Gunthorpe Environment and Flood Alleviation Group

RESPONSE TO QUESTIONS SUBMITTED BY ROGER FELL ON BEHALF OF THE GUNTHORPE ENVIRONMENT & FLOOD ALLEVIATION GROUP

12 January 2004

A) SELF DEFENCE: during a radio programme “You and Yours” Elliott Morley MP Minister for Floods responded to a question by Peter Barnett National Flood Forum) that he was enthusiastic about the ideas of grand aid to support communities which fell outside the framework for hard flood defence provision.

Q1. What progress has been made by the Environment Agency in discussing with DEFRA, ODPM and Treasury for the establishment of grant aid or other financial support/funding mechanisms which will help the undefended property owners/communities meet the costs of carrying out self help protection as advocated by the EA in many leaflets and booklets?

The legal framework is such that DEFRA grants money to the Agency under S47 Environment Act 1995.  There is no legal provision to enable the Agency to give grants.  The provision of financial assistance to individual households is entirely a matter for government. We have had initial discussions with Defra but the Government has not taken a decision.

Q2 Will the Environment Agency support small communities and individuals to prepare defence plans with technical expertise and flood modelling to assess the risk to near neighbours as required in current guidance?  (PPG 25 Appendix F)

The Agency is a public body and must work within its empowering statutory provisions.  We make data on flood levels and flooding history available to individuals and groups, for which a charge is sometimes made.  We prepare reports when investigating possible schemes for communities at risk and the findings are available from our Area Offices.  There are no plans to prepare defence plans for small communities and householders that assess the risk of flooding to a particular property.

Q3 Will the Environment Agency give an undertaking that it accepts that the human habitat has a more valuable economic contribution to the nation’s wealth than the wildlife habitat which now appears to be given significant and possibly excessive precedence in decision making on provision of flood defences?

 In discharging its functions the Agency is required by statute to make the contribution towards attaining the objectives of achieving sustainable development outlined in statutory guidance.  It must also comply with the other law, for example the Habitats Directive.  The Agency applies Government tests to determine the merits of investment in flood risk reduction measures by considering the economic costs and benefits, as well as the social and environmental costs and benefits.  The contribution towards the economic justification of our investment varies according to the flood risk at the location under consideration, although often the tangible damages to property form a large element of the economic cost of flooding.

 The Agency is working with DEFRA to develop an alternative approach to investment appraisal.  This is termed “multi criteria” analysis.  This approach attempts to address the point that not everything can be measured in economic terms.  The method will try to strike a balance between social and environmental criteria to aid decisions subject to the normal test of value for money in the use of public funds.

 The Agency cannot therefore give an undertaking in the terms you suggest.
 
 Q4 Will the Environment Agency give an undertaking to consult urgently with DEFRA – ODPM – treasury to resolve the ambiguity in respect of what permissions and flood risk assessments are required for temporary demountable defences whether for individual properties or groups of properties?

 No, because the Agency cannot give legal advice to individuals or groups of people.  Many issues will be site specific and require specific legal and engineering advice. 
 

Planning matters are the responsibility of ODPM and a direct approach to the local planning authority involved may be useful.

B) COST BENEFIT CALCULATION: During a television programme Your Politics (Midlands Region opt-out) in mid year Paddy Tipping – MP Sherwood Constituency acknowledged that the revised methodology appeared to be flawed and required re-visiting.  This aspect also noted by the Minister in January to be giving strange results.

Q1 What action has the Environment Agency taken to resolve this point with DEFRA?

 DEFRA will be consulting on the revisions to their project appraisal guidance shortly following the Green Book changes.  We have discussed with DEFRA officials the use of the priority scoring system and the impact this is having on priorities within the capital programme.  We know that the needs of flood defence exceed the money available so some system of prioritising expenditure is necessary.

Q2 Will a revised methodology be commissioned which reduces the urban low income and coastal bias and removes the issue of statistical ward level social deprivation and wildlife habitats?

DEFRA has published a priority scoring system for flood and coastal defence investment based on guidance from the Treasury.  The system takes into consideration economic, social and environmental impacts.  Again it is a question of striking a balance between all of these criteria to reach an optimum solution that meets wider Government aims and objectives from flood defence investment. The Agency is planning to introduce a new prioritisation system for all flood defence investment from 2007/08.

C) ENGAGEMENT WITH LOCAL FLOOD GROUPS FOR PUBLIC AWARENESS CAMPAIGNS:  The recent campaign which commenced October 14th failed to have any connection with any flood action group – yet these groups represent probably a very significant majority of directly affected flood risk victims.  The campaign appeared to be confusing two elements : those directly at risk who have no defences and are repeatedly flooded and those others (the greater number) who are behind some form of defence yet considered at risk in the event of defence barrier failure or overtopping.

