The Association of Drainage Authorities Response to the: A National Flood Emergency Framework Proposals for consultation
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1 Version Dr Jean Venables OBE FREng Chief Executive Please respond to: David Sisson CEng MCIWEM Operations Director Address: Wellington House, Manby Park, Louth, Lincolnshire, LN11 8UU Web: Tel: Fax: The Association of Drainage Authorities Response to the: A National Flood Emergency Framework Proposals for consultation (Issued by Defra but produced in partnership with the Cabinet Office (Civil Contingencies Secretariat) and the Environment Agency) ASSOCIATION OF DRAINAGE AUTHORITIES - The membership body for those involved in water level management
2 Contents ADA s Response to A National Flood Emergency Framework; Proposals for consultation 1 The Role of ADA 1 An Introduction to Internal Drainage Boards 2 Map 1 Indicative Flood Map of England & Wales 2 Map 2 - Geographical Distribution of IDBs in England 3 Introduction 4 Proposal 1 - Sharing data 5 Proposal 2 - Government flood emergency planning and response 5 Proposal 3 - Health and social care 5 Proposal 4 - Guidance on multi-agency planning 6 Proposal 5 - Arrangements for mutual aid 6 Proposal 6 - Electronic data systems 6 Conclusions The Role of ADA The Association of Drainage Authorities (ADA) is the membership organisation for those involved in water level management. Its members include Internal Drainage Boards (IDBs), the Environment Agency Regional Flood Defence Committees and the Northern Ireland Rivers Agency. Associate Members include Local Authorities, Consultants, Contractors and Suppliers. The main activities of ADA involve a wide range of work for and on behalf of its members including facilitating the exchange of ideas and promoting discussions to solving common problems and/or introduction of new approaches to members' work. ADA responds to consultations from the Government, either on behalf of members or by facilitating individual member responses. It represents the interests of Drainage Authorities and other members nationally and locally, for example in relation to Bills in Parliament, other legislative measures, and local public inquiries. ADA acts collaboratively with other appropriate bodies or institutions to pursue the Association's objectives including linking to Europe through ADA's membership of EUWMA, the European Union of Water Management Associations. ADA obtains and disseminates information on matters of importance and interest to members, and provides assistance on technical and administrative problems. ADA organises exhibitions and demonstrations such as Catchment 08 for the benefit of members, maintains a website and publishes the quarterly ADA Gazette. An Introduction to Internal Drainage Boards 1 Internal Drainage Boards are long established statutory operating authorities with histories dating back hundreds of years. IDBs predominantly operate under the Land Drainage Act 1991 and have permissive powers to undertake work to secure drainage and water level management of their districts and undertake flood risk management works on ordinary watercourses within their districts (e.g. watercourses other than main river ). Much of their work involves the maintenance of rivers, drainage channels and pumping stations, facilitating drainage of new developments and advising on planning applications. They also have statutory duties with regard to the environment and recreation when exercising their permissive powers. The IDBs in existence in England in April 2005 covered 1.2 million hectares of England representing 9.7% of the total land area (Map 2) 2 and approximately 90% of the indicative flood map zone 3 for England (Map 1) 3. Their average annual expenditure is in excess of 49 million, they employ directly or indirectly over 576 staff, have assets in excess of 145 million and operate and maintain over Taken from Internal Drainage Board Review: Final Report February Map 2, Geographical Distribution of IDBs 3 Map 1, Indicative Flood Map from Office of the Deputy Prime Minister presentation on PPS25 (2006) 1 Page
3 pumping stations, 22,000 km of watercourse, 174 automatic weed screen cleaners and have a part in providing flood risk management to 879,000 properties. They also have responsibilities associated with 398 Sites of Special Scientific Interest plus other designated environmental areas. IDBs are providing a valuable contribution to Defra s Making Space for Water Strategy by protecting and managing the water corridor. They provide a valuable service to the Town and Country Planning process by guiding and advising Planning Authorities regarding surface water management, flood risk and sustainable urban drainage, covering growth areas such as the Thames Gateway and Milton Keynes and South Midlands, and existing developed areas of the Thames gateway, East midlands, Humber Bank. Geographical Distribution of IDBs in England (13 IDBs also occur in Wales) Map 1, Indicative Flood Map from Office of the Deputy Prime Minister presentation on PPS25 (2006) Map 2. Geographical Distribution of IDBs in England 2 P age
