Written evidence submitted by Witham and Humber Drainage Boards (FLO0007) Summary and objective Recent events have brought the challenges of managing flood risk back to national attention, and climate change means these events are likely to become more frequent. Building on the previous Committee’s interim report on coastal flooding and adaptation to climate change, this inquiry would focus on the Government’s approach to managing the risk of inland flooding in England. The inquiry will also consider evidence received and questions raised during the coastal flooding inquiry. Terms of reference 1. Are the current national and local governance and co-ordination arrangements for flood and coastal risk management in England effective? 2. What lessons can be learned from the recent floods about the way Government and local authorities respond to flooding events? 3. Given the challenge posed by climate change, what should be the Government’s aims and priorities in national flood risk policy, and what level of investment will be required in future in order to achieve this? 4. How can communities most effectively be involved, and supported, in the policies and decisions that affect them? 5. With increasing focus on natural flood management measures, how should future agricultural and environmental policies be focussed and integrated with the Government’s wider approach to flood risk? 6. How can housing and other development be made more resilient to flooding, and what role can be played by measures such as insurance, sustainable drainage and planning policy? House of Commons EFRA Committee Floods Inquiry Terms of reference – Consultation Response to Questions 1-6. 1. Are the current national and local governance and co-ordination arrangements for flood and coastal risk management in England effective? This response is submitted on behalf of the 4 Internal Drainage Boards which work in a voluntary partnership under S11 of the Flood & Water Management Act [2010] collectively known as ‘Witham & Humber Drainage Boards’, but retaining their independent status as 4 separate and local Land Drainage, Water Levels and Flood Risk Management Authorities [i.e. North East Lindsey IDB, Upper Witham IDB, Witham First District IDB and Witham Third District IDB]. The 4 IDBs are 4 of 112 IDBs nationally. Structurally, since the Pitt Review [2007] following extensive heavy rainfall events and flooding, there has been considerable clarification and improvement nationally and locally in governance responsibilities for water and flood risk management in what may appear to the public as a ‘crowded land scape’. The Flood & Water Management Act [2010] assisted with this and the introduction nationally of Lead Local Flood Authorities [LLFAs] and the requirement for the LLFAs to produce a JOINT Strategic Plan supports a coordinated and joint approach to water levels and flood risk management [indeed to the management of water from all sources – be that tidal inundation, fluvial, surface water or ground water]. In Lincolnshire for 3 of the 4 IDBs here this means the LLFA responsibility sits with Lincolnshire County Council and the second iteration of a Joint Strategy was approved in February 2020, having been developed in a collegiate way using the well-established partnership architecture of the Lincolnshire Flood Risk Management & Drainage Partnership [which includes representation from, for example, the Upper Tier Authority in 1 Lincolnshire County Council, the 7 District Councils, the Environment Agency, relevant Water Company representation like Anglian Water Services, Local Resilience Forum input for emergency planning, voluntary sector input via the Canal & Rivers Trust etc]. For our North East Lindsey IDB, the Board relates to two Unitary Authorities, namely North Lincolnshire Council and North East Lincolnshire Council. The Board is a full member of North Lincolnshire Council’s Flood Risk Management Board. Under the leadership of the Environment Agency, the IDBs are linked into the Anglian [Northern] RFCC structure which is the IDB mechanism for accessing Grant in Aid funding for significant capital schemes. It is helpful that local scheme sign-off thresholds have been raised to £250,000 but undoubtedly for small-scale public bodies like IDBs, the current Partnership Funding calculator mechanism is complex and bureaucratic for accessing minor improvement schemes at catchment scale, which is where IDB schemes are focused. Many of the circa 60 Pumping Stations in the 4 Boards’ drainage districts protect prime agricultural land, indeed these were schemes developed post-WW2 in recognition of the need to meet increased food production targets. Whilst the IDBs maintain these Pumping Stations and other flood defense structures, some are now reaching the end of their life-cycle and the current funding mechanism which awards points and grant in aid monies largely in line with number of properties better flood protected does very little to recognise the value of prime agricultural land and its economic value to achieve food production targets. Unless the scope of this funding formula is broadened there is a very real risk that existing and ageing flood defense assets will not be adequately maintained in the medium term. In short, whilst IDBs understand the investment in flood protection via RFCCs and the emphasis on better protecting homes, there is a need for increased investment to wider criteria including protection of agricultural land and agri-business. We would also highlight the differences in national policy approach between the UK and, say, the Netherlands. Listening to the Delta Commissioner present in February 2020 there is more emphasis on flood prevention in the Netherlands’ national policy than in the UK, where we appear to be more reactive to flood events [which is evidently not a cost effective way of managing flood risk] and also now placing policy emphasis on flood resilience rather than prevention.. There also appears to be longer-term planning in the Netherlands, with a 14-year Delta Plan, which provides better planning and investment certainty. The Delta Commissioner is obliged to account annually for progress on implementation of the Plan and Report to Parliament, which arguably keeps national focus upon and accountability for Flood Risk Management. A similar focus should be considered for the UK. There are also publicly published ‘Standards of Protection’ in the Netherlands, reviewed every 6 years. The UK should consider committing to defined national standards of flood protection and investing in such which we suspect would bring comfort to may communities adversely affected by Autumn 2019 and early 2020 flood events. Turning to our local flood risk management and the adequacy or otherwise of this: On balance yes, these arrangements are adequate within the national constraints just outlined. The reason for this is based on the availability of technically competent and experienced officers as well as the strength of the local voluntary partnership arrangements for flood risk management in Lincolnshire. The 4 IDBs do not see justification for an additional administrative tier or governance at a RFCC level with the creation of, say, a Lincolnshire Rivers Authority akin to the separate precepting body established in Somerset as the Somerset Rivers Authority [which may suit the partnership architecture in Somerset]. The bodies already involved like the RFCC, LLFA, EA, DCs, Water Companies, IDBs etc contain enough local representation with the presence of appointed members supported by technical officers form the FRMAs. Adding 2 another layer of governance or administration will only spread resource more thinly, increase bureaucracy and potentially increase administrative costs. With respect to the local response to a high rainfall or tidal event: At times yes, the arrangements for emergency response and then recovery are adequate. This is especially so when the various criteria/thresholds are met and local Emergency Planning LRF architecture invokes TCG/SCG. This system works well for the organisations involved. Indeed, for the type of rainfall or tidal inundation event incident being managed it can provide a clear line of responsibility and accountability. In the heat of an event, it is important that stakeholder expectations are reasonable and informed, based on evidence. In Lincolnshire, North Lincolnshire and North East Lincolnshire, IDBs are involved in the response phase and management of a high rainfall event, tidal/coastal event, and where appropriate, pollution incidents. This is a good thing and should be encouraged as the Boards provide a sizeable portion of the operational and management of land drainage and flood risk management within the County of Greater Lincolnshire, outside of the main river system maintained by the Environment Agency, and in such events very local knowledge is imperative. However, the effectiveness of the incident response system is diminished by several local factors: i) During times of LRF event activation, the TCG is resource hungry, with little flexibility for involvement. If you sign-up as an organisation [or group of organisations as are the IDBs, honorary cat 2 responders] you are expected to comply with all the systems requirements and procedures. During flood events this is very difficult for small public bodies such as IDBs as their very limited resources are required to ensure the Boards’ core functions are maintained. Therefore, the Lincolnshire Boards operate a system of mutual aid and