Supplementary memorandum submitted by
the Chairmen of Regional Flood Defence Committees in England (FL
63a)
1. The Priority Score System and its use in
ranking Flood and Coastal Erosion Defence expenditure
1.1 The priority score system is designed
to rank the expenditure of capital in flood and coastal erosion
defence schemes that, if implemented, would deliver specific benefits.
The system is not able to rank non-capital expenditure, in particular
revenue funded work, and the benefits that can be counted are
controlled. In practice some flexibility is permitted in the benefits
that are included but the process is opaque. This is almost inevitable
but it sits uncomfortably in a system that purports to be objective;
a point that is discussed further below.
1.2 The system is based on three criteria
designed to weight the economic impact of a scheme, the effect
on people and the benefits for the environment. These mirror the
economic, social and environmental pillars of sustainable development.
1.3 The benefit/cost ratio is the basis
of the economic impact score. It is assessed using the guidance
in the Flood and Coastal Defence Project Appraisal Guidance documents
published by Defra, primarily FCDPAG3. This covers the need for
defences as represented by the economic risk (economic damage
resulting from flooding or erosion multiplied by the probability
of the events causing the damage) compared with the whole life
cost of providing the proposed defence. Only benefits and costs
that can be assigned a monetary value are included in the benefit/cost
ratio. The cost of repair of damage (adjusted for obsolescence
and depreciation) is estimated and reflected in the benefit/cost
ratio and score but consequential damage, eg from the loss of
a water treatment works or electricity sub station, is generally
not included, but examples are known where this stricture has
been relaxed.
1.4 The people score recognises that there
are often impacts on those living in risk areas that are not reflected
in the economic assessment. The focus is on impacts on people
as a result of flood or erosion risk at their places of residence,
rather than at their places of work. Ideally the basis of the
population adjustment would be the number of residents affected
but as this figure is difficult to obtain, the number of residential
properties which have their risk of flooding significantly reduced
by the proposed investment is used. An attempt is made to factor
in vulnerability of communities at risk, based on a measure known
as the "scale of economic deprivation", which ranks
electoral wards on an assessment of a mix of economic indicators.
1.5 The environment score is included to
give greater priority to those projects that are expected to provide
additional benefits to the natural environment. This includes
the recognition that Government is committed to the promotion
of Biodiversity Action Plan (BAP) targets, which include habitats
such as grazing marsh, reed bed and salt marsh that may be created
through appropriate flood and coastal management projects. This
is intended to assist achievement of the target that all projects
should, at least, maintain the status quo in habitat terms and
should, where possible, provide environmental enhancement. Thus
additional priority is provided for those projects that support
national environmental policy by addressing national BAP targets
as well as their primary defence.
1.6 Further details on the applicability
of the priority score system can be found at http://www.defra.gov.uk/environ/fcd/policy/grantaid.htm#psstudies.
1.7 There is a general belief amongst practitioners,
and those for whom the priority score system is a black art which
has a profound but opaque effect on their efforts to manage flood
risk—which includes the RFDCs—that a new approach
is required. Defra have commissioned research on the subject the
results of which can be accessed at: http://randd.defra.gov.uk/Document.aspx?Document=FD2013_2315_TSM.pdf.
The work is attempting to use current thinking on multi criteria
analysis (MCA) to update the priority score system. Defra and
Environment Agency officials are in the best position to describe
the current state of play in adopting the findings of this work,
but from our participation in workshops devoted to the subject,
it seems very unlikely that a wholly objective system can or will
be devised.
2. The broader issues of resource allocation
2.1 From the above description and discussion
it can be inferred that the Priority Score System, or any foreseeable
development of it, will not remove the need for judgement in the
allocation of resources. To be credible such judgements need to
be transparent and open to challenge, at least during their formulation
and preparation. Arguably they should also be open to subsequent
review as part of a necessary learning process.
2.2 It is clear that RFDCs, meeting four
or five times a year, cannot hope to second -guess the detailed
assessment of alternative uses of resources developed by a large
cadre of full time officials, but they can and do help to formulate
the total need for expenditure at regional level and challenge
the subsequent proposed allocation of resources at both regional
and national level, as outlined in the response to Q789. As argued
there, we believe that this is both feasible and healthy, and
compatible with the accountabilities of the EA Chief Executive
and Board to Parliament and government, and of the RFDCs to the
communities we are there to serve and represent.