Flood Action groups have a vested commitment to securing the best response to local victims and offer unrivalled local knowledge and expertise which is not available in remote control rooms in an emergency situation.

Q1 What steps will the Environment Agency take to ensure that the financial resources allocated to Flood Warning and Awareness Campaigns are targeted accurately with the help of the many flood groups all of which will be well known by the various local and regional Flood Defence Managers/Flood Warning Officers of the Environment Agency?

Our flood awareness campaign is a national one targeting everyone who lives, works or invests in the floodplain. We take great care in targeting national messages using the most appropriate media.  Local flood groups do not cover all flood risk areas and not all investors, businesses, public bodies etc.  Local targeted campaigns can reinforce the national messages but they would have to be funded locally.

This year’s public awareness campaign was specifically targeted at the non-engaged, or “complacent” customer audience and the National Flood Forum (which represents local Flood Action Groups) was made aware of this during the planning process for the media campaign

A report on the Agency’s campaign is published on the NFF’s  website www.floodforum.org.uk and we are in regular contact with the Forum on a number of flood communication programmes.

Q2 What steps will the Environment Agency take to engage local flood action groups in all matters of flood warning methodology and make available via the website and flood warning/Floodline system the telemetry data at gauging stations so that local flood groups/wardens can actively monitor the risk at local community level?

 The Agency is always looking to improve its Flood Warning Service.  The Agency has a close working relationship with the National Flood Forum along with other stakeholders eg involvement in the development of the Agency’s Flood Risks Strategy, and is currently providing financial support as part of a 3-year initiative.  The Agency has worked with the forum this year on specific elements of the Public Awareness Campaign, including: enlisting support from people who have fitted flood protection products.  The Agency already receives input from local groups, and values the feedback which they give.

We are constantly developing the Floodline pages on our website in order to improve the range of consumer and technical information available to the public.  For 2004, our programme involves improved flood risk mapping information and our new flood warning dissemination system.  The provision of telemetry data on line or through our Floodline service is a long-held ambition but we do not have the resources to do everything at once.

D) EXEMPTION FROM REGULATION:
 
 Q1 What action is the Environment Agency taking in the process of consultation for  the proposed revision of PPG25 with ODPM-DEFRA to ensure that no  exemptions of consultation are given for any development in the active  indicative floodplain including the actions of highway authorities. 
 
The current PPG25 is due to be reviewed in 2004, and the Agency expects to be fully involved in this review.  We are also seeking a review of regulatory legislation such that we become a statutory consultee on flood risk by 2005 to ensure that we are consulted on all developments that could affect flood risk in a catchment or coastal cell.

 Q2 Will the Environment Agency seek to make the guidance one of statutory    power?
 
The Agency made it clear in its response to the Flood and Coastal Defence Funding Review consultation that it is in favour of aspects of PPG 25 being translated into law if PPG 25 fails to have the desired effect as planning guidance.

E) INSURANCE PROBLEMS: It is noted that the new Floodplain mapping will not offer sufficient detail to identify the actual property risk – that the maps are suited merely to strategic processes. (From report to Midlands RFDC)

The Agency’s Flood Mapping Strategy sets out our plans to improve flood maps over the next 5 years.  A copy can be obtained from your local Agency office.  The Agency will be mapping areas at risk from flooding, rather than specific properties, because mapping specific properties would require detailed information to the two million properties within those areas at risk of flooding.  Our investment in flood risk mapping will enable us to improve our information on flood risk over time.  This will help us to communicate the level of risk to people that live, work or invest in flood risk areas.

Q1 What steps will the Environment Agency take to provide every resident who wishes a definitive statement of the flood height for the 1% and particularly the lower 1.33% risk (set as the current ABI Statement of Principles document threshold) and a certificated threshold and floor height for that property?

 We currently have a national assessment of the probability of flooding to areas of land at post code sector level and we have shared that information with the insurance industry.  This is available by visiting our Area Offices.  We have no plans to provide individual risk assessments for every property in the floodplain.  To do so would involve maintaining a database of nearly 2 million properties with floor levels along with complex calculations.  Residents can always seek professional advice if they require better information than we have.
 
Q2 What steps will the Environment Agency take to consult with DEFRA – Treasury to provide grants to carry out such surveys as a matter of priority following the production of new floodplain mapping?

 The implementation of the Government’s funding review means that from 1 April 2004, DEFRA will no longer grant aid specific projects.  We do not propose to carry out household surveys.  We believe that the money would be better spent on reducing flood risks.