4 The Association of Drainage Authorities Response to: A National Flood Emergency Framework; Proposals for consultation The consultation was issued by Defra and produced in partnership with the Cabinet Office (Civil Contingencies Secretariat) and the Environment Agency. Consultation document sourced from: Introduction The Association of Drainage Authorities (ADA) welcomes the development of a National Flood Emergency Framework as recommended by the Pitt Review following the Summer 2007 flood events. ADA is also pleased to see the establishment of a joint Environment Agency / Met Office Flood Forecasting Centre and wishes it every success with its aims to deliver more targeted and consistent information with extended lead times so that emergency services, utility companies and local authorities can be better prepared to act. ADA would note the importance of extending the provision of this information to all operating authorities including Internal Drainage Boards and crucially, without charge. A number of Internal Drainage Boards across England have appointed a representative to their Local Resilience Forum. They have played an active role in assisting with the emergency planning process by: attending Gold, Silver and Bronze commands; being actively involved with flood fairs; and working in partnership with the Local Resilience Forum. IDB involvement in local resilience forums can be invaluable during an emergency flood event due to each IDB s detailed knowledge of their local water environment. They also have access to a network of local Board members across their district, who can up date the command structure with the latest water levels in more remote parts of a catchment. These remote areas often act as a pre-warning of flood conditions which can be expected further down the catchment in the coming hours. IDB staff are highly experienced in the drainage practices of the local area and have an encyclopaedic knowledge of the local geography especially the bridges, sluices and water control structures that can prove to be so essential during flood events. They also intimately understand what parts are likely to become inaccessible first and can direct emergency services. This compliments the strategic water level guidance that the Environment Agency is often able to provide to emergency command structures. ADA has been calling for the revision of the Civil Contingencies Act to formally recognise the role of Internal Drainage Boards during emergency flood events across the 10% of England which are covered by Internal Drainage Districts. 3 P age
5 Proposal 1: The Met Office and Environment Agency should develop new, formal arrangements to provide specific flood risk advice to local emergency responders and professional partners in the lead up to a potential flooding incident. ADA strongly supports the development of procedures to share data before and during flood events with all operating authorities, local emergency responders and professional partners. It is essential that this information is provided to all operating authorities (local authorities and internal drainage boards) without charge. ADA s members understand the essential role of local knowledge prior to, and during flood events. Every sub-catchment and catchment has different characteristics and will respond differently to precipitation events. Influencing factors to flooding include: rainfall intensity, duration and location; weather conditions (such as snow); soil moisture deficit; and the condition of the watercourse network (individual elements and the system as a whole). Internal Drainage Boards specialise in this area of water level management expertise within and surrounding their drainage districts. Drainage, flood risk, and water level management are all 24 hour, 365 day a year proactive activities within the areas of the country managed by Internal Drainage Boards. Thus, flood risk management activities cannot simply begin as an emergency begins to develop. Whilst emergency response is important, it is essential that priority is given to managing and maintaining the assets and systems to ensure that the assets are in a fully operational condition at all times and thus able to react to minimise the consequences in times of extreme event. This will increasingly be the case in the UK as the effects of climate change are felt over the coming years. The present flood warning system operated by the Environment Agency provides a suitable public information service but currently fails to supply an adequate level or swiftness of information to professional partners. A two tier warning system is essential to provide technical information to professional partners, so that they can take early action as necessary. Many of ADA s members have found that significant flooding occurs in smaller localised parts subcatchments before triggers are hit on Main River. This is often overlooked and thus parts of an Internal Drainage Boards district may already be in flood by the time an EA river flood warning is received by the IDB. By being able to access regional 5 day weather forecasts and short range, high resolution flood forecasting and warning services such as Nimrod and Gandolf 4, IDBs would be better able to prepare their catchment for flood events. ADA has recently lobbied the EA and Met Office to share the five day weather forecast with IDBs and all other operating authorities. A 5 day advanced heavy rainfall warning can be analysed with data such as SMD and will enable the Board to mobilise its workforce to prepare for an event, such as lowering water levels where possible, preparing flood defences and checking and clearing structures. ADA has also sort for IDBs and other operating authorities to receive short range, high resolution precipitation forecasting and warning services such as Nimrod and Gandolf which can prove essential emergency forecasting tools during extreme convective rainfall events as occurred during the Summer of Integrated relationships must be developed between all operators. It is essential that the Environment Agency has a policy for including IDBs within their processes. Too often in recent years IDBs have only been invited to receive information or become part of partnership initiatives following the lobbying of ADA or local Internal Drainage Boards and even by regional departments of P age