2.3 What then are some of the current issues?
Is there an appropriate balance between expenditure on recurrent
maintenance of assets (revenue) and capital expenditure for replacement
of assets at the end of their useful life and new structures designed
to increase the standard of protection? What revenue funded resources
should be committed to control development, in the implementation
of PPS25 and elsewhere? Flood risk mapping is revenue intensive,
what priority should be given to that? What revenue and capital
expenditure should be allocated to improving the quality of flood
warnings (accuracy, reliability, specificity, timeliness) and
what to increasing their uptake (numbers of subscribers to Flood
Warnings Direct)? What is the correct balance between expenditure
on policy and process development centrally and delivery in the
Regions? What fraction of the total expenditure on measures to
improve standards of protection should be spent on preparatory
studies and strategy development and what on building the assets
that deliver that protection? Defra ministers have made it clear
that they expect multiple objectives to be delivered from investment
in flood risk management. Some of these objectives stem from European
Environmental Directives. What priority should be given to those?
Many of these issues cannot be judged effectively on an annual
basis, which is why we are pressing for a long term funding arrangement,
from which effective strategies for all of the above can be prepared
and implemented efficiently.
2.4 From our oral evidence, the Select Committee
will know that the RFDC chairmen as a whole have had the opportunity
to review the planned expenditure for the coming financial year
funded by Grant in Aid and after discussion have endorsed the
executive's proposals. The final decisions on allocations will
be made by the EA Board during February. Of course there are always
small differences in opinion at the margin. Peter Ryder has expressed
the view that improvements in the quality of flood warnings might
be achieved, which is compatible with Pitt's Interim Conclusions
3 & 7 and Tim Farr has recommended a different approach to
the deployment of demountable and temporary defences, which feeds
into Pitt's Recommendation 3.
2.5 There are other outstanding issues which
exercise the RFDC Chairmen. These concern the acceptability and
role of third party funding, eg from developers or public and
private authorities. Should such contributions affect the priority
score of capital flood alleviation schemes, through their reduction
in the net cost to the public purse? There is an imperative throughout
the Pitt review that flood risk management needs to engage a wider
range of authorities and is not something that can be delivered
effectively by any one central organisation. This is certain to
require the effective pooling of resources and their agreed deployment;
policies to govern these arrangements need to be put in place.
3. The use of local levies
3.1 Although reference was made in the response
to Q778 to the local levy, we are not sure that the significance
of this source of funding and the implications for resource allocation
were made sufficiently clear. The vast majority of revenue expenditure
and capital investment by the EA in England and Wales is now supported
by a Grant in Aid from Defra and the Welsh Assembly Government.
In 2008-09 this is expected to amount to £530 million of
which £250 million is for capital expenditure.
3.2 In addition regional committees have
raised a further £27 million for use in 2008-09 through a
levy on principal local authorities in their regions. The levy
rate is agreed by each Committee separately and must have the
support of a majority of their local authority members. As a result,
the amount of levy and the rate at which it is set vary widely.
The amounts raised by each English committee are set out
in the table below:
|
| Flood Defence Committee | Approved Levy
08/09 £k
|
|
| Anglian Central | 926
|
| Anglian Eastern | 1,670
|
| Anglian Northern | 1,473
|
| Midlands | 3,000
|
| Northumbria | 1,542
|
| Yorkshire | 778
|
| North West | 3,433
|
| Southern | 1,131
|
| Wessex | 3,015
|
| South West | 473
|
| Thames | 10,000
|
| Total | 27,441
|
|
3.3 Local levy is typically invested in flood protection
measures which are important to local communities but which do
not achieve a priority score that is high enough to be funded
from the national grant in aid. Although projects must be cost
beneficial, the investment of local levy is otherwise entirely
at the discretion of the regional committee, who generally exercise
their collective judgment against a range of options. Because
the sums involved are relatively small it is often necessary to
accumulate balances to fund individual schemes, which requires
forward planning and commitment. Some Committees are beginning
to seek third party funding too.
3.4 It may be helpful to illustrate the approach and
implications with three examples:
Improving the defences at Kilnsea
The village of Kilnsea in east Yorkshire faces the imminent
erosion of the coastal defences which protect it with a serious
risk of flooding to houses in the village that would result.
The economic case for realigning the defences at Kilnsea so
as to protect the village is not good and it is difficult to justify
spending money from the national flood and coastal defence budget,
so the defences would probably be abandoned. When we looked in
more detail, however, we concluded that we could carry out the
work provided a significant part of the funding was raised by
others, since even though no money would be available from national
budgets we could use the resources from the levy raised by the
Yorkshire Regional Flood Defence Committee to lever in resources
from elsewhere.
The offer of a £100,000 grant from local levy stimulated
local residents who had formed the Kilnsea and Spurn Flood Defence
Group to raise funds themselves and to seek further grants, and
also brought a sizeable commitment from the East Riding of Yorkshire
Council for infrastructure protection. These funds allowed the
Environment Agency to go ahead and build a new earth flood bank
in time for the 2006-07 winter storms. The Group has taken on
the responsibility for managing the new defence, which will protect
the village for a further 30 years or so and give the residents
much needed time to plan their future.
