, but it was not always clear to customers
who was responsible for which aspect of the response. Going forward,
key organisations and their responsibilities need to be identified
and defined in order to prepare and plan for the next event. They
should work together to take a more strategic approach to tackling
flood risk management including the response to the loss of essential
infrastructure.
CCWater in its role as the consumer representative
should be part of this planning. After the loss of water supply
in Hexham in 2005, WaterVoice, our predecessor, contacted emergency
planners to make them aware of how we could help. CCWater needs
to do this again to renew contact and ensure we are part of the
process, and emergency planning teams also need to update their
records and regularly review contact details.
In Gloucestershire, our qualitative research
obtained views on how customers felt that Severn Trent had responded
to the loss of supply. The following issues were raised:
— Customers felt that the distribution
of bottled water was managed effectively, with some customers
still having spare supplies even after the water was turned back
on.
— Severn Trent's management of the
location and filling of the bowsers was not considered as effective,
particularly as promises to keep them topped up were not fulfilled.
— Large tankers had difficulty accessing
the streets where the bowsers had been left, and the water had
to be transferred to smaller trucks, adding to delays.
— The placement of the bowsers was
not considered to be well planned, with the distribution taking
no account of the density of the population in that street/area.
"Obviously, there was no plan . . . and
the siting of the bowsers was haphazard. There were areas that
were bereft of them, and the refilling of the bowsers was haphazard,
until the Army [became involved]."
Customers acknowledged Severn Trent's hard work
in providing temporary water supplies and restoring their mains
water supply. They felt that, for the most part and under difficult
and extremely unusual conditions, Severn Trent had done a good
job.
However, Severn Trent may have fared better
had it known more, or been advised, about the local circumstances
and infrastructure. If it knew the best locations for bowsers
and the size of the roads accessing those sites, it may have been
able to meet its promises to fill bowsers quickly.
4. Issues for wider emergency planning arising
from loss of essential infrastructure
The impact of losing infrastructure creates
a number of problems. In most of the flooding incidents this year,
flood water made it difficult for people to move around their
area. In the case of Upton upon Severn, this meant that their
flood barriers did not arrive in time due to delays on the motorways.
For some customers, the flooding also resulted
in power cuts which meant that they had no way of getting information
through the television or radio. Respondents to our research were
clear that what they wanted to see in such events was direct communication
from the people responsible.
The key planning issues we have identified following
our involvement in the floods are:
— Clear, consistent and constant communication
is essential. It needs to start early in the process and cover
a range of media, not relying on communication methods that need
electricity if power is out. Including CCWater in the earliest
emergency contacts by water companies and emergency planners will
help get the message out to consumers, and will enable CCWater
to help consumers that contact it for advice.
— The security and emergency measures
direction requires water companies to provide a minimum of 10
litres per person per day in emergency circumstances. Severn Trent
provided 20 litres per person per day. This suggests that a review
may be needed of what the minimum should be, with consideration
given to a higher minimum standard.
— Logistics need consideration. The
failure of the flood barriers to arrive at Upton should not have
happened. However, their redeployment to protect the Walham electricity
station prevented 100,000's customers from being without electricity.
This example shows how there is a need for more locally based,
mobile flood defences, and the need to identify, in advance, critical
infrastructure.
— All major services including utilities
need to review their flood defence and contingency plans. They
should consider the population in an area so that the response
provided is proportionate.
— Plans should take account of the
type of urban/rural environment that the company works in. If
streets are not wide enough for tankers, there should be an alternative
plan.
"Severn Trent Water put the big lorries
out then they had to tip it into a smaller lorry so they were
doing twice the work, they needed the little lorries to get through
the streets. I think they did very well personally."
— Plans need to take account of where
to access additional volunteers to help staff who are working
exceptionally long hours. Volunteers played a vital role in distributing
bottled water in Gloucestershire.
— During the Gloucestershire loss of
supply, the army became involved and helped to reassure consumers.
However, an alternative approach might have been for the Government
to have set aside "disaster" money to pay for other
water companies' workers to be redeployed to the emergency area.
