Water Bill

Written evidence submitted by John Copley, Head of Environmental Development, Oxford City Council (WB 15)

John Copley, Chair of the Oxford Area Flood Partnership (OAFP) and Head of Environmental Development at Oxford City Council.

The OAFP members include the Environment Agency, Oxford City Council, Oxfordshire County Council, Network Rail, Thames Water and the Vale of the White Horse District Council.

The Partnership has considered the proposals and has the following comments to make.


1. Oxford has over 3,600 homes in the flood plain. More than 2,700 of those are at risk from floods of 1.3% Annual Event Probability (AEP) (‘1 in 75 years’).


2. There is concern that ending an affordable flood insurance scheme after only 25 years will leave significant areas of Oxford at risk of property blight. It is noted that there are no current proposals before the Committee to enable that period to be extended, only to be curtailed.

3. The proposals tend to address owners of houses which can usefully be fitted with conventional property-level flood defence for under £4,000. However, the proposals do not address the problem facing owners of houses which are at risk of flooding from below (e.g. by groundwater as in Oxford) – where the costs of protection per property will be up to ten times higher. The Partnership believes that this should receive consideration.

4. In order to protect houses at flood risk of 4% AEP (1 in 25 years) or lower, and to protect neighbourhoods from the potential associated blight, the scheme should be extended well beyond the 25 years (see below). The Partnership also believes that all flood repairs should be undertaken to resilient standards, in order to achieve a gradual reduction in risk to the housing stock and so reduce the amount and number of insurance claims in the long-term.


5. In order to protect a house from groundwater flooding a solid floor is needed. With ancillary works, that costs about £20,000 - £30,000 for a small terraced house. Such work is disruptive unless the property is empty, so is only likely to be undertaken once a house has already flooded.

6. Even so such work will often only be undertaken if insurance companies are prepared to allow owner to use insurance claims to part-fund resilient repairs, in order to improve levels of flood protection and reduce the risk of future claims.

7. In addition, such an approach to resilient repair is only likely to become widespread if Building Regulations are updated to make the resilient repair of flood damage obligatory.

8. In Oxford, the flood risk to houses at risk of ground water flooding is typically 4%AEP (1 in 25 years) or less. Hence resilient repairs as a result of flooding are unlikely to occur at most "at risk" locations within the life of the proposed scheme.

9. The chance of a flooding event occurring once in a 25 year period (see Annex) is under 64% [1] for flood risk of 4%AEP (1 in 25yr) events.

10. This means there is approximately 36% chance of no flood worse than 1 in 25 year severity occurring in the next 25 years.

11. If no serious flood has occurred that has prompted resilient repairs within 25 years, and constraints have not been applied to discourage inadequate "like for like" repairs, then the proposed scheme will leave a legacy of many areas at risk with many owners facing both unaffordable insurance and unaffordable repair at the next serious flood. Oxford will not be the only location where this will occur.

12. If at risk houses have not been made resilient by the end of the scheme and only unaffordable insurance is available, this may well lead to blight. If this occurs on any significant scale, then it could be an issue for society at large – not only for individual owners and their insurers.

13. As 1 in 75 years is the currently recognised boundary between ‘significant’ and ‘moderate’ flood risk, 75 years might be a more appropriate period for the life of the scheme proposed. In that period the risk of a 1 in 25 year flood not occurring at least once, is reduced to less than 5%. That increases the likelihood that significant numbers of resilient repairs would be undertaken before the system of affordable insurance ends, and so would greatly reduce the risk of blight.

14. The Partnership appreciates that there are other considerations that must be balanced in the introduction of a new insurance regime, but believes that long-term affordability remains the key test for any viable replacement regime.

 November 2013

[1] The National Weather Service Weather Forecast Office, El Paso, Texas.http://www.srh.noaa.gov/epz/?n=wxcalc_floodperiod


Prepared 11th December 2013