EFRA Inquiry into Flooding Comments from the Country Land & Business Association (CLA) Executive Summary The CLA is the leading national organisation which represents and supports businesses in rural communities, covering all aspects of land use and management. Our comments are based on those received from our members and their collective experience of the recent floods. Rural communities have suffered significant losses and difficulties in the recent floods. Farming has been particularly hard hit. Crops were destroyed or damaged by flood water and the excess rainfall experienced, which will have a knock-on effect on availability, quality and prices of a number of foodstuffs. Livestock farmers were given little warning or advice before/during the floods and encountered severe problems trying to move and house large numbers of animals at short notice. Grazing and fodder crops were destroyed leading to longer-term difficulties for these farmers. Many of the financial losses resulting from the flooding will not be met through insurance, as premium costs are prohibitive, and will have to be borne by the businesses themselves. Accepting that the rainfall was abnormal, the primary causes for the severity of flooding in rural areas, and the length of time the flood waters took to recede, was lack of maintenance of river channels and flood defences, coupled with the difficulties arising as a result of excess building on flood plains. Weed growth and overhanging vegetation has been allowed to choke many watercourses, severely reducing flows, leading to overtopping of river banks and defences. One of the causes of this lack of weed cutting is the Environment Agency’s concentration on environmental/wildlife priorities rather than flood protection. One suggestion is that the Environment Agency concentrates on its water management and flood defence roles and achieve a more sensible balance with its environmental champion role. Flood defences and pumping equipment have not had the level of repair and improvement needed in the past decade, and were not therefore fit for purpose. Lack of personnel and resources, such as temporary flood barriers, were obvious in the days leading up to the flooding. Rural populations have suffered particularly due to lack limited resources and priority being given to urban areas. It is abundantly clear that the level of spending on flood protection is woefully inadequate and will need to be substantially improved if losses from future flood episodes are to be minimised. Future flood management needs to be based on a planned, catchment-based approach, limiting further development in flood plains. Landowners have a role to play in the creation of washlands sited to accept excess water and protect local and downstream populations. However, they will need to be properly recompensed for this benefit to wider society. We believe Internal Drainage Boards have the ability to play a greater role in flood management, taking back responsibility for Critical Ordinary Water Courses. EFRA Inquiry into Flooding Comments from the Country Land & Business Association Background The CLA is the leading national organisation which represents and supports businesses in rural communities, covering all aspects of land use and management. We represent the breadth of the rural economy and 38,000 members in England and Wales between them own around 5 million hectares of rural land. Our members run more than 250 different types of businesses in rural areas including agriculture, forestry, fisheries, renewable energy, food, tourism, recreation and other rural businesses. Availability of fresh water, flood and coastal defences are important concerns for them, and are, in turn, influenced by their land management activities. Our comments are based on those received from our members and their collective experience of the recent floods. Problems Encountered 1. Flood damage to property and buildings. Homes, business premises and farm buildings were all subject to flooding with resultant damage and losses. Of particular concern to farmers was damage to materials such as seeds, livestock feedstuffs, fodder crops (hay) and farm produce – many of which are difficult to replace due to the localised production of certain crops and the seasonal nature of their production. 2. Damage to crops and longer term effects. Flood water that covered growing crops, including grassland, for more than 48 hours generally resulted in the total destruction of that crop, rendering it worthless. It is worth noting that in circumstances where saline water covers crops the time before total damage is incurred is significantly less (usually about 1½ - 2 hours). The result of crop losses is economic loss, but unlike most domestic and business losses, crop losses are more difficult to replace due to the seasonal nature of farming. Loss of potatoes, peas, oilseed rape, etc will undoubtedly impact on food availability and prices. Even areas that were not flooded have suffered from reduced yields and lower quality crops as a result of the unusually high summer rainfall so there are likely to be general shortages of many UK grown foods. One vining pea farmer in Lincolnshire estimated his loss from the pea crop alone of £410,000 - resulting from 42 acres of crop completely destroyed by flooding from the local river, 360 acres partially flooded and the remainder damaged by heavy rain leaving the crop unfit for vining. Two neighbouring members in Lincolnshire lost 70 acres and 55 acres respectively of a borage, completely destroyed by river flooding. They have estimated a net