Memorandum submitted by The Chartered
Institution of Water and Environmental Management (FL 90)
The Chartered Institution of Water and Environmental
Management (CIWEM) is the leading professional and qualifying
body for those who are responsible for the stewardship of environmental
assets. The Institution provides independent comment, within a
multi-disciplinary framework, on the wide range of issues related
to water and environmental management and sustainable development.
CIWEM welcomes the opportunity to provide comment
in response to the Committee's review of the flooding in England
during June and July 2007.
We hope that the attached comments are of value
to you. Should you wish us to expand on or clarify any of the
points raised please do not hesitate to contact us. We would be
pleased to provide oral evidence to the Committee, as there are
many issues which we have highlighted which would benefit from
further, in-depth examination.
Nick Reeves
Executive Director
INTRODUCTION
1. CIWEM welcomes the opportunity to make
a submission to the Environment Food and Rural Affairs Committee
Review of the flooding that affected various locations in England
and Wales during June and July 2007. We believe that whilst the
rainfall events were severe and subsequent damage extreme, in
some cases this was partly due to failures related to infrastructure
in the floodplain. Such flooding is likely to occur more often
in the future as a result of climate change.
2. It is our belief that, following previous
reviews into floods, lessons have been noted rather than actually
learned or acted upon. This is unacceptable, and must change.
The lessons from this review must be translated into an action
plan with each specific action given a date for completion and
an accountable person or organisation. The actions must be realistic.
This plan must be monitored and reviewed at the highest level.
3. CIWEM membership is drawn from all sectors
of the flood risk management profession (operators, designers,
contractors and regulators). CIWEM's Rivers and Coastal Group
has nearly 1000 members who are drawn from the key organisations
involved in flood risk and environmental management. The Group
is able to provide evidence on what we believe are the key issues.
4. There are clearly many lessons to be
learned and implemented and some lessons will have a particular
local relevance. From a national perspective CIWEM believe that
there are three key factors which warrant specific attention due
to their universal impact on all locations. The key issues are:
— Governance and institutional arrangements
— Infrastructure and development planning
GOVERNANCE AND
INSTITUTIONAL ARRANGEMENTS
5. Since the Easter Floods of 1998, there
has been a decade of floods, inquiries, reviews, emergency planning
exercises, and Lessons Learnt reports. These have been helpful,
and there has been substantial improvement in the management of
flood risk during this time which is welcome. However, we consider
that Government should be more ambitious and establish more robust
management arrangements for flood risk. These should:
— Remove dis-incentives to delivery
or participation
— Ensure that all partners work together
within a common framework, in an open, transparent and robust
way
— Improve reporting mechanisms on problem
identification and delivery.
6. The Foresight Future Flooding report
(2004) identified the likely increases in risk over the next 30-100
years, and highlighted the particular challenges faced by towns
and cities from intense storms. The recent floods have shown this
so devastatingly in places such as Hull, Sheffield and Tewkesbury.
7. The Governance and institutional arrangements
through which flood risk is managed is complex. This is undisputed.
The main organisations reducing the risk of flooding (from whatever
source), using permissive powers are:
— Environment Agency —main rivers
and the sea
(b) Flood Management operating authority
for ordinary watercourses
(d) Emergency Planning Authority
— Internal Drainage Boards
— Water Companies as Sewerage Undertakers.
Note: Water Companies are private companies,
but they provide a public service.
8. There is no clear line of sight from
the setting of Government policy to its implementation, and the
delivery of Flood Risk Management outcomes in a holistic way.
As an example, for a city to establish the flood risks in an area,
and future management plans, it would be necessary to assemble
information from each of the organisations listed above.
9. CIWEM believes Government should put
responsibility and accountability for ensuring planning of Flood
Risk Management with a single, fully resourced and empowered Public
Organisation. The primary purpose of this remit would be to ensure
that all the delivery agents are working together on the planning
and delivery of their respective activities, for a common timeframe.
