Evidence sessions by the Committee are likely to begin on 10 October and the Committee has invited written memoranda to reach them by 13 September 2007. 

Submission regarding the recent floods

By Cllr. Philip Booth, on behalf of Stroud District Green Party and in consultation with the Ruscombe Brook Action Group,

Contents

1. Executive Summary

2. Climate change: need for honesty
2.1. Cause of floods
2.2. Need for clearer message re climate change

3. Sustainable Urban Drainage systems
3.1. What are SUDs?
3.2. Advantages of SUDs
3.3. Ignorance and resistance
3.4. Adoption problems
3.5. Lack of urgency worrying
3.6. National guidance needed

4. Other key measures to reduce floods
4.1. Prioritise upstream flood defences
4.2. Develop a proper water resources strategy
4.3. Stricter rules about housebuilding on flood plains.
4.4. Reduce impermeable surfaces
4.5. Important role of agriculture.

5. Crisis management

6. Other wider issues
6.1. A robust carbon emissions reduction programme
6.2. Build community resilience
6.3. Restore water companies to public ownership and ensure proper regulation.
6.4. Consume less water.
6.5. Decentralising energy.
6.6. Rethink sewage

1. Executive Summary

Gloucestershire was one of the worst hit regions with the recent floods and all the indications are that such events will increase in the future. Our main recommendations are that we urgently need to adopt a mandatory and comprehensive national SUDs policy and significantly improve public awareness about the realities of climate change. We need to develop a comprehensive strategy towards water: this would include prioritising upstream flood defences, stricter rules about housebuilding on flood plains, reducing impermeable surfaces and a re-looking at the role of agriculture.

We also need to look at how we can improve our crisis management, seriously tackle the causes on climate change with a robust programme of carbon reduction, restore water companies to public ownership, build community resilience, rethink our sewage systems, decentralise energy and consume less water.

2. Climate change: need for honesty

2.1. Cause of floods. Let us be clear from the start the amounts of rainfall have been so extreme that any measure of preparation would have been bound to fail: dredging rivers, better sand bag organisation, inadequate contigency planning (bowsers and communication) and a host of other measures would have helped but it is clear we need to better acknowledge the climate-change-related nature of the floods. Recent joint research by several national climate research institutes, including the Hadley Centre of the UK Met Office, supports this view: it is not just the climate's natural variability which has caused the increases in rainfall and temperatures, but there is a detectable human cause ­ climate change, caused by our greenhouse gas emissions (i).

2.2. Need for clearer message re climate change. The public are not being given the facts about climate change or the urgency with which we need to tackle it. Numerous local examples like a County newspaper confusing ozone layer and climate change in their editorial last month, local Drainage Boards not having the implications of climate change as part of their policy and the local airport issuing a statement that climate change is a myth. Similarly nationally some papers rarely mention climate change (The Sun mentioned it about 6 times in 6 years) and even the Government's Chief Scientist goes against international scientific agreement that the stabilisation target should be 430ppm CO2e. While he doesn't deny the catastrophic effects of climate change or that the number of people at high risk from flooding will more than double to 3.5 million by 2080, he suggests 550ppm CO2e is a realistic goal. As Tony Juniper (Executive Director of Friends of the Earth) said: "That might well be an arguably realistic perspective, building on one set of political and economic judgements, but that is not what the science says we should aim to achieve; nor is it the role of scientists to propose such compromises."

We would fully support Mark Lynas view when he writes (ii): "Admitting our own culpability in this emerging crisis is a recipe not for despair, but for hope: we can still stop the situation deteriorating beyond the point of no control, but only if we act fast to cut back on greenhouse-gas emissions. And that means politicians in particular need to sell the climate mitigation message better, making explicit links, for example, between the misery of people in Tewkesbury and the determination of BAA to expand Heathrow and Gatwick. Polls show that the general public is still not convinced about the reality of climate change, even as the flood waters rise towards people’s front doors."

