Supplementary memorandum submitted by
the Environment Agency (FL 121b)
1.0 A paper outlining the respective potential
future roles of the Agency and Local Authorities in relation to
surface water flooding (appendix to the Agency's Pitt submission)
1.1 Surface water flooding is not easy to
predict and the division of responsibility between Local Authorities,
water companies, the Highways Agency and the Environment Agency
makes coordinated management very difficult. This is recognised
in the Governments Making Space for Water Strategy and is also
highlighted in Sir Michael Pitt's interim report on last summer's
floods. With no single organisation having the strategic overview
role for all flooding issues the differing approaches and responsibilities
mean that there is no common approach to the management and operation
of drainage systems, a lack of joint strategic outcomes and failure
to optimise expenditure, particularly within urban drainage systems.
1.2 We believe that the Environment Agency
should be asked to undertake a strategic overview role for all
forms of flooding to provide national leadership, co-ordination
and advice to bodies that have roles to play in the management
of flood risk for the future. Local Authorities will need to take
a lead role in the local management of surface water flooding.
Defra's Making Space for Water initiative and the Pitt
Review have come to the same conclusion. These roles will need
to be supported by appropriate powers and resources.
1.3 On 7 February, Defra published its Water
Strategy "Future Water". The Strategy sets out a vision
for water management and includes consideration of more effective
drainage of surface water, given the pressures of climate change,
development and the analysis of last summer's flooding. The Government
also announced a consultation on ways of more effectively dealing
with surface water flooding on the same day. This consultation
focuses on the mechanisms for developing Surface Water Management
Plans (SWMPs), encouraging the use of sustainable urban drainage
systems (SUDS), and considers the role the Environment Agency
should play. We have been developing our ideas on the consultation,
including the relationship SWMPs could have with our Catchment
Flood Management Plans (CFMPs) and the role of other undertakers.
The consultation has been informed by the Making Space for Water
programme and the initial findings from the Integrated Urban Drainage
pilots. Detailed consideration of the role that the Environment
Agency can play is presented in a paper agreed by the EA Board
in November 2007. This is reproduced in full as an appendix to
this note and covers both the EA role and the cost implications.
2.0 How much is spent on flood risk management
scientists and engineers and what proportion of this is outsourced
to consultants (Q 922)?
2.1 The Environment Agency currently has
45 individuals contracted as engineer consultants, compared with
538 employees in specified engineering roles in flood risk management.
We have nine scientist contractors as consultants, compared with
266 employees in specified scientific roles in flood risk management.
In addition, many of our other flood risk management and other
staff may have scientific or engineering qualifications, even
though they do not perform a scientific or engineering function.
Less than 8% of our engineers are contracted consultants and the
equivalent figures for scientists is approximately 3%. The cost
in 2007-08 is approximately £2.5 million.
3.0 The Outcome Measures that the Environment
Agency will be delivering from its additional flood risk management
money over the CRS 07 period (Q 959)
3.1 The following Outcome Measure targets
have been set for the Capital Programme in the period April 2008
to March 2011. These targets reflect the contribution of all operating
authorities. The Environment Agency is responsible for compiling
the overall programme to achieve them:
|OM1 Economic Benefits||Average benefit cost ratio across the capital programme based upon the present value whole life costs and benefits of projects delivering in the CSR07 period.
||5 to1 average with all projects having a benefit cost ratio robustly greater than 1
|OM2 Households protected||Number of households with improved standard of protection against flooding or coastal erosion risk.
||145,000 households of which 45,000 are at significant or greater probability
|OM3 Deprived households at risk||Number of households for which the probability of flooding is reduced from significant or greater through projects benefiting the most deprived 20% of areas.
9,000 of the 45,000 households above
|OM4 Nationally important wildlife sites
||Hectares of SSSI land where there is a programme of measures in place (agreed with Natural England) to reach target condition by 2010.
|OM5 UK Biodiversity Action Plan habitats
||Hectares of priority Biodiversity Action Plan habitat including intertidal created by March 2011.
||800 hectares of which at least 300 hectares should be intertidal
3.2 In addition, we have introduced a target for 2008-09
to ensure that 70% of our high-risk asset systems are serviceable,
an improvement of 5% upon our current position. The increase in
delivery in comparison with the previous spending review period
is evident in the new targets, but since a typical project might
take three to five years to complete, the increased funding has
a bigger impact towards the end of the target period. In fact,
the increased expenditure during SR07 will also be used to start
projects that will deliver benefits in future periods.
4.0 What preliminary work has been carried out on issuing
flood warnings to people affected by surface water flooding in
urban areas? Is the provision of such warnings technically feasible?
4.1 A Making Space for Water project examined
the feasibility of establishing flood warning services to cover
all forms of flooding. Two forms of flooding, groundwater and
surface water, have been studied in detail. The study concluded
that a form of service is feasible for forewarning flood responding
agencies and responsible bodies of the potential for surface water
flooding, so that they can take actions to mitigate or minimise
the effects of flooding on the public. The service proposed relies
upon pre-identification of surface water "hot spots"
and accurate forecasts of causative rainfall from the Met Office.
The Environment Agency and the Met Office are currently working
together to establish plans for testing this proposal and will
deliver a strategy for implementing such a service on the success
of the proposed trials.