10. Greater alignment of strategic plans
should deliver benefits locally through more detailed delivery
plans. Clearly planning should be carried out on a consistent
basis, using flood risk as the "common currency". This
organisation should have the power to set the basis and criteria
used for planning, and would need to be equipped with the necessary
powers, tools, and resources.
11. The opportunity to do this is before
us with the stated Government intention to give the Environment
Agency a Strategic Overview for Inland Flooding (all types). Recent
years have shown that the effectiveness of "voluntary"
approaches is not good enough for an issue as potentially crucial
as Flood Risk Management. The challenge is too great, and there
are too many competing pressures, to expect "tweaking"
of the current system to deliver the certainty and clarity which
the Nation deserves. Government should be bold and ambitious in
developing the Strategic Overview, and requiring its effective
implementation. (Two examples to support this approach are provided
in Appendix 1.)
12. CIWEM believes Local Authorities should
"grasp" the flood risk issues within their area, and
develop a long-term leadership role. Local Authorities should
embed Flood Risk Management in all their activities, and satisfy
themselves that appropriate management plans are in place.
13. This role includes contingency planning,
and flood aftercare and recovery phases. Local Authorities, as
democratically elected organisations are uniquely placed to fulfil
this role and ensure sustainable development within their areas.
Extra resource will be needed, but benefits will come locally
from ensuring that all the delivery agents take a long term, strategic
approach to Flood Risk Management, and resilience will be increased.
CIWEM understands that there is currently no single target on
a Local Authority which requires them to do anything on Flood
Risk Management.
INFRASTRUCTURE AND
DEVELOPMENT PLANNING
14. CIWEM recognises the significant advance
that has been made in establishing sustainable planning policies,
the aims of which are to ensure that flood risk is taken into
account at all stages in the planning process. Government policies
for flood risk and water management including Making Space for
Water and Planning Policy Statement 25: Development and Flood
Risk direct new development away from areas at highest risk and
where development is necessary in flood prone areas ensure that
it is safe from all but extreme floods.
15. Whilst a strategic risk based approach
to future development can protect all new development from frequent
floods, CIWEM believes there is a danger that millions of people
in existing communities will become increasingly subjected to
a life that is punctuated by flooding on a scale similar to that
witnessed across England during June and July 2007. An area of
particular concern highlighted by the 2007 flooding related to
the resilience of existing critical infrastructure such as electricity
transformers, pumping stations, potable water and waste water
treatment stations to flooding. With this in mind, CIWEM is organizing
a series of conferences in 2008 focusing on Critical Infrastructure
and Flooding (March 2008) and Emergency Planning and Extreme
Flooding (November 2008). In addition, CIWEM has an annual
conference on Integrated Urban Drainage Management (May 2008)
at which key issues from the recent extreme flooding will be highlighted.
All outputs from past conferences on flooding and drainage issues
are freely available on the CIWEM website www.ciwem.org
16. CIWEM believes owners, operators and
regulators of critical infrastructure must design and operate
their distribution networks to ensure continuity of supply for
a range of flood events, in accordance with the precautionary
principle.
17. Infrastructure plays a crucial function
during emergency situations and throughout recovery. It is imperative
that this issue is treated with the urgency it deserves. Infrastructure
owners and operators must be accountable for ensuring that new
works provide resilience against extreme flood events, and are
designed used a risk based approach.
18. CIWEM is unable to see how the Civil
Contingencies Act 2004 has enhanced the nation's ability to assess,
plan, advise and act on the flooding of critical infrastructure
such that our preparedness for increasingly severe flood events
is improved.
FUNDING
19. The recent floods provide evidence that
without sustainable investment decisions, future generations will
be subject to frequent exposure to lengthy periods of homelessness
as a result of disruption following flood events. There will be
an increasing financial impact upon the national economy. The
cost of sustainable solutions is something that we, as a nation,
must start paying for now. The established systems for investment
decisions already place great importance on the "best value
for money" approach. Processes and mechanisms to achieve
"value engineered" solutions are firmly embedded within
investment decision making.
