Ewan Larcombe
67 Lawn Close
Datchet
Berks SL3 9LA
27 March 2008
The Pitt Review
Cabinet Office
22 Whitehall
London
SW1A 2WH
Dear Sir
Ref: Response to Interim Report Page 4 ‘The findings’
(i.e. The Report contains a total of 15 recommendations and 72 interim conclusions. They are strategic in nature but with implications for every locality in the country. The Report also considers one or two of the ‘myths’ surrounding flooding. These include strongly held views about standards of waterway maintenance and the belief that some communities were deliberately allowed to flood to reduce the impact on places further downstream)
Thames catchment – flooding and myths
There is no doubt that flooding is exacerbated by inadequate or badly maintained drainage and watercourses, but in particular I believe that much of the problem is caused by channel bed-rise flooding, due to lack of dredging and re-grading.
I do not agree that responsibility for watercourse maintenance is confusing, but I do believe that watercourse maintenance is neglected, especially by the Environment Agency who has responsibility for flooding.
I have no doubt that the actions and/or inactions of the Environment Agency have led to flooding that could have been prevented. You have only to refer to the Thames Catchment Flood Management Plan which reveals their intention to retain rather than release floodwater.
The truth is that the Thames is just a drain.
Within the Thames catchment, the primary purpose of the River Thames (and its tributaries) is to act as a drain, with any commercial and recreational benefits being a bonus.
Since the EA took over from NRA over ten years ago, the centuries old practice of ‘flood defence’ has been replaced with ‘flood risk management’ where ‘risk’ is the combination of probability and consequences.
The EA claims to be reducing the risk of flooding, but in practice the probability of flooding is ever-increasing due to lack of watercourse maintenance, increased building and climatic variations.
Furthermore the EA has claimed that watercourse maintenance responsibility was confusing and needed improvement. In order to meet that objective the EA took over responsibility for over 3000km of Critical Ordinary Watercourses from local authorities and LDA’s, but then failed to ensure that those same watercourses were properly maintained. Indeed riparian owners of such watercourses now have to submit applications to the EA for permission in order to implement maintenance works such as dredging. Unbelievably permission is sometimes withheld.
The EA has only a ‘responsibility’ for flood defence and watercourse maintenance rather than a ‘duty’. In my opinion the EA is not even fit to take responsibility for watercourse maintenance, being firstly encumbered by internal conflicts of interest (e.g. consideration of water voles and Depressed River Mussels) and secondly believing that watercourse maintenance can be achieved remotely from a keyboard in a warm, dry, safe, office.
The EA claims that the Thames is a natural river and is self-scouring. The truth is that the Thames is extremely unnatural, being highly engineered, structured and controlled. The water is normally unable to achieve the velocities necessary for material conveyance. In fact over time, many of the structural flood arches have been blocked, and the ‘within banks’ flood water conveyance capacity has been greatly reduced. Indeed I believe that even the ‘normal’ water level of the Thames has risen steadily during the last century in order to maintain navigation while avoiding dredging.
The EA claims that dredging ‘is not a sustainable solution’. In fact when the EA took over from the NRA, the EA disposed of and did not replace the existing Thames dredging equipment. So apart from not having dredging equipment, the EA now has nowhere to dispose of dredged material. Furthermore, the problem is compounded because low-level radioactive waste and other toxic run off has been discharged into the Thames for over fifty years, therefore ‘hot’ and polluted Thames sediment may be designated as ‘hazardous liquid waste’ consequently being difficult (and expensive) to dispose of.
Finally, having taken over responsibility for the watercourses, the EA has failed to effectively utilise local knowledge and resources to maintain watercourses and thus reduce the probability of flooding.
This is (briefly) what I would do to improve the situation:
a) Agree that expenditure on watercourse maintenance must be considered a good investment on the basis that prevention (of flooding) is cheaper than cure.
b) The importance of the complete existing ‘Main River’ watercourse system (including the River Thames) should be acknowledged by redefinition to ‘Critical Infrastructure’ similar to pumping and electrical facilities.
c) Create a position for an independent ‘Ombudsman’ for flooding and flood defence.
d) Prevent the EA from reducing the numbers of lock-keepers and selling assets (particularly to developers) without proper consultation.
e) Remove responsibility for flooding from the EA and create an independent Flood Defence Agency – with a DUTY for flood defence and maintenance (rather than simply ‘responsibility’ for flood risk management) and also unencumbered by internal ‘environmental’ issues and conflicts of interest in the way the old Thames Conservancy/National Rivers Authority used to.
f) The new Flood Defence Agency should create and maintain an internet based public Register of all watercourses, to which the public have direct access for reference purposes, and also the opportunity to add comments and pictures. This would ‘engage’ the general public and in particular local people and organisations with intimate knowledge of the area and vested interest in flood prevention.
g) Parish and Town Councils should have a DUTY to regularly monitor the condition and levels of watercourses and/or groundwater within their parish, to record the data, to highlight the need for maintenance, and to communicate with adjacent parish/town councils (using the internet based Register?)
Yours faithfully
Ewan Larcombe
p.s. I am content to have my comments published.