3. Sustainable Urban Drainage systems

3.1. What are SUDs? The SUDs philosophy is an integrated approach to managing water on site by minimising run off, attenuating discharge rates, detaining water for passive treatment, improving water quality and creating amenity space for people and wildlife. The overriding concept of SUDS is that drainage design for development sites should mimic, wherever possible, the existing drainage characteristics of the area and seek to minimise the effects of development on the hydrology of the site and the surrounding environment: water will be dealt with as close to where it falls as possible (iii). SUDS can be achieved by utilising a series of porous hard surfaces, swales (broad open ditches), ponds and wetlands. These all ensure that water seeps slowly away in to ground water (as would happen naturally pre-development) or is discharged to the drainage system at a low controlled rate.

3.2. Advantages of SUDs. SUDs systems offer solutions that are often at a lower cost and lower maintenance costs to traditional systems and are more sustainable than convention methods because they:

- reduce runoff flow rates which reduces the resulting pollution from run-off
- reduce flooding and subsequent damage to water courses and more
- protect or enhance water quality
- improve habitat for wildlife
- provide a public/functional space (good examples in Sheffield and Lewisham where SUDs have been integrated into local parks) or for willow, biofuel or aquaculture
- reduce depletion of ground water flow which in turn impacts upon water resources

3.3. Ignorance and resistance. Take up in England and Wales is very poor indeed even with support from Government through PPG25 and other policy documents, and from the Environment Agency. Forward thinking councils like Gloucester City are attempting to develope ways to encourage more SUDs schemes. However they and indeed most Councils, even where they have SUDs policies as part of their planning process, are not seeing SUDs schemes delivered. Ignorance and resistance within the construction industry means that drainage proposals that have been called SUDs schemes have not always delivered easily maintained, visually attractive and functional solutions. Similarly even where Local Plans have called for culverts to be opened up this has not occurred despite new developments. It is critical that greater guidance and support is provided before a Detail Planning Submission is made.

3.4. Adoption problems. One key excuse that developers use to not submit a SUDS scheme is 'adoption'. However if structures are designed correctly in the first place then maintenance costs should not be prohibitive and structures can be adopted as long as appropriate commuted sum payments are made. In traditional systems pipes are adopted by Severn Trent, for which they are allowed to charge through the water rate: typically 10 – 15% of a water bill will be for this service. If the pipe discharges into a balancing pond then it is the local authority, who, with a commuted sum will take on the maintenance of this area in a similar way to public open space. Currently Severn Trent are obliged to adopt pipes typically used in traditional systems, but refuse to adopt many of the features associated with SUDs such as swales, filter strips or French drains even though they convey water from one place to another. It is not clear why this is the case, however, it has been suggested that the current system suits them well and there is no commercial benefit to change it. Local authorities have also been reluctant to take them on board as they are unfamiliar with them, and they have no long term revenue stream to pay for their maintenance even though SUDs usually have lower maintenance costs than traditional systems.

3.5. Lack of urgency worrying. The Interim report on SUDS was published in July 2004 and there is not even an estimated date for the final report. Furthermore that Interim report did not go far enough in making use of the advantages of SUDS. Apparently a group led by the Environment Agency, including representatives of major stakeholders, is considering both the technical standards and legal issues required to underpin the future adoption of SUDS. Again this appears to lack any sense of urgency.

3.6. National guidance needed.  We urgently need clearer guidance and a stronger lead from bodies like the Environment Agency. A move to adopt a mandatory and comprehensive national SUDs policy in all new developments like in Ireland and Scotland would be a significant step towards managing our water better, but in the meantime individual Councils can considerably improve their current provision of SUDs through LDFs and more.