— Whilst vulnerable people were provided
for during the loss of water supply, it is clear that with flooding
and the loss of water supply, the term "vulnerable"
takes on a new meaning. Water companies' vulnerable group lists
do not include people who are unable to carry bottled water and
take buckets to bowsers, or who needed special bottled water for
babies. Whilst lists from the councils and GPs could provide this
information, it is clear that a central list needs to be created
that is consistent and includes all classes of customer that could
be considered vulnerable under different emergency situations.
We recognise this would be a huge task, but we consider that it
would be worthwhile and offer reassurance to consumers. In the
meantime, water companies need to maintain their extra care registers,
particularly to include care homes, as recommended following the
Hexham loss of supply.
5. Issuing arising from the transition from
response to recovery
The key message we received from consumers who
took part in our research was that they want to see direct communication
from those responsible not only throughout the incident, but also
afterwards, during the recovery phase.
— The importance of maintaining communication
was emphasised in Gloucestershire where because there was no direct
contact from Severn Trent, some consumers did not realise they
should not yet be using water for cooking and washing up.
— Severn Trent should have built on,
and improved, the dialogue they had with their customers throughout
the Gloucestershire incident. Many customers wanted to hear directly
from Severn Trent and to see a real presence from the company.
— The importance of listening to those
affected, even after the event, was emphasised when some customers
told us that the £3.5m Community Fund from Severn Trent was
not welcomed. Those consumers said that they would rather that
money was spent on making sure the loss of water supply never
happened again.
6. Lessons for the future
The recent flooding across the country and the
loss of supply in Gloucestershire has identified a number of lessons
that can be applied to any emergency situation. The key priorities
are to ensure that:
— Key assets are protected from flood
waters to ensure continuity of supply in the future. This includes
making sure that all emergency plans and risk assessments are
re-assessed to reflect recent experiences and lessons learned.
We endorse the Hull review's recommendation that a list of strategic
sites and infrastructure is drawn up.
— Communication is clear, consistent
and continuous. Consumers need to know what is happening and what
they need to do. There needs to be a clearly defined communications
process in the case of a declared disaster involving national
and local media, with clear bulletins and information being given
at specified time slots.
— Disaster recovery plans and contingency
plans are reviewed in the light of the experience of these events
and their existence communicated to customers.
— Companies are allowed to invest in
their assets to ensure resilience for future eventualities. The
Hull review suggested that the 1 in 30 year design standard for
sewers needed changing to account for climate change. The most
effective way forward is likely to be an approach that balances
keeping the water in the catchment through sustainable drainage,
removing streams from entering combined sewers and improving some
assets.
— Climate change is not ignored. We
need to develop a more sustainable approach to flood management.
— Key organisations and their responsibilities
are clearly identified and defined. They should work together
to take a more strategic approach to tackling flood risk management
including the response to the loss of essential infrastructure.
This would include involving CCWater where water and sewerage
customers are affected, so that we can represent their views and
feed information directly to them.
We also echo the recommendations in the Scottish
Government's flooding issues review which emphasises the need
to:
— Set up a forum to help people and
communities become more proactive through better awareness of
flood risk and preparedness for flooding.
— Pursue the possibility of an individual
property grant scheme.
— Link to catchment strategic planning
and River Basin Management Planning.
— Ensure reducing the risk of flood
damage is an objective of the Government. It should seek to promote
rural land use solutions as part of its strategy for flood risk
management.
— Set up a forum to continue to advise
the Government on flooding matters.
7. How to co-ordinate responses to flooding
What is clear from the Gloucestershire flooding
and loss of supply is that a number of organisations did work
closely together to restore supplies to customers and ensure that
they were provided with adequate temporary supplies. Whilst this
may have worked well, it was not always clear to customers who
was responsible for what.
— Key organisations and their responsibilities
should be identifiable and they should work together to tackle
flood risk management and the loss of essential infrastructure.
— Work needs to be taken forward now
to improve communications between all the agencies responsible
for dealing with flooding and loss of critical infrastructure,
eg local councils, national government, the Environment Agency
and water companies. Where water and sewerage customers are impacted,
CCWater would also need to be involved.