Q3 Does the Environment Agency accept that when only the existing insurer will offer new insurance there is no free market for the property owner and that this has direct adverse effect on the national asset of housing stock and on social costs and that in such circumstances the American model is appropriate whereby the State undertakes the risk cover against stringent land use control having declared an area to be one of flood risk?

 Insurance is a matter for the Government and the Insurance Industry.  The Agency has no view on insurance policy as you describe above.

F) REPRESENTATION ON RFDC (or successor bodies resulting from Water Bill): In recent debate in Committee Stage of Water Bill the point was raised regarding local group representation.

Q1 Will the Environment Agency consult with DEFRA to support the representation of Action Groups at all RFDC Meetings, in addition to the standard appoint of Local Authority Councillors and that all proceedings and reports to RFDC meetings shall be placed on the Environment Agency website?

 
The appointments to the Regional Flood Defence Committees are made by DEFRA, the Agency and Local Authorities under the Environment Act 1995.  The RFDCs take a strategic view of flood risk management in their district and no member represents an interest group.  Any member of the public can apply to DEFRA for appointment to a Committee when vacancies are advertised.  Local residents can make representations to the Councillor who is appointed by their local council to the Committee.

All  RFDC meetings are open to the public and reports and minutes of their meetings (except confidential items such as contractual papers) are available to the public from your local Regional Office.  Our website is in the process of being improved to enable us to place further information on the site late 2004.  We may then be able to add such items as the RFDC Committee papers.  The Agency’s Board papers and minutes are already available from our website.

 

ABOUT THE GROUP

Nottinghamshire – Postcode NG14 7ES
Submitted 29 September 2003

LOCATION:

Situated on Lower Trent between Nottingham and Newark, Gunthorpe parish comprises some 350 households plus a number of businesses serving the leisure industry - pubs, restaurants, car and caravan sales and petrol station.  It is a major crossing point of the River Trent by road (A6097) which crosses the 3.5km wide valley.  This road is used by some 20,000 vehicles per day.  It is therefore strategically important in regional communications.

FLOODING HISTORY & CHARACTERISTICS:

Major damaging events are relatively infrequent with 1795, 1852, 1875,1910,1932, 1946, 1947, 1960, 1977 and 2000 being particularly notable.  The flood plain spread in such events is some 2.5kms in width although flood depth is limited - in 2000 the general flood depth was less than 500mm although the critical road access was up to 1000mm deep marooning 250 households which were otherwise dry.   Flood duration is 2 to 3 days.  The 2000 flood event was deemed a 1 in 55/65 return period therefore well below the present ABI threshold of 1 in 75  (1.33% probability in any one year).

Less than 50 properties were flooded internally but the final overall damage value to home and business owners probably exceeded £1.5M.  Repair costs ranged to in excess of £100,000 and a number of homeowners were out of property for 6 months - a pattern repeated in many communities.

FLOOD GROUP COMPOSITION:

Originally it operated as a simple round table forum avoiding any formal structure with a co-ordinator who brought together meetings and gathered information.  A detailed survey of every property was carried out to establish a solid database in respect of the impact of the flood:  this produced detailed mapping.  All data gathered was forwarded to the respective agencies and authorities and over time these bodies joined in meetings to review the position and to consider what lessons could be
learnt.

Funding was by voluntary individual donation to offset out of pocket costs. In order to be given a grant towards those costs from the Parish Council it became necessary to formalise the group with a constitution to satisfy auditing requirements.

As part of a long-term objective the aims include a wider environmental view which might facilitate funding stream application from bodies such as the Lottery, Heritage Initiative, Aggregates Sustainability Levy Fund etc. This is applicable due to a major potential quarry being permitted in the immediate upstream location with the perceived implications from major alteration of the natural floodplain during the process of extraction. This extraction is both off line and within the active floodplain if permission and approval of a Revised Local Mineral Local Plan are passed.

A core group of residents operate the group:  any resident is able to input to the discussion and where appropriate differing views and potential solutions are treated in equal weight in order to maintain harmonisation of objectives.  A list of defence objectives has been drawn up and from those a shortlist of priorities.

PROVISION OF DEFENCES:

Under the current system Gunthorpe does not qualify for any funding nor will in the foreseeable future.  GEFAG is therefore working on the basis of local provision from alternative funding / enabling mechanisms in conjunction with individual resident protection.  Thus far few residents have felt it worthwhile to provide own defence mechanisms preferring to develop community concepts to give added value.  A difficulty exists in that a number of locations are involved and each has specific requirements needing differing solutions.  A further major problem is that water rises into properties via gravel bed flows which therefore require defence lines some distance from properties to create a reduction in groundwater levels.