4. Other key measures to reduce floods

4.1. Prioritise upstream flood defences. It was reported last month that only 46% of flood defence systems in high-risk areas are adequate. This clearly needs addressing. The importance of measures like dredging of some water channels and ensuring culverts do not become blocked has also been underestimated. However the key cause of our flooding (and regular droughts) is the inability of our land to properly store and infiltrate rainwater, together with the increased evaporation this causes. Further expenditure on downstream flood defences and increased drainage will be little help. Upstream storage and infiltration is a much cheaper and safer alternative (amongst a range of options), which will boost agricultural and local economies in a variety of ways.

4.2. Develop a proper water resources strategy. This is currently part of another consultation by the Environment Agency which starts with the welcomed acknowledgement that water companies should not be continuing to meet unconstrained demand. There are many aspects here that need consideration including many of the points already mentioned in this report. There is also a huge potential to better model the possibility for flooding within each catchment, but also to improve our analysis of potential flooding and provide proper protection for key sites like Mythe water treatment plant and Walham substation.

4.3. Stricter rules about housebuilding on flood plains. New properties must be expressly designed to cope with flood risk and still allow the land to soak up the water so that the problem is not transferred elsewhere. There are a whole host of designs available from what are effectively houseboats that rise and fall with water levels to others homes designed to cope with flooding. In the last year 21 major developments have been built on flood-plains despite explicit appeals by the Environment Agency and in direct contravention of national policy.

4.4. Reduce impermeable surfaces. National awareness campaign to reject concrete in favour of “porous” townscapes which allow rain more easily to refill the aquifers and reduce run-off and flooding (iv). Severn Trent Water report a 4% increase in their regions impermeable hard surfaces area each year. Councils need to be enabled to take action to manage and protect more effectively all green spaces including front gardens.

4.5. Important role of agriculture. Instead of civil engineers we need agriculture to be restored to it's role of helping manage our water resources. This will require changes in farming practice in catchment areas prone to flooding such as reducing over stocking which compacts the soil and run-off, turning more arable areas into pasture land (which retains water better), expanding flood plains, planting more trees (woodlands are up to 60 times more effective at infiltration than bare arable land) and supporting organic farming which manages water better.

Water companies spend up to £313 million a year dealing with nitrates, pesticides and other contaminants (10% of the costs of supplying drinking water): chemicals and energy-intensive ultra-violet treatment make the water-industry the most energy-intensive utility (2.6% of UK carbon emissions). Instead we should tackle pollution at source, reduce chemical farming and use critical upland sites to allow water to soak away naturally. Defra should pay farmers to produce food in a way that works for water, wildlife and landscape.

5. Crisis management

Various measures like better preparation but also:
- stronger measures to stop people making unnecessary journeys, which contributes to congestion and stops the emergency services being able to reach affected areas: despite extreme weather warnings people still streamed onto 'their' roads as if on autopilot
- clearer warnings about the health risks of contaminated flood waters
- improved communication over issues like siting of bowsers

6. Other wider issues

6.1. A robust carbon emissions reduction programme. This is critical to lessen the risk of freak weather events in the first place.

6.2. Build community resilience. The cheering news from the flooding is the way people have supported each other in the face of crisis. We are increasingly going to have to learn to rely on ourselves and each other more and more in the coming years. Building up resilient local economies and strengthening our communities is the most positive route we can take to protect ourselves from future crisis. Government can and must facilitate such moves (v).

6.3. Restore water companies to public ownership and ensure proper regulation. Ownership matters profoundly: rather than companies that seek to exploit loopholes in the regulatory regime, sell off  "surplus" assets and fail to make improvements we want water companies back in public ownership and properly accountable to the electorate. In the first 9 years of privatisation pre-tax profits of the water companies rose by almost 150%. OFWAT, the sector's regulatory body, found that operating expenditure as a proportion of bills had shrunk; the capital charges rose; but operating profits, which have more than doubled, account for virtually the entire increase in customers' bills. The Environment Agency, Health Protection Agency, OFWAT and Defra all need to play a more significant role in improving and enforcing regulations.

6.4. Consume less water. The Germans consume a third less water than the English so it is possible to reduce consumption and still be comfortable. Measures needed include dual-flush loos, water butts, drip irrigation rather than sprinkler, grey-water harvesting and water metering to encourage conservation of water.