6 the Environment Agency that understand the importance of coordinated actions with other operating authorities. All operating authorities must be included at all times, i.e. the Environment Agency, Internal Drainage Boards, and Local Authorities, so that complete coverage of ordinary watercourses and main river is analysed. Proposal 2: Flood emergency planning and response what you can expect of the Government and its agencies in the event of a flooding emergency. When multi agencies take action together in an event, it is important that the Government considers them together for additional support and funding, rather than as a series of independent organisations working in isolation. (Bellwin) Defra needs to lead, direct and fund authorities with powers to maintain assets to ensure that they are in optimum condition to minimise the consequences of flooding. The current priority given to capital schemes fails to fund routine maintenance. For example, where silt levels are elevated, conveyance capacity of the riverine system is reduced, which is particularly problematic in lowland rivers. Thus, siltation leads to the earlier occurrence of flooding, to a much greater extent and for an increased duration. It is the view of ADA s members that a failure to maintain an asset or system should be classified as a failure of an asset to perform. Government must embrace long term funding for water level, and flood risk management in order to avoid and minimise the occurrence of flood emergencies in the first place, rather than waking up to the failings of an unmaintained system post-event. This would be achieved by Defra prioritising the maintenance of systems and thus reducing the costs of emergencies when they occur (actual cost plus insurance costs, plus indirect business costs, plus health and welfare costs). ADA supports the inclusion of a list of partners in Annex Flood emergency planning and response: the responsibilities of the major players. However, there is a fundamental omission to include ALL operating authorities, in particular IDBs. Internal Drainage Boards are established in Regional Flood Defence Committee areas where there is significant benefit or danger avoided from drainage operations. They cover almost 10% of geographical England and ~90% of the Indicative Flood Map Zone 3 (Map1 page 2). Also sewerage undertakers are not included. This is particularly disappointing considering Defra s work into Integrated Urban Drainage, which demonstrated the critical need for inclusion of all key stakeholders. Proposal 3: Health and social care in the event of a flooding emergency. Do you agree that the new and planned arrangements referred to will provide what emergency responders, and those whose heath and/or social care may be affected by flooding, actually need? This proposal is supported by ADA. Proposal 4: Developing definitive guidance on multi-agency planning for flooding of all types and at all necessary geographical levels. ADA is concerned that an overreliance on modeling practices by Government agencies are proving to be inadequate to represent how watercourses react to flood events and thus are likely to reduce the effectiveness of this proposal. Decades of research and development have been undertaken by the Government which demonstrate the benefits of well maintained watercourses and the significant impacts that siltation and weed growth has on reducing flow. There is a worrying current trend to invest in consultants to predict and re-model rivers to try and replicate flooding occurrences, rather then proactively maintaining the design characteristics of lowland, heavily modified/artificial watercourses. 5 P age
7 It is essential that this trend is reversed and that watercourses are maintained rather than neglected and money invested in essential maintenance operations and away from costly remodeling activities. The philosophy of minimising the emergency response required needs to be embraced, where professional operating authorities seek to maintain assets in order to reduce the frequency and severity of emergency responses. We should not accept emergency responses to flooding as the norm. It needs to be recognised that flooding is catchment based and does not follow political boundaries. There needs to be greater weight given to historic knowledge and technical expertise from local operating authorities (IDBs, Environment Agency Area office, local authorities). Maximum cooperation and funding for working in partnership, inclusive of key stakeholders (IDBs, Local Authority, Environment Agency, Water Companies, Highway Authority). ADA supports the need to assess the risks and consequences of failure to classify reservoirs. It is important that the Agency administers this from national funds, because any proposals to charge reservoir operators will encourage individuals (who are often small business/organisations) to avoid registration and certification. Proposal.5: Arrangements for mutual aid in the event of predicted and/or actual flooding. ADA raises no comment to this proposal. Proposal 6: A single gateway for, and an electronic compendium of, information, advice and guidance for flood emergency planners and responders. Electronic systems can be detrimentally affected by emergencies, such as flooding or fire. There is also a tendency for systems to become overloaded during such events. Overreliance on complex systems can prove dangerous unless suitable standby measures and guidance is available. Conclusions The Association of Drainage Authorities (ADA) welcomes the development of a National Flood Emergency Framework as recommended by the Pitt Review following the Summer 2007 flood events. ADA is also pleased to see the establishment of a joint Environment Agency / Met Office Flood Forecasting Centre and wishes it every success with its aims to deliver more targeted and consistent information with extended lead times so that emergency services, utility companies and local authorities can be better prepared to act. ADA would note the importance of extending the provision of this information to all operating authorities including Internal Drainage Boards and crucially, without charge. A number of Internal Drainage Boards across England have appointed a representative to their Local Resilience Forum. They have played an active role in assisting with the emergency planning process by: attending Gold, Silver and Bronze commands; being actively involved with flood fairs; and working in partnership with the Local Resilience Forum. 6 P age