loss of £230/acre amounting to £28,750 between them. Potato growers have also suffered significant losses of crops from flooded crops. Where the floods receded more quickly the result was much reduced quality produce. Loss of hay/silage crops can only be replaced by buying in materials from other areas, with the resultant countrywide shortages and higher prices further affecting businesses already devastated by flooding. Grazing land is particularly difficult to replace especially where significant areas of grassland were affected. It is both costly and practically difficult to move herds any distance from the farmstead. Insurance is not available to cover these losses. The flood waters not only damaged the economically important crops but many environmental stewardship strips, field corners and natural meadowland. In several places, land that had been deliberately converted to flood alleviation grazing meadows under an ESA scheme - but is usually only waterlogged over winter - was badly affected leading to concerns about environmental stewardship payments and the impact on flora and fauna. Rotting crops, especially grass that had been cut for hay or silage started to ferment and polluted the flood waters and resulted in several local complaints that farmers had emptied their effluent pits into the floods. In winter floods the water is colder and there are no fleshy crops, thus this problem does not normally occur. 3. Particular problems for livestock farmers. In addition to the obvious difficulties of finding higher ground/available empty buildings, moving substantial numbers of livestock and finding replacement feeds/fodder crops in a very short time scale, there were a number of welfare and bureaucratic issues following the floods. In several instances, cattle had to be moved from flooded land onto grassland allocated for second-cut silage, thus the second-cut silage crops were lost. In addition some farmers had to start feeding first-cut silage to young stock because of lost grazing. Several members have reported having to reduce stock numbers due to lack of winter feed stocks. Having to move livestock away from the main farm results in higher costs and less opportunity to keep watch over them – contrary to the advice given in the Animal Welfare Regulations. One farmer on the banks of the River Severn had to find accommodation for 1000 sheep and 500 cattle in less than 24 hours – and is now left with the difficulty of finding grazing and fodder for them as all his crops were destroyed. Neighbouring farmers do not have the necessary ‘spare’ grazing land. Many livestock farmers cited lack of help and advice in dealing with animal movement records and other bureaucratic requirements. The recent restrictions on animal movements due to FMD will have further compounded problems for many farmers suffering lack of grazing and fodder. 4. Lack of flood warnings and advice. Many CLA members commented that whilst flood warnings were generally adequate, little help and advice was available for businesses/farmers. Because of the problems noted above, particular priority needs to be given to issuing warnings to livestock farmers. We understand that in past this was the case but that was not the experience in the recent floods. 5. Disruption to water supplies following the floods and resulting problems. Following disruption to fresh water supplies, housed livestock and dairy herds, in particular, had great difficulties, resulting in distress to animals. Whilst emergency supplies for domestic use were being provided, little was forthcoming for farmers. There was no point of contact to obtain help or advice on this or other matters. 6. Insurance. In common with domestic premises in flood plains, farm insurance is either very costly or not available. It is prohibitively expensive to get insurance cover for damage to growing crops, grass, fodder, etc so these losses will have to be borne by the farming business. Livestock farmers, already under pressure financially, will suffer severe hardship in bearing these losses and these floods may result in them going out of business. It is hoped that giving the affected localities Disaster Area status will allow EU funds to be made available to those businesses that have suffered catastrophic losses. Underlying reasons for the problems 7. Lack of maintenance of flood defences and river channels. In rural areas the main reason cited for the severity of recent floods was lack of maintenance of flood defences and lack of clearing rivers and watercourses of vegetation. Many defences overtopped where they had been allowed to fall into a state of disrepair, and once the water got through, further damage to the defence resulted. The lack of basic repairs and maintenance to defences has resulted from inadequate funds and resources, coupled with excess emphasis on habitat protection. Farmers and the rural population feel strongly that defence of their land and properties is being neglected in favour of larger urban areas as funds are inadequate. The poor state of some of the pumping stations and the bureaucratic delays in getting authorization to pump were also cited as contributing to the severity of flooding. Some members commented on the policy of maintaining high water levels in certain watercourses – for example the Ankeholme - to allow recreational navigation. This, of course, reduced the ability of the water course to cope with extra rainfall. 