The EFRA Committee report into future flood prevention offers a challenging vision after the damp squib of the Government’s National Flood Resilience Review. It distils a wide range of evidence into a set of pertinent challenges. Headlines will inevitably focus on the proposal to dismantle and rebuild current flood management governance and delivery bodies but the report contains recommendations that have the potential to make a lasting impact on how we approach flood risk management in England.
The Committee recognises that we need an approach to catchment management that considers how to reduce flood risk alongside providing a resilient supply of clean water and a healthy environment. The risk is that, by removing the flood management function from the Environment Agency and the Lead Local Flood Authority role from county and unitary authorities, you take responsibility from bodies with a broad remit to consider a full range of environmental services to create new structures with a much narrower remit. How will this help us to achieve a joined up approach to catchment management that delivers the best outcomes for society in the most cost effective way?The counter argument is, as the Committee suggests, that combining the full range of catchment management functions into one structure risks flood management not getting the attention it deserves or the size of the challenge results in other functions getting squeezed out. Of course there is a great deal to recommend in the Environment Agency being able to focus on its critical role as the environmental regulator, without getting swamped by the magnitude of the flood risk management role (a similar approach was recently proposed by Dieter Helm) so perhaps it is at the higher strategic level that we need to make sure we don’t lose the join up. Certainly, how well it brings together the multiple outcomes we need from our land management and recognises the opportunity for synergies will be a key test of the Government’s 25 year environment plan.
Given the Committee’s contribution to the debate about the future of flood risk management bodies, it is not clear why Internal Drainage Boards (IDBs) should be left out. Despite a strong commitment to improve environmental delivery from several IDBs, supported by the Association of Drainage Authorities (ADA), their performance is still mixed. Their decision-making is difficult for stakeholders to understand or influence and we question whether they are adequately accountable for the range of outcomes society wants from water management authorities. If the roles and responsibilities of public bodies are defined too narrowly, then this may well leave them with too weak a responsibility to safeguard and enhance the natural environment. A clearer and stronger statutory environmental duty would also help to ensure that the best practice we see in a small number of IDBs becomes accepted common practice across the board.
The Committee makes some very useful recommendations on how to remove several barriers to the wider adoption of Sustainable Drainage Systems (SUDS) in new developments. The proposals would make a significant contribution to reducing the risk of surface water flooding and overloaded sewers in town and cities but a wider roll-out of the principles promoted through initiatives like Blue Green Cities and Susdrain would ensure that more opportunities were taken to retrofit SUDS wherever possible. A steer for the newly formed National Infrastructure Commission to consider the role and value of improving green infrastructure, would make a valuable contribution.
The report gives a good overview of the role that catchment measures can have on flood risk and recognises that these can be deployed throughout a catchment, not just in the headwaters. It does not explore one of their great strengths in that they will often deliver significant additional benefits, such as improving water quality or wildlife habitat. Flood risk management strategies need to be designed to maximise those benefits because they ensure solutions are chosen that deliver the best outcomes for society.
Similarly, the assessment of the impact that dredging has on flood risk is balanced, recognising that dredging that speeds the rate at which water is conveyed to critical pinch points is the last thing you want and can increase the risk and severity of flooding at those points. It is critical that any review of the current permitting system recognises the negative impact dredging can have on downstream flood risk as well as the damage it can cause to aquatic wildlife and habitats.
As we look to a future outside the European Union it is essential that we recognise the role that directives, such as the Birds and Habitats Directives and the Water Framework Directive, have had in providing the framework for good environmental governance and it is critical that new domestic legislation builds on that ambition. The loss of the Common Agricultural Policy presents an opportunity to take a fresh look at how catchment management could change to improve delivery of a much wider range of outcomes. This report calls for Defra to ‘put flood risk management at the centre of any new support scheme for farmers’ but the Government’s approach to agriculture policy must be broader than that. It must recognise that the long-term sustainable management of land need not always be dependent on incentives and that regulatory and voluntary measures to conserve soils and prevent diffuse pollution can also deliver a flood risk management function. Furthermore, the best approach to incentivising catchment measures to reduce flood risk may not come from centrally designed agri-environment schemes but from bespoke tailored contracts formed through partnerships between land managers and communities at risk.
The Committee’s inquiry has produced a very useful contribution to the national debate. We look forward to the Government’s response.
Simon Wightman, RSPB
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