8 IDB involvement in local resilience forums can be invaluable during an emergency flood event due to each IDB s detailed knowledge of their local water environment. They also have access to a network of local Board members across their district, who can up date the command structure with the latest water levels in more remote parts of a catchment. These remote areas often act as a pre-warning of flood conditions which can be expected further down the catchment in the coming hours. IDB staff are highly experienced in the drainage practices of the local area and have an encyclopaedic knowledge of the local geography especially the bridges, sluices and water control structures that can prove to be so essential during flood events. They also intimately understand what parts are likely to become inaccessible first and can direct emergency services. This compliments the strategic water level guidance that the Environment Agency is often able to provide to emergency command structures. ADA has been calling for the revision of the Civil Contingencies Act to formally recognise the role of Internal Drainage Boards during emergency flood events across the 10% of England which are covered by Internal Drainage Districts. ADA s members understand the essential role of local knowledge prior to, and during flood events. Every sub-catchment and catchment has different characteristics and will respond differently to precipitation events. Influencing factors to flooding include: rainfall intensity, duration and location; weather conditions (such as snow); soil moisture deficit; and the condition of the watercourse network (individual elements and the system as a whole). Internal Drainage Boards specialise in this area of water level management expertise within and surrounding their drainage districts. Drainage, flood risk, and water level management are all 24 hour, 365 day a year proactive activities within the areas of the country managed by Internal Drainage Boards. Thus, flood risk management activities cannot simply begin as an emergency begins to develop. Whilst emergency response is important, it is essential that priority is given to managing and maintaining the assets and systems to ensure that the assets are in a fully operational condition at all times and thus able to react to minimise the consequences in times of extreme event. This will increasingly be the case in the UK as the effects of climate change are felt over the coming years. ADA has recently lobbied the EA and Met Office to share the five day weather forecast with IDBs and all other operating authorities. A 5 day advanced heavy rainfall warning can be analysed with data such as SMD and will enable the Board to mobilise its workforce to prepare for an event, such as lowering water levels where possible, preparing flood defences and checking and clearing structures. ADA has also sort for IDBs and other operating authorities to receive short range, high resolution precipitation forecasting and warning services such as Nimrod and Gandolf which can prove essential emergency forecasting tools during extreme convective rainfall events as occurred during the Summer of Integrated relationships must be developed between all operators. It is essential that the Environment Agency has a policy for including IDBs within their processes. Too often in recent years IDBs have only been invited to receive information or become part of partnership initiatives following the lobbying of ADA or local Internal Drainage Boards and even by regional departments of the Environment Agency that understand the importance of coordinated actions with other operating authorities. David Sisson ADA Operations Director CEng MCIWEM 7 P age
9 Individuals and Organisations who assisted with the production of ADA s Response: B Easom, Technical & Administrative Advisor to the Group - Bedford Group of Drainage Boards J Oldfield, Engineer to the Group - Bedford Group of Drainage Boards Photographic Acknowledgements Cover Photograph: Emergency pumping activity. P Brewin Somerset Consortium of Internal Drainage Boards The drain is managed using environmentally sensitive techniques to infer water level and flood risk management and promote biodiversity. Back Page Photograph: Cowbank Drain, nr Skegness. D Sisson - Lindsey Marsh Drainage Board A rural watercourse inferring flood risk management to: infrastructure, isolated communities and farmland, managed with a stepped profile to ensure: water conveyance, habitat creation and ease of maintenance. Contact Details Dr Jean Venables OBE FREng Chief Executive Please respond to: David Sisson CEng MCIWEM Operations Director Address: Wellington House, Manby Park, Louth, Lincolnshire, LN11 8UU Telephone: +44 (0) Fax: +44 (0) admin@ada.org.uk Website: ASSOCIATION OF DRAINAGE AUTHORITIES - The membership body for those involved in water 8 level Page management
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