20. The Minister's announcement in July
2007 to increase the flood risk management capital allocation
over a period of time is welcomed. However, this initial expenditure
must be accompanied by a commitment to long term strategic public
expenditure to maintain, manage and renew the existing assets.
21. CIWEM believes that there is a danger
that existing communities will be increasingly subject to severe
flooding. Capital investment needs to keep pace with climate change
so that existing communities can have a sustainable future. It
will be important to ensure that a proportion of the financial
benefits from new development is captured and contributes towards
improving the resilience of existing communities. We believe that
this leads to two specific issues that we would wish to highlight,
continuity of funding streams and sources of funding.
22. The timetable to produce a flood alleviation
scheme typically lasts several years. If schemes cannot be constructed
having been consulted upon, designed and having gained regulatory
approval they are "shelved". The concept is applied
so that the scheme can be "re-opened" as soon as funding
is available. This concept is flawed in that both public expectations,
regulatory requirements and technical standards may have changed
during the intervening period and hence significant amounts of
detailed re-design are needed at further cost. A lack of continuity
of funding leads to significant changes in workload across the
profession and this exacerbates the difficulties in efficiently
managing project work that are caused by the current skills shortage
within the industry. It also leads to increased costs to deliver
flood reduction measures.
23. The sources of funding for flood prevention
schemes should be reviewed. The current public funding rules allow
for almost no consideration of scheme components that do not directly
contribute to flood alleviation. A more holistic approach should
be adopted so that it becomes easier to incorporate into scheme
justification and funding contributions from sources that are
seeking to, for example, provide social and environmental enhancement.
24. We believe that improvements to the
piped drainage network should be addressed by OFWAT. This should
feature in the 25 year Strategic Direction Statements which water
companies are currently preparing, and forthcoming Price Reviews
(eg PR2009, PR2014). This should ensure that targets for local
water companies are set that will lead to improvements to the
drainage system and this source of funding be incorporated into
the economic appraisal of schemes. Improvements should be planned
in a strategic way, and consider the functioning of drainage systems
across the catchment area. These issues are a key focus for forthcoming
CIWEM conferences with OFWAT in November 2007, at our "Land
Use and Water" conference in November 2007, and at the Integrated
Urban Drainage Management conference (May 2008).
25. This same process should also be used
to ensure that water companies assess and reduce the flood risk
of their critical infrastructure.
26. CIWEM believes that with regard to funding
arrangements public authorities should:
— Maintain 5-10 year capital investment
programmes and lobby to secure funding from Central Government
to deliver those plans. Public bodies should openly report progress
on delivery of those plans.
— Identify additional sources of funding,
other than Central Government, to deliver the capital investment
programme where it can be demonstrated that further benefits will
arise from flood alleviation schemes (ie social and environmental
enhancements linked to EU funding streams).
— Require OFWAT to secure commitments
from water companies to reduce the incidence of sewer flooding
to properties, in a strategic way. Breaches of the commitment
should result in full financial compensation to the affected property
owners and/or financial penalties paid to the relevant public
authority. The penalties would contribute towards the costs of
the recovery phase of a flood event.
— Secure additional funding through
"planning gain" receipts (Section 106 Agreements) to
support flood risk management activities.
27. These are additional requirements over
current practice, and failure to implement the actions will lead
to repeated incidents of extensive flood events across England.
28. This submission is made with specific
reference to England. The issues however are common throughout
the UK.
29. We believe that the steps outlined above
will help to better prepare the Country for future floods. Continuation
with the status quo will lead to more of the same. That is an
option we cannot afford.
30. CIWEM would be pleased to provide oral
evidence to the Committee, as there are many issues which we have
highlighted briefly which would benefit from in-depth examination.
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