Dear Secretary of State
First allow me to present my credentials. I am a long-standing volunteer for, and member of, the Angling Trust, the representative body for anglers. I am a lifelong, passionate angler with an interest in environmental matters, as well as in recent years a writer on angling politics.
I have no specific party-political axe to grind, neither have I ever canvassed in favour of any political party.
Below I give a brief resume of facts, as regards both recent events and also long-term flood and water strategy, together with my concerns, and ask what I consider to be relevant questions, for your consideration.
RECENT FLOODING: BACKGROUND
Severe flooding has occurred in the UK regularly throughout recorded history. 2013 and the end of 2015 saw unprecedented amounts of rain falling in the south west, and north west of the country respectively. Recent years have seen an increased frequency of flood events. December 2015 brought unprecedented flooding to Royal Deeside. Rainfall in flood-hit Yorkshire in December 2015 was nearly twice the long-term average.
On 13 December, 2015, following the storm and flood devastation in Cumbria and elsewhere, you announced the setting-up of a flood protection review under the chairmanship of Oliver Letwin MP. Clearly, if the review is to be properly carried out, representatives of all interested parties will be able to comment and present evidence, and the proceedings will be conducted in an open and transparent manner.
However, Daniel Johns, of the government’s Climate Change Committee has already voiced concern over the openness of the review, commenting that so far very few details of the scope of the review have been made known.
Furthermore, I was most concerned to learn that you made it known in a speech at a farming conference on 6 January this year that dredging is to be de-regulated to allow farmers to dredge ditches on their land without the permission of the Environment Agency. The aim would be to protect agricultural land from flooding.
Such dredging, apart from being environmentally destructive, might well protect farmland, but would exacerbate flooding in downstream urban areas, sending increased flows at high speed along river channels. Worryingly, your statement comes after a number of agricultural pilot schemes in 2015 failed to make the case for de-regulation.
More seriously in my mind, the decision to de-regulate dredging on farmland would appear to pre-empt the outcome of the planned flood protection review, assuming the latter is to be conducted in a fair, balanced manner. It also gives me more than a little concern that an Environment Agency report published in 2013 which claims that dredging does not prevent flooding has been removed from government websites.
The report in question states that:
‘Channels which have been artificially deepened by dredging silt up more frequently…dredging will be an unsustainable activity since it needs to be repeated regularly. The best approach is to identify the sediment source and address the issue at source rather than treat the impact.’ (my italics)
The same report goes on to state that dredging can ‘…potentially increase the risk of flooding downstream.’
FLOOD REVIEW: SPECIFIC QUESTIONS
I have a number of questions, to which I and many others would appreciate your answers and comments:
(a) Is it appropriate for the flood review to be chaired by a politician who is furthermore a member of the party in power?
(b) What is the scope of the review and what vested interests will be represented in the evidence heard?
(c) To what extent will the review consider expert submissions from hydrologists and environmentalists?
(d) What measures will be put in place to ensure external scrutiny of the review’s findings?
LONG TERM POLICY
Clearly, flood prevention/flood resilience is a complex issue which needs to be tackled in the longer term. If climate change is a reality, then long-term policies and planning are essential. Hard choices will need to be made.
Recent media debate has focused on the relationship between agricultural practices and urban flooding. Prof Dieter Helm of Oxford University, in his paper ‘Flood defence: time for a radical rethink’ (January 2016) has stated that that ‘…agricultural policies and the associated subsidies pay little or no attention to the flood risk dimensions.’ As examples he quotes: the growing of crops which cause rapid run-off into watercourses, high densities of grazing stock, and neglect of the importance of pasture and grasslands on river margins.
The question of continued urban development on flood plains also causes regular controversy. Prof Helm criticises the Environment Agency’s policy of giving most protection to areas at highest risk. This has of course been a green light for planners and developers to continue building in flood-prone areas. He also criticises the government’s new ‘Flood Re’ scheme, which will mean householders in non-flood prone areas paying an extra £10-£50 for their house insurance to fund insurance for those at risk. As a result, the government is causing houses to be built ‘in the wrong places.’
Large areas of concrete cause rapid run-off of rainfall into the nearest watercourse, thus adding to flooding which originates upstream. Possible means of mitigating flooding caused/exacerbated by urban/developed areas receives relatively little attention.
Despite severe flooding, and also drought, in recent years, there has been hardly any real airing of changes which will inevitably need to be made, not just in relation to flooding, but also in the context of water policy as a whole.
Given an increasing UK population, increased rainfall in a warming world, and at the same time the increased likelihood of drought, it makes no sense to return to the destructive dredging practices of the last century. If water is set to be an even more precious commodity than it already is, then it is simply nonsensically wasteful to send it out to sea at high speed at a time of surplus.
A notable recent report on flooding and related issues was the one put together by the Angling Trust, water engineers and wildlife groups (‘Floods and Dredging: A Reality Check’), which was presented to a parliamentary select committee in February 2014. It states clearly that the claim that dredging gives protection from flooding is ‘a cruel offer of false hope to those living in flood-prone communities.’ Dredging has in fact ‘significant potential’ to increase downstream flooding.
If anything, the report states, what is needed is a slowing of the rate at which the land drains, together with an increase in its capacity to fill and store water. Rather than straightening of rivers, what are required are measures which will encourage them to meander, together with the restoration of wetlands.
Sensibly, the report advocates a holistic, catchment based approach to the issue: one which takes account of residential needs and land use, including, crucially, activity in upland areas. It is now recognised that such things as intensive sheep farming and the burning off of heather uplands and removal of trees have been responsible for fast run-off, hence potential flooding, in downstream areas.
In the light of the above, I would greatly appreciate your responses to the following questions:
(i) What measures are under consideration for the holding back and possible storage of floodwater specifically for the purpose of domestic, agricultural and industrial supply and to mitigate the effects of future drought?
(ii) Why is it not mandatory for new housing/urban development to incorporate drainage perforations in large areas of concrete to ensure a steady run-off of rainwater into the water table?
(iii) Why is residential development on flood plains still permitted?
(iv) Why is the government effectively subsidising development on flood plains?
(v) What plans are there in place to encourage flood-resilient construction/modifications to existing buildings in affected urban areas?
(vi) What plans are there, if any, to establish an effective, independent flood prevention agency?
The formulation of an effective flood management policy and indeed a national water strategy are challenges which your own government and future ones will simply have to address. These are both issues on which a coherent, joined-up policy, as opposed to localised, unimaginative, ‘sticking-plaster’ measures, is long overdue. I look forward to your response.
Sincerely
RJ STURDY
