Written evidence submitted by Pete Berry
In response to the request for evidence, please
find attached my comments. Comments in response to consultations
are inevitably made with vested interests, whereby organisations/individuals
want to protect/expand their own roles/empires. Understandably,
the EA favour an oversight/controlling role whilst minimising
responsibility, LA senior officers want to rebuild crumbling empires
and IDBs are intent on self-preservation. However, I am in a position
where I am now able to express (knowledgeable) views entirely
in the public interest from a taxpayer/ratepayer viewpoint with
no personal bias. It is difficult to get excited about the specific
details within the current consultation. Government & Defra
need to see beyond the self-interests and have the courage to
sit back and reflect and then consider the radical changes needed
in the national interest to give significant savings and make
the most efficient/effective use of the limited public purse.
1. We have the most complex organisation
in Europe for flood matters and the introduction of upper-tier
counties exacerbates this. It remains in the public interest to
have one body dealing with flood matters. The drainage roles of
EA, LAs, IDBs, Counties, BWB (other than drainage of their own
buildings/assets) should all be scrapped and replaced by sub-regional
(CFMPlan-sized?) local river authorities (l.r.a.) in order to
simplify and eliminate all the duplication/waste. The l.r.a. would
be under the democratic control of Boards, formed mainly by LA
Members. Defra would need to take direct control of some of the
residual EA national development work and all coastal defence
work should be under one national authority. The differing designations
of main river and ordinary watercourse could then also be scrapped.
Unfortunately it would now prove impractical to include the privatised
W&SCs, although their s.w. sewers could be transferred out
in exchange for private sewers in. Big savings could be made just
by eliminating all the multi-agency overlap work, meetings/communications/consultations/etc,
and by removing all the money-go-round procedures. In comparison
to pre-1974, the country now spends a fortune on drainage admin
and bureaucracy, yet the public receive a worse service.
2. A mountain of additional admin/bureaucracy
is being introduced as a direct result of the EA's defensive and
unsubstantiated statement to a previous Select Committee that
most of the 2007 floods were caused by "surface water".
Sheffield was quoted as an example, yet 97% of property flooding
in the city was actually caused by fluvial main river overspill.
Flooding from surface water sources is of course important to
those affected, but in overall terms the damage and cost to the
country is small compared to the large scale devastating fluvial
floods seen in recent years, eg Boscastle, Cumbria, Carlisle,
Morpeth, S.Yorkshire, Upper Thames Valley, Severn Valley, Kent,
Northampton, etc. It is acknowledged that flooding in Hull and
parts of London differs in that very low lying land is often highly
dependant on pumping, which necessitates specific considerations.
In June 2007 the relief type rainfall throughout Yorkshire was
heavy and prolonged, ie 13mm/hr x 6 hrs, and it fell onto a saturated
catchment, creating widespread fluvial flooding. Such rainfall
does not generally "overwhelm local drainage systems"
as claimed. Convectional rainfall, with short duration intensity
of perhaps 50mm/hr for 30 minutes does overwhelm local drains
and creates pluvial flooding, but typically affects only limited
areas. Fluvial and pluvial flooding terms were well understood,
but the introduction of "surface water" flooding was
unwarranted and especially confusing when differentiated only
by main river or ordinary watercourses origins. The increased
fluvial flooding over recent years is caused substantially by
climate change, exacerbated by greatly increased speed and volume
of run-off from the uplands.
3. Regularly dealing with perhaps 50 different
EA officers gives a great insight into the quango. Each individual
officer is busily working on their own aspect, but collectively
the EA are a hive of inefficiency. EA officers spend a lot of
time travelling around from their regional offices and attending
meetings, often with multiple attendance, and the EA regularly
rotate posts losing valuable continuity and local knowledge. The
EA are overly obsessed with hiring consultants to do extensive/expensive
modelling work. The extensive EA R.Don/Sheffield Strategy study
is over a year late with no worthwhile outcome, another 18 month
study now being required. The current EA s.w. mapping is another
exercise whereby a consultant is busy modelling flood risks with
no local knowledge or input. After the 2007 floods in Sheffield
the EA made inaccurate conclusions about the causes of the flooding;
in reality the spread of floodwater was often related to debris
blockages at bridge structures and loss of channel capacity due
to shoals/trees/etc. Unlike sewer pipe modelling, river hydraulics
and overland flows are a non-precise science and too much emphasis
is being placed on unverified theoretical modelling. Of course
blockages can be included in river models, but a real blockage
could be 10% or 90%. Having stated the above, there are many officers/sections
in the EA who do valuable work, eg the recent river clearance
works to restore channel capacity in Sheffield has been very good,
albeit overdue.