8. Building in flood plains. The failure of planners and developers to heed the Environment Agency’s advice about building homes and associated roads/hard surfaces in flood plains is generally regarded as one of the main reasons for the severity of the flood problems encountered. It puts at risk those properties in the flood plain as well as those further downstream which suffer because the ground is covered in hard impermeable surfaces which have a very much reduced capacity to absorb water. 9. Flood defence vs habitat protection. Numerous members suggested that many watercourses were not being kept clear of vegetation to the same extent as in previous decades – and most believed this was because the Environment Agency is jointly responsible for flood and environment protection, leading to conflicts of interests within the one organization. Whilst East Anglia did not suffer severe flooding on the scale experienced in Gloucestershire, there have been numerous cases where grazing meadows have been flooded and have failed to drain away quickly (resulting in lost grazing) - all as a result of rivers being infested with weeds. The local Agency personnel have stated that they were unable to undertake adequate weed cutting early in the season because of having to protect nesting birds and other wildlife. 10. Lack of resources and manpower. In the days leading up to the floods, and subsequently, the lack of adequate personnel within the Environment Agency was manifestly obvious. Operational teams have been greatly reduced in recent years and they were clearly unable to cope with the emergencies. In this situation the resources were, understandably directed at larger areas of population, leaving isolated rural communities and farmers more vulnerable. One example occurred north of Welshpool where the Environment Agency had just started renewing a flood embankment using its own workforce. They had removed 500mm from the top of the old defence and had started building the new embankment on a new line set back from the river. A flood warning was issued on Thursday 19th July, with a further two flood warnings the next day at which time there were no Agency in-house work force available as they were all south of Worcester. On the Friday evening the Field Team Manager had to obtain some (inexperienced) private digger drivers to try to rebuild 1,480 metres of partially demolished flood defence. On Saturday morning it failed and the embankment overtopped. The area defended is 1,500 acres with 29 dwellings, including 7 dairy farms, resulting in much unnecessary damage. Firstly, the Environment Agency should have heeded its own flood warnings and started the repair 24 hours earlier when the first flood warning was issued. Secondly, the in-house Operations Delivery Team of 16 (originally 22) are responsible for not only work in Upper Severn Wales but also for erecting flood barriers in Shrewsbury, Ironbridge, Bewdley and Worcester. They were away doing this as well as assisting in the Tewkesbury area with the defence of electricity substations. They were stretched beyond what was humanly possible. The reliance on temporary barriers for flood protection clearly relies on adequate barriers being in the appropriate place and adequate manpower to erect them. In some places there appears to be lack of clarity between local Councils and the Environment Agency about responsibilities for storage and erection of these barriers and post-flooding clear up. As an example, the Environment Agency decided that temporary flood barriers were the solution in places such as Shrewsbury, Ironbridge, Bewdley, Worcester and Upton on Severn. It decided it would retain the responsibility for the erection and storage of the equipment rather than delegate this to the local councils. The policy of retaining control of the barriers caught it out at Worcester and Upton on Severn. The barriers are kept at Kidderminster, upstream of Worcester and again it did not respond to its own Thursday Flood Warning. The men started moving the equipment on Friday and got caught in the local flooding on the M5 and local roads. They never got to Worcester or Upton. 11. Failure to consider whole catchment. Flood management has historically been looked at on a fairly local basis, especially with regard to individual development proposals. It clearly needs to be considered on a much wider scale. Whilst some of the recent problems undoubtedly arose due to local ‘flashy’ watercourses and inadequate drainage systems, many problems arose due to water rushing downstream – there being inadequate upstream areas to absorb the excess water. 12. Piped ditches and culverts. Many of the recent problems in urban areas resulted from inadequate drainage capacity. Within rural areas the increased use of piped roadside ditches and culverts - to save Highway’s maintenance costs was cited as adding to local problems coping with the excess rainfall. Piping reduces the area of land that can receive the floodwater and directs it to the nearest stream, and so the road and nearby properties flood. 13. Debris and rubbish. Many members noted that a number of bridges, culverts and rivers with overhanging trees were blocked as a result of debris and rubbish being carried in the flood water and building up around obstructions – both in rural and urban locations. One member noted a local factory, located in a floodplain that had pallets and wagon bodies stacked up in the yard. The flood took all this material and piled it against the nearby railway bridge, blocking it and creating a massive localised flood. Suggestions for future improvements to flood management 14. Better maintenance of flood defences and water courses. Without doubt the reduction in basic maintenance and repairs to flood defences and reduced clearing of watercourses contributed significantly to the degree and extent of flooding. This needs to be addressed as the first priority. 