6.5. Decentralising energy. Power station cooling accounts for 39% of national water consumption: ironically drought orders could shut power stations like Didcot as flows of the Thames become too low. Decentralised energy could include using existing technology to siphon methane off sewage plants to sell as energy and using the dry wastes as fertiliser.

6.6. Rethink sewage. Flood waters are highly contaminated with sewage and virtually every river in the country faces regular sewage contamination. Even in normal rainfall, sewers regularly surcharge into rivers and onto land (50 times a year in Thames area, typically 20 times a year in Gloucestershire). These surcharges, often through 'consented outflows' (ie with consent from the Environment Agency), comprise of the biggest single source of pathogenic (disease causing) material. Over the years these discharges have in many cases worsened. We urgently need a rethink of the Victorian model of urban sewerage infrastructure. Embedded, decentralised wastewater treament within the urban context using SUDS appears the only cost effective method of reducing these health risks, and could in many cases also reduce sewerage charges.

We need a whole host of measures to address this issue, including:
- Breaking up present unnatural sewage disposal infrastructure
- Investigation into the health risks of sewage in our water courses
- Determine appropriate public health (microbial) standards for watercourses and the discharges into them
- Cease local development (new sewer connections) until appropriate sewer (microbial) standards for watercourses and the discharges into them are achieved
- Transfer of private sewers into the hands of the water companies (a Defra consultation is currently looking at this)
- Promotion of cheaper and more sustainable solutions like reed beds



Notes:

(i) The Intergovernmental Panel on Climate Change (IPCC) confirms, in its February report: “The frequency of heavy precipitation events has increased over most land areas, consistent with warming and observed increases in atmospheric water vapour.” As the IPCC states, there is an identifiable global trend towards more intense precipitation – in all regions, and in all seasons. Even where the climate overall is becoming drier, as in Australia, when rain does arrive, it falls with undreamt-of ferocity. That means flash floods, even in places far away from rivers that may never have experienced flooding before. None of this on its own “proves” climate change, but it clearly fits the prevailing trend. There is more energy in the system, driving a more vigorous hydrological cycle.

(ii) See article in New Statesman here:
http://www.marklynas.org/2007/7/26/britain-s-floods-what-s-really-going-on

(iii) The basic underlying concept of SUDs is referred to as the 'management train' and this generally mimics, by a series of drainage techniques what happens in the natural world. The management train has 4 components:
1. Prevention. This may mean reducing the area of hard standing or simply including water butts in roof down pipes.
2. Source Control. This is the control of runoff at or as near the source where it falls and could include permeable porous paving for vehicular hard standing.
3. Site Control. This deals with the actual runoff and may include swales that transport water around the site and balancing structures that allow water to stand to infiltrate into ground water or discharge slowly into a water course.
4. Regional control. This is beyond the confines of the individual site and would include an integrated approach involving a number of developments.

(iv) Carlo Laurenzi, Director of the London Wildlife Trust notes the increase in run-off from an impermeable surface such as concrete can be as much as three times greater than the run-off from porous surfaces. This  impacts significantly on drains when flash floods occur. The Royal Horticultural Society notes that an average suburban garden on a typical rainy day will absorb 10 litres of rainwater a minute: this is about 10% of water that will fall in a storm. Although this may not seem a lot it plays a part in preventing thousands of litres contributing to localised flooding or causing rivers to burst. See the London Assembly's report (September 2005), "Crazy Paving: The environmental importance of London's front gardens."

(v) There are many examples on how we rely too much on growing centralised provision and control. In the fuel blockade protests (September 2000) supermarkets confirmed that we came within a couple of days of the whole food industry coming to a halt. Similarly if Gloucester's Walham substation had been flooded 250,000 would have lost power (and water as electricity is used to pump water). Local food and decentralised energy are clearly more robust in the face of crises.