4. The introduction of the SABs is an expensive
mistake. Development control on drainage is already overly complex
and it will become much worse, especially in the 2 tier counties.
These matters could have been better dealt with by tweaking the
existing planning and building control arrangements, such that
the principles and s.w. discharge arrangements are set at planning
and building control approve detail design & certifies construction
being in accord with both planning conditions and building regs.
Without certification of site build all the development control
procedures are wasted. LAs will generally accept adoption of attenuation
ponds etc serving large developments, often set within linear
parks. However, LLFAs must not be forced to adopt small scale
suds in private land; eg infiltration trenches serving two properties
set against rear boundaries would be unsustainable both practically
and financially. Suds must be owned/maintained by the most relevant
person, eg private owners, W&SCs, LAs, estate management companies,
highway authorities. It is completely impractical and unaffordable
to lump all suds together and pass to the LLFAs. The use of suds
to attenuate flows is widely supported to reduce flood risk from
overloaded local drainage systems and where infiltration works
well then that should be encouraged. There are however dangers
of infiltration suds increasing flood risks in areas of sloping
land &/or impermeable sub-strata, because water infiltrating
at one location often resurfaces in other downslope locations.
The requirements of BRE365 need substantially upgrading. Suds
however will have virtually no affect in reducing the large scale
fluvial flooding over the next century.
5. It is impractical to defend all existing
development by hard engineered flood defences and managed retreat
may be necessary in some areas. However, the public will not accept
wholesale blight of existing land in flood zone areas. Development
control can facilitate appropriate development in flood zones,
eg roads/gardens/car parking at ground level, with residential
accommodation raised to first floor level. Make space for water.
6. With regard to the forthcoming privatisation
of sewers, the government's estimate of £50 million p.a.
existing LA expenditure is hopelessly wrong. Most expenditure
is recovered from householders. In Sheffield the net expenditure
by Environmental Services on drainage matters is around £80k
p.a. and half of the current work is not transferring, such as
septic tanks, single curtilages, etc. A saving to Sheffield of
say £40k translates into approximately £4 million nationally.
The quoted £36 million p.a. extra for LLFAs is adequate for
the new duties, but it must be shared out pro-rata population
or length of ordinary watercourses, rather than an arbitrary assessment
of flood risk. There perhaps needs to be greater emphasis on LAs
using permissive powers to maintain ordinary watercourses in the
same way that the EA have revenue funding for main rivers. There
have been other claims by Government that work to reduce flood
risk will create savings for LAs money in the long term, which
will then pays for suds work; this is totally inaccurate because
LAs cannot save where there is virtually no current expenditure.
The only significant spend by LAs is coastal work by maritime
authorities.
7. One example of the mistakes made by rushed
legislation is the definition of "flood" which now means
that every time it rains then there will be literally thousands
of floods in every town. The extra clause "to the extent
necessary…." inserted into S.19 F&WMAct is absolutely
essential, but it remains the case that it is necessary to somehow
relate "flooding" back to the real public level of concern.
Water in gardens and interruption to travel plans may be a temporary
nuisance, but "flooding" must concentrate on the high
damage aspects which involves big costs to the insurance industry,
and that is fluvial main rivers inundation. With regard to S.21,
it is impractical for LLFAs to spend a fortune finding ownerships
and checking conditions of watercourse culverts throughout their
areas; as with other matters it should be left to the LLFA to
decide what is "significant". It is vital that the PFRA
process doesn't exaggerate or misrepresent the level of flood
risk. Areas identified should be an honest reflection of real
flood risk in the area and not dictated by artificial criteria
set nationally for flood risk areas. The amendments to the reservoirs
legislation are not unreasonable provided that the designation
reflects realistic high risks and doesn't encompass virtually
every one.
8. LAs are busy complying with the partnership
requirements, filling in NI 189 forms, setting up SABs & sub-regional
FRMBoards etc. Unfortunately more "talking shops", admin
and bureaucracy will just waste funds and not solve flooding problems.
Funds would be better directed eg to more upland rain/river gauges
to provide better real-time flood warnings and more projects to
restrict upland run-off.
October 2010
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