A great deal of time has been spent assembling a significant database of reports and factual material (both written and visual)  with active support of all agencies and authorities.   It is now felt that there is a need to seek a total review of the DEFRA / EA methodologies since for Gunthorpe (and seemingly many other communities of small size) the present system is a total failure.   Although defences and flood engineering can be identified back to Roman times modern engineering solutions have become cumbersome. Many existing Lower Trent defences are very old and really target protection of agricultural land  -  reports from 1700 show a detailed awareness of the need for flood protection.   It is felt that it is only in the last 50 years or so that the provision of simple flood banks for rural communities has become bogged in red tape.  Furthermore GEFAG has identified a number of actions by past authorities which have ignored the impact of development - including the raising of the cross-valley highway - and Highway Authorities remain exempt from control by EA and predecessor authorities.

EMERGENCY RESPONSE:

Following the 2000 event GEFAG has worked very closely with the Emergency Planning teams at County and District level as well as engaging with the responding emergency services.  This is producing excellent results and recently GEFAG produced a draft Emergency Response Plan for consideration by District Council drawing on 2000 experience as well as experience and knowledge from residents who have lived in the community for up to 90 years.

An embryonic Flood Warden scheme is in position able to immediately work with the Emergency Planning and responding Agencies:  it is accepted widely that the local input is fundamental since local knowledge saves time and effort:  furthermore local Wardens are immediately trusted by residents should evacuation be required in adverse conditions.

CONCERNS and ACTIONS

The primary issue is that the DEFRA / EA / ABI agenda is continually shifting away from the initial belief that there was to be a funding stream to secure many an defended small communities.  The word DEFENCE is being removed in favour of FLOOD MANAGEMENT which offers a catch-all get-out to Government.

There is total confusion in the area of temporary defences and whether or
not individual defences are or are not permitted when they include enveloping areas around properties displacing flood storage capacity.

There is a marked implication by EA statements that they are really intent on being a regulatory body yet experience is that neither the EA nor predecessor authorities have been able to effectively manage flood risk since there are too many exemptions.   There is conflict between Bylaw 21 1979 Land Drainage Act and the apparent permitted small-scale provision of extensions to properties with PPG25.  Bylaw 21 prohibits solid structures in the floodplain but operations by Highway Authorities etc are exempted. This is not an equitable position for residents and businesses.

There is no further movement in respect of Grant Aid for local small-scale defences - there are ongoing issues surrounding the level of insurance cover from 2007.

New Flood plain mapping appears to have stalled:  locally the EA is unable to quantify / demonstrate the 1 in 75 floodplain outline which is required for insurance purposes:  there is no floor level data held which is reliable/ accurate by EA.

There is concern that far too much weight is being given to Flood Plain modelling accuracy:  GEFAG research indicates that this is a very difficult area - it is not an exact science and has many problems linked to data input.  The work currently underway by Black and Veatch (Fluvial Trent Strategy - c. £500,000) is well behind schedule and the final modelling is likely to have a tolerance of plus or minus 200mm which is hopelessly inadequate to determine precise risk as required by insurance company enquiries to local policyholders.  This tolerance could mean a difference
between a 1 in 50 and 1 in 200 risk value in this location whilst being regarded as a nominal 1 in 100.  No one can give a clear statement.

GEFAG is seeking that Regional Flood Defence Committee minutes and associated reports are made available on the EA website.

GEFAG is seeking that the flood level data at gauging stations is given out on Floodline and shown on the website to offer clear guidance in respect of river rise rate and expected peaking so that local judgment of risk is able to be calculated:  this is supported by the Emergency Planning Officers at County and District.  The present vague info is useless in real terms. Individual residents need to know whether they are actually at risk – in the 2003 New Year event this was tested informally with the help of staff at EA and worked favourably in Gunthorpe when it was possible to assure
businesses and residents that levels would not become damaging.

Concern is expressed that far too much weight of thought is directed to soft engineering solutions / environmental interests driven by European Directives on Habitats and that there is a need to seek a priority position weighted in favour of humans.

GEFAG will therefore continue to represent these concerns through an agreed quarterly review meeting with the local EA Defence Manager and Team.  The
aim is to achieve a positive mitigation of flood risk through local initiatives by the community and individual home and business owners:  to challenge past decisions and to seek restoration of the floodplain where it can be shown to have effect.  The philosophy is that where there is a community will there will be a community way:  positive thinking is required by all parties to solve the problem and changes are required in the regulatory process to enable some of those actions to become solutions.

CONTACT:  Co-ordinator  -  Roger Fell 0115 966 5513