15. Greater spending on flood & coastal defences The lack of maintenance of flood defences is largely a result of under-funding flood (and coastal defence) spending – something highlighted in the Foresight Report in 2004. At present levels the total flood spending equates to three days spend on the Health Service. In view of the enormous economic and human cost of the recent floods, this would seem wholly inadequate. 16. Less building in flood plains. Clearly development in flood plains is a significant factor in both exacerbating flooding and putting more homes/business premises at risk of flooding. Development needs to be curtailed in flood plains and that which is permitted needs to include better provision for the absorption of water (permeable surfaces, etc) and compensatory flood provisions. In addition any building in flood plains (including farm buildings) may need to consider incorporating flood resilience measures and better provision for drainage – e.g. SUDS. One suggestion is to levy a developers’ charge or bond to be used towards flood defence funding/creation of compensatory flood plains. 17. Environment Agency to concentrate on flood role The EA should concentrate on delivering water management and flood protection, reducing the emphasis on its environmental champion role. The conflicting roles of the EA in delivering both flood and environmental protection has resulted in reduced clearing water courses and has a similar adverse effect on the provision of coastal defences. Whilst generally providing adequate flood warnings in domestic situations, better provision for livestock farmers and general post-flooding advice is needed. The bureaucratic nature of the EA makes it extremely difficult to find a local contact who can help in any given situation. 18. Make better use of the Internal Drainage Boards There is a good case for strengthening the IDB responsibilities as their record of water level management, and keeping drainage channels clear, is highly regarded. It would be worth reassessing whether IDBs should be given back responsibility for maintaining Critical Ordinary Watercourses. The efficiency of IDBs seems to have prevented serious domestic flooding and their recent record in low-lying areas would seem to be a lot better than in those areas ‘protected’ by the EA. IDBs have good local knowledge which is valuable in prioritizing the necessary maintenance and improvements to flood defences. Giving the IDBs greater flood protection responsibilities, rather than burdening them with the extra ‘public accountability’ work would make a valuable contribution to flood protection. 19. Catchment based approach to flood management and use of natural washland The recent emphasis on catchment based flood management plans is a good one and needs to be extended to development proposals. During the late 1980’s/1990’s EA embarked on a series of maintenance works increasing height of the banks alongside the River Severn, only to realise this was causing even more flooding downstream. A holistic catchment approach may have forseen these problems. Landowners have a significant role to play in providing natural flood plains/washlands where water can be held rather than it rushing downstream and causing flooding to towns and villages. However, in order for this to happen there needs to be suitable recompense for the affected landowners whereby the government purchases the land for this purpose or compensates for any loss of income as a result of this land being used for the public benefit – as occurred in some places, e.g. the Lincolnshire Washlands Scheme. Historically, environmental stewardship has been proposed for this purpose, and whilst being a suitable mechanism there is insufficient in the budget to be widely used. However, proper provision for livestock evacuation needs to be incorporated in any agreement as much of this washland would be grazed during the summer months, the expectation being that only winter flooding would occur. 20. Clarity of roles & emergency planning In the light of, for example, the difficulties encountered when erecting temporary flood barriers and delivering fresh water after the floods, there needs to be greater clarity of roles between the EA, local councils and the emergency forces. Better planning with regard to protecting and restoring basic infrastructure such as electricity and water is needed. Specific points of contact are needed where, for example, livestock farmers can obtain help and advice. 21. Greater controls on rubbish near water courses Whilst retaining trees in the floodplain may have some benefits in reducing flows, it is clear that fallen trees and other debris were washed downstream to become lodged in the next bridge, causing localised flooding or damage to the bridge. River banks and the adjacent floodplain should not be used to store any materials and fallen trees should be removed from the river and the adjacent fields. 22. Insurance cover/financial support for hardship cases The recent floods have again highlighted the very real difficulties that homeowners have with regard to getting adequate insurance cover if the home is situated in a flood risk area. Insurance is even more costly and difficult to obtain for many businesses and farmers. Greater government help is needed, either in the form of supported insurance or hardship funding to help with economic losses due to flooding. September 2007