4.2 The suitability of using the information to provide
the public with this warning service needs testing. In its current
proposed form the coverage of the rainfall forecasts are very
broad-scale (circa 30km2) and there is a likelihood for a high
number of false alarms. Also the study has so far only investigated
the "alerting" part of the warning service. For a flood
warning service to be effective, people require information on
what the flood is doing when it is happening. For this we would
need to invest heavily in methods for determining the extent and
potential duration of a flood, so that people know what actions
to take and how long the situation will last. As such further
work is required to understand the requirements of the people
who will receive any proposed service to ensure that it meets
their needs. Any proposed service would therefore be very different
from that which the Environment Agency currently provides for
flooding from rivers and the sea. There will be technical difficulties
in implementing any service and a well considered strategy for
doing so will be vital if it is to be successful.
4.3 At the moment it appears that an effective flood
warning service for service water flooding may be some way off.
In the meantime, a sensible investment is in mapping areas at
high risk of surface water flooding, so that we can identify where
the need for intervention is greatest.
5.0 Who should be responsible for the maintenance of sustainable
5.1 The Environment Agency view is that ownership should
rest with a durable, accountable organisation that can be expected
to have the financial capacity to meet its responsibilities in
the longer term, if our strategic outcome of improved water quality
and minimised flood risk is to be achieved.
5.2 When considering surface water drainage, we have
specific responsibilities for water quality, flood risk and for
protecting water resources. We believe that the SUDS approach
to surface water drainage offers the most sustainable solution
for draining built-up areas in the future. It is our policy to
promote the SUDS approach. We strongly advocate integrated drainage
planning to respond to issues such as development pressures, climate
change and deliver the requirements of the Water Framework Directive
in an effective manner. Drainage issues (both foul and surface
water) need to be considered early in the planning system (preferably
at spatial strategy stage) and Building Regulations to ensure
issues are dealt with before development commences.
5.3 Our submission in response to the Defra surface water
management consultation will cover these issues in detail. In
brief, we believe that allocation of long term responsibility
for SUDS is an institutional issue (and not a technical one) and
may be case specific but that both Local Authorities and Water
Companies have key roles. We call for:
The Government to provide leadership and support
for SUDS in Government policy, in particular building on the position
outlined in Defra's water strategy, Future Water, published in
Action by Government to seek opportunities to
make appropriate amendments to legislation, in particular those
identified in the Improving Surface Water Management consultation
which accompanied the Future Water strategy.
Support from OFWAT in taking forward SUDS approaches
in all improvements undertaken by sewerage undertakers, and in
particular a recognition of the wide benefits of this approach
offers, not only for provision of effectual drainage but also
for water resources and wildlife.
Regional and local government to embed SUDS in
the planning process and to ensure a consistent approach to drainage
across planning, building control, engineering, parks and highways
6.0 How do you balance the conflict between your Water
Framework Directive objectives, your role as protectors of the
natural environment, and your responsibilities for managing flood
6.1 To understand the challenges and opportunities resulting
from the Water Framework Directive (WFD), water bodies and their
current status have been identified and assessed across England
and Wales. We recognise that flood risk management activities
have the potential to significantly impact the status of water
bodies and the wider natural environment. Our flood risk appraisal
processes consider the consequences of flooding on both people
and the environment and assess the impacts from measures to reduce
flood risk. In this way we can identify ways to reduce unacceptable
risks to life and property in ways which do not harm the environment.
6.2 The WFD places new requirements upon flood risk management
specifically to protect and enhance water bodies, while allowing
for the continuation of appropriate flood risk management activities.
Our current appraisal processes are being revised to include the
specific tests required under the WFD. This will ensure that we
continue to reduce flood risk in ways that avoid harm to the environment.
7.0 Many witnesses to the Committee's inquiry have provided
examples and evidence of occasions where inadequate maintenance
of rivers and watercourses seems to have contributed to local
flooding last summer and on other occasions. Some criticise the
Environment Agency for not having cut weeds in channels and cutting
bank side vegetation. How do you respond to claims made by many
organisations and people who highlight the lack of maintenance
of water courses and rivers under your jurisdiction as contributing
to local floods?
7.1 The Environment Agency approach to all flood risk
management activities, including vegetation clearance and dredging,
is risk-based, meaning that our resources are focussed where need
is greatest. We must also ensure that our activities take appropriate
account of public interest and the environment. We consider carrying
out channel maintenance work where it is technically sound, economically
viable, and environmentally acceptable and sustainable to do so.
We spend around £3 million per year on dredging in England
and Wales. A further £8 million is spent on weed removal
to let rivers flow freely in their natural channels. We also de-silt
rivers at critical locations, where we are also the navigation
authority, to allow passage for boats.
7.2 Dredging and aquatic vegetation clearance are not
always effective flood risk management tools, however. Both activities
have serious, and potentially extremely detrimental, impacts on
the environment. It is important to keep channels clear of blockages
in built up or urban areas where the impact of flooding is greatest
and where a watercourse may be confined to a single, narrow channel.
However, in other locations, water courses may have both a channelcontaining
low to medium flowsand a floodplain, which contains the
excess water during higher flows. De-silting channels in these
circumstances would not increase the flow in the channel sufficiently
to prevent the water from spilling out onto the flood plain, and
may increase flooding in other areas downstream. Any benefits
would be short-term as channels would rapidly silt up again.
7.3 We have developed improved analytical tools to determine
where we need to carry out work and we are still working to deliver
the full potential of these tools. Our work thus far, however,
has not identified the need for wholesale changes in practice.
The Water Framework Directive does not prohibit dredging or channel
clearing. On the contrary, the Directive calls for the reinstatement
of natural river channels, as far as possible. Where we can demonstrate
a need for flood risk management activities in the public interest,
then these activities will continue. In light of the learning
from the summer flooding, the new tools available to us and the
emerging requirements of the Water Framework Directive, we are
taking stock of some of our practices.