Memorandum submitted by Tony Adams (FL
166)
I am the Flood Working Group Coordinator for
West Lindsey District Council and have been since flooding in
August 2004. In addition to coordinating the partners to the group,
I have undertaken much of the investigation of matters not the
specific role of a partner agency. As such I have hands on experience
of some of the exacerbating circumstances to the flooding.
I welcome the invitation made at the close of
the Select Committee oral evidence submission at the Lawn, Lincoln
on 30 January 2008 when the Chair invited any additional evidence.
As such I write to introduce three matters,
as follows:
1. Development and failure to ensure adequate
onward systems for disposal of surface water.
2. Agricultural practice—effect on
permeability.
3. Gulley Maintenance—lack of confidence,
transparency and accountability.
In writing I advise that the matters I bring
to your attention are my opinion and tendered independently of
West Lindsey District Council.
1. Development and failure to ensure adequate
onward systems for disposal of surface water
Time and time again during investigation of
internal flooding within the district, I have established that:
Development in some way shape or form has been
an exacerbating factor; frequently there has been no apparent
regard to disposal of surface water off site. There
are many examples of connections into inadequate onward systems
and frequent occurrence of inappropriate culverting.
It should be born in mind that Water Companies
and Highways are not responsible for disposing of surface water
from land or private property yet both discharge what they
do collect to systems, many of which are privately owned, either
directly or indirectly. Developers similarly discharge to these
"private" systems and examples of connections for whole
developments to 100mm and 150mm onwards systems are becoming frequent
as is flooding in the vicinity becoming apparent.
The Land Drainage Act does not make provision
for upgrade or maintenance of these systems as it is primarily
for maintaining flow or carrying out essential works. Neither
it nor the overall planning process appears to adequately allow
for the whole system and the rate of expansion within it.
2. Agricultural practice—effect on permeability
On 25 June 2006 I travelled from the East coast
of Yorkshire through to Lincoln, my route took me mainly through
arable land off which water was streaming and roads were literally
being closed as I passed through the floods upon them. The flood
water was not coming off upland moors or peat bogs but flowed
through the hedges at the edges of saturated fields. The same
was the case in West Lindsey on 21st January 2008.
It is therefore a matter of concern that upon
hearing evidence from Natural England and more significantly from
the National Union of Farmers at The Lawn, Lincoln on Wednesday
30 January 2008, that no mention was made of an apparent widespread
change to arable farming that has been taking place which is likely
to have impacted greatly upon soil permeability. I refer to the
practice of "discing" in preference to ploughing.
This practice came to light during an enquiry
into complaints of odours in 2004 when it was evident that less
ploughing takes place now than did some years ago.
The enquiry revealed that many crops do not
need deeply tilled soil and therefore the practice of incorporating
nutrients into soil to a depth below the likely uptake is wasteful
and inefficient, whereas discing the surface not only retains
nutrients where they are required, but also effectively reduces
wasteful leaching of the nitrates.
Enquiry was made to DEFRA at that time over
the term "incorporation" as it related to good agricultural
practice. It appeared to be an acknowledged issue and the subject
of research for further guidance in relation to odour complaints
which originated from the incomplete incorporation of organic
materials by discing methods.
Information received at the time of enquiries
in the field also appeared to suggest that the practice was widespread,
to the extent that many farmers no longer own ploughs. It is however
acknowledged that discing methods differ with some very deep capability
where it is required.
It is therefore suggested that when land is
no longer ploughed and instead shallow discing methods are applied;
soil structure becomes settled, removing significant pockets of
air. These pockets would have been filled with water at times
of prolonged rainfall whereas now fields become saturated much
more quickly. It is therefore suggested that reduction of deep
cultivation may be a cause of rapid agricultural run off, which
appears to have increased in recent years.
Soil compaction, as above produces a partial
barrier that slows the passage of surface water downwards to the
water-table. It also seems reasonable to assume that soil compaction
at higher levels and reduced incorporation of organic material
at greater depths will have an adverse effect upon porosity, worm
populations and the interactions of deep cultivation and passage
of water generally.
It should also be noted that there is some evidence
of land at the periphery of urban areas having been purchased
by development companies and put into set-aside; I am also aware
of two examples of set-aside exacerbating run off related flooding.
3.Gulley Maintenance—lack of confidence,
transparency and accountability
Failure to adequately maintain surface water
gullies in adopted roads was believed by this officer to be a
significant factor in flooding during August 2004. This opinion
was derived out of:
— the many reports of failure;
— apparent absence of a robust maintenance
schedule; and
— apparent inability and evasion in
responding to these allegations.
Indication was that there was a general lack
of knowledge as to locations of gullies and drains that was compounded
by uncertain ownership and responsibility. This state of affairs
was still apparent as a National scenario upon discussion with
officers from different parts of the country at a "Highways"
drainage course in Leeds in December 2007.
In bringing this matter to your attention I
would like to demonstrate that the problem is being addressed
locally, as follows:
Progress
There has been gradual improvement since 2004
with gully cleansing increased to twice annually in flooding hot
spots.
Improved accountability from inability to say
if or when gullies had been cleaned, to a situation whereby specific
areas could be accounted for within a fortnight.
Suggestion that all gullies should be subject
of tracker tracing for purposes of recording cleansing operations
received tentative agreement in 2005 and a more positive confirmation
was received in 2007.
— Parish Councils are in the process
of being asked to review highways mapping and mark upon them any
missing gullies.
— Gulley cleaners now have trackers
that can pin point them to 10m.
— A new post is being considered to
administer the process.
Confidence in gully cleaning and proactive fault
finding is therefore increasing—at least locally.
I trust that the above is of help and in closing
I advise that although I am not qualified in drainage I have the
following experience and qualifications:
4½ years as the coordinator of the Flood
Working Group.
7½ years as an Environmental Protection
Technician.
An HND in Environmental Landscape Management.
NVQ Level 3 in Conservation.
Tony Adams
February 2008
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