— We echo the Scottish Review of Floods
report which calls "for stakeholders to work together to
ensure that a more strategic, catchment level approach is taken
when considering flood alleviation options." and the response
to the loss of essential infrastructure.
— As already emphasised, a clearly
defined communications process is key.
— There needs to be a centrally held
list of customers who could be considered to be vulnerable in
different emergency situations, so that this is easily accessible
and accurate.
8. What access to support, equipment and facilities
is needed in an emergency
From the comments customers provided during
our research, we believe that in the event of the loss of water
supply, easy access would be needed to:
— Bottled water and special bottled
water for babies.
— Adequately stocked bowsers in easy
to access locations.
— Tankers able to negotiate narrow
roads, or roads with parked cars.
— Manpower to relieve those working
excessive hours.
— Lists of vulnerable consumers, which
during the loss of supply includes customers who may not be able
to carry bottled water or drive to distribution points.
— Information about the numbers and
density of the population in an area.
— A supply of water butts to allow
consumers to collect their own water.
— Water efficiency advice, eg hippos,
so when they can flush the toilet, it uses less water.
9. Communication
As already stated throughout this submission,
communication needs to be a key priority during any emergency
incident.
Severn Trent's communication throughout the
loss of supply was considered by customers to be patchy and inconsistent
and it was not always clear to them who was in charge of the situation
or responsible for certain aspects of the distribution of water.
This was the area most criticised by our respondents in terms
of their response to the situation. Particular areas of criticism
include:
— Information regarding the location
of bowsers was considered poor.
— Respondents with babies were initially
unaware that they needed special bottled water for babies and
of the location where they could get this.
— Not everyone received the letter
from Severn Trent regarding the restoration of mains water.
— Customers found it difficult to get
through to Severn Trent and, when they did, responses from Severn
Trent call centre staff lacked confidence and did not reassure.
— There was also criticism for Severn
Trent's low profile in media communications.
"There's always somebody who's listening
to the local radio who's going to call somebody else. I heard
from somebody who was actually in Yorkshire at the time . . .
and somebody else would find out because they were queuing up
in Sainsbury's wondering why everybody was buying water."
In addition, channels of communication were
also questioned. Local radio and Sky Television were mentioned
as having been the best sources of information, along with the
local "grapevine". Media reporting was felt to have
focused more on flood victims perhaps at the expense of those
without water supply.
Work is therefore needed to ensure that areas
of responsibility are clearly defined and communications improved
between the agencies responsible for dealing with flooding and
loss of infrastructure, eg local councils, national government,
the Environment Agency and water companies. Where the loss of
infrastructure affects water and sewerage assets, CCWater should
be involved.
During the Gloucestershire flooding, our website
contained useful information for those consumers able to access
it. We also did regular press releases and interviews and met
with consumers to find out about their experiences. Our daily
liaison with Severn Trent enabled us to keep customers that contacted
us informed of the latest developments.
10. What worked well
Respondents acknowledged Severn Trent's hard
work in providing temporary water supplies and restoring their
mains water supply. They felt that, for the most part and under
difficult and extremely unusual conditions, Severn Trent had done
a good job. And in the Interim Report into the Hull floods, the
fact that the pumping station worked as well as it did during
the extreme rainfall was praised.
Whilst communications to affected customers
appeared to be mainly through the media, Severn Trent's use of
its website and telephone information line was considered up-to-date
and informative. It was also very effective in keeping the local
CCWater office updated on a daily basis so that we could inform
customers of what was happening. This was essential to be able
to keep customers that contacted us fully informed.
Prompt distribution of bottled water to customers
was considered good. The volunteers who helped distribute the
bottled water were praised at the same time as noting Severn Trent's
absence or, at least, their low profile. The Red Cross and the
army were also considered an asset to the situation.
"My opinion was that, until the army arrived,
Severn Trent were absolutely hopeless. The army appeared and they
set up on the racecourse and suddenly it all started to happen."
"They (Severn Trent) worked really hard,
all through the night."
During the loss of supply, customers reported
a real community spirit with neighbours looking out for each other,
particularly the elderly or less able. It was clear from our research
that customers had shown great resourcefulness in dealing with
the loss of water supply.
Consumer Council for Water
October 2007
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