Completing the Flood Alleviation Scheme at Banbury
Extensive rainfall during Easter 1998 on the Cherwell catchment
caused flooding within Banbury to over 160 residential and 30
commercial properties. Banbury railway station was out of action
for several days. The event was estimated to have a return period
of 1:100 years. Upstream flood storage with online improvements
in Banbury and a pumping station to take water away from properties
during flood conditions will provide a 1:200 year standard of
defence reducing the risk of flooding to 386 residential and 97
commercial properties.
The pumping station was completed in 2003, but it proved difficult
to obtain the land for upstream storage. Eventually CPO action
became necessary and was approved by the Committee. A Public Enquiry
was called and was due to take place in September 2006. However,
the priority score for the scheme was 16.9 at a time when the
threshold for Grant in Aid funding had risen to the mid twenties,
so funding could not be assured and the Public Enquiry had to
be abandoned.
Alternative funding options were explored. Cherwell District
Council has agreed to contribute £2 million and to seek a
similar sum from business in the town. On this basis the Committee
has resolved to commit £9.7 million over four years from
the local levy to enable the scheme to be built. This is almost
a quarter of the expected levy over that period which shows very
significant solidarity from the local authorities in the Region,
which include the London Boroughs as well as upstream authorities
out to the Cotswolds The Public Enquiry will restart in 2008-09.
Banbury railway station and several commercial properties flooded
again in Summer 2007.
Breadth of Local Levy's Impact
In the Midlands region, there have been many examples in recent
years of schemes that have brought a range of benefits. On the
River Maun at Mansfield a collapsing culvert was opened up and
an attractive, natural and flood-friendly watercourse created
in partnership with the County Council, in front of whose offices
the work was needed and by whom it was undertaken. At Coleshill
in the West Midlands an old quarry adjacent to an industrial area
produced an environmental improvement at the same time as offering
a substantial reduction in flood risk. Local Levy has helped to
fund the provision of temporary defences (at Beale's Corner, Bewdley
and Upton-upon-Severn), a recent development in which the Midlands
region has been pioneering creative solutions to flooding issues
and expanding the flood risk management options available to the
Environment Agency. The scheme at Newark that is currently getting
off the ground will bring much needed third party financial contributions
into the arrangements, allowing a project that might otherwise
have remained unfunded and thus un-started to happen.
The Midlands region's programme for 2008-09 will cost approximately
£3.5 million, and will be applied to flood vulnerable locations
at Worcester, Ashbourne, Long Itchington, Burton Joyce, Gunthorpe,
Radcliffe-on-Trent and Newark. Approximately 788 properties will
be better protected or prepared as a result of this expenditure,
including approximately 50 houses (in the second year of a three
year rolling programme) at Trentside villages downstream of Nottingham
that suffer repeated regular flooding where conventional methods
of flood risk management are unlikely to be cost beneficial.
4. Internal Drainage Boards
Internal Drainage Boards ("IDBs") exist primarily
for the drainage of agricultural land and only extend over low-lying
areas of land that require this function. There are 160 individual
IDBs at present, covering substantial areas of eastern England
and running inland from the south, south-eastern and south-western
coastlines. Defra has recently launched an initiative to concentrate
these IDBs into 22 sub-catchment groups (see attached map).[2]
The responsibility for land drainage of IDBs is confined
to Internal Drainage Districts ("IDDs"), which are defined
in a document of many years standing known as "The Medway
Letter", and which is based on a formula derived from worst
known flooding events (of no particular date or specification)
and for rural areas an additional eight feet in elevation from
that line.
Many IDBs remain fundamentally unchanged in functional structure
from the 1930s and earlier. There is a strong body of opinion
that the change recently initiated by Defra is overdue, and ought
to be undertaken on as broad a basis as possible to improve the
integration between land drainage and flood risk management, particularly
in relation to updating the IDDs and the definitions contained
in the Medway Letter.
5. Self Help
It is to be noted that in the village of Woodborough, Nottinghamshire
during the June flood event, one of the householders in the flooded
area had the foresight to acquire Floodguard to block his doors
and vents against the waters. His was the only house not to be
inundated in the flooded area and demonstrated the viability of
such flood defence products and the potential for their application
by householders in certain circumstances.
6. If further explanation on this evidence and our oral
responses to questions asked on 23 January please let us know.
Tim Farr (Midlands RFDC)
Peter Ryder (Thames RFDC)
Jeremy Walker (Yorkshire RFDC)
Chairmen of Regional Flood Defence Committees in England
February 2008
2
Not printed. Back
|
