By Vicky Boorman, LGTAG FCERM Board Vice Chair
Local authorities need policy change across government to share funding between fluvial and surface-water projects. The latter needs consistent standards across all providers of sustainable drainage system (SuDS) design, strengthen collaboration and support national drainage training and adequate funding to encourage and recruit much-needed staff.
Surface water is the UK’s biggest flood risk. Of 5.2 million people affected by flooding, at least 3.2 million face surface-water flooding. The UK risks deaths, damage and disruption similar to those in Belgium and Germany during last summer’s devastating storms.
Summer storms in 2007 prompted Sir Michael Pitt to reassess England’s flood-risk management. His recommendations underpin the Flood and Water Management Act 2010. This introduced Lead Local Flood Authorities (LLFAs) to manage local flood risk from surface water, groundwater and ordinary watercourses, including asset registers and consenting.
We have seen progress since the Pitt Review – but not enough in surface-water management. SuDS can tackle surface-water flood risk, reducing river pollution from stormwater overflows and providing green infrastructure to adapt to climate change.
Generally, LLFAs have embraced responsibilities dating back to 2014, requiring all major applications to include SuDS, for which local planning authorities must consult LLFAs. On average, says the Association of SuDS Authorities (ASA), each LLFA comments on 1,000 applications a year – and more than 150,000 nationwide. In 2021, an HR Wallingfordconsortium reviewed Defra’s Non-Statutory Technical Standards for SuDS (NSTS). It found many urban SuDS schemes met the standards which are for quantity, holding water below ground in tanks.
For one major Hillingdon planning application, the LLFA required the developer to keep an Olympic-sized swimming pools’ worth of water out of sewers – and eventually the watercourse – every 30 minutes of a storm. Building SuDS into developments, managing rainfall as a greenfield site would, is much more cost-effective than retrofitting.
SuDS could deliver quality and quantity though the planning system, supporting government aspirations for biodiversity net gain and amenity, creating better places for people and nature – the four pillars of SuDS – by making Defra’s technical SuDS standards statutory and adopting last year’s recommended updates. This would improve consistency, making life easier for developers and helping the UK to adapt to more frequent short, sharp rainstorms that come with climate change. Tighter standards will require SuDS to provide benefits beyond managing flood risk and diffuse pollution, to support leisure and nature. Future planning reforms must enable SuDS to go mainstream, complement the much-needed Schedule 3 removal of new developments’ so-called right to connect to sewers and secure funding to inspect and maintain SuDS.
There’s a clear divide between places where LLFAs’ experienced, passionate champions introduce good local policies and encourage developers to deliver best practice and those that lack expertise. It’s why we must fund experienced advisors, nationwide.
Why it matters
The IPCC’s sixth report, confirms why we must act now. It attributes last summer’s flooding across Europe to climate change increasing rainfall intensity by 3-19 per cent. This hits urban areas, with their dense populations, and Victorian infrastructure, hardest.
Following last July’s London floods, mayor Sadiq Khan convened a roundtable on managing future risk. London Councils and the Environment Agency set up a Surface Water Task and Finish Group with Thames Water, London Drainage Engineers Group (LoDEG), TfL, GLA, CIWEM and London Resilience Partnership. It reported in February to London Councils’ Transport and Environment Committee (TEC). It said the capital lacks a strategic plan and a lead organisation to address surface-water flood risk.
Few Londoners are aware of flood risk – how to reduce it; how to prepare and be more resilient, as the National Flood Coastal Risk Management Strategy notes. The UK generally needs better evidence and understanding about the risks that face vulnerable people – especially families living in basements. Society’s most vulnerable are also at most risk of flooding. But we need funding and resources to demonstrate this.
Government is increasing spend on flood risk, from £3.6 billion in the previous six-year cycle, to £5.2 billion for 2021-2027. It doesn’t mean more money for surface-water management schemes. LLFA-led schemes secured a fifth of regional flood and coastal programme funding in 2015-2021. Funding small, dispersed SuDS is difficult to justify and align to funding streams. Although the London Strategic SuDS pilot shows how to overcome barriers, this demands more streamlined and transparent funding. The National Audit Office (NAO) report on managing flood risk says: “Defra does not assess whether funding to local authorities is adequate to cover the level of flood risk individual authorities face.” Funding for LLFAs is not ringfenced, may not cover a staff post and can stretch across responsibilities and disciplines. Last year’s Environment Flood and Rural Affairs public accounts committee flooding inquiry called for dedicated resources to help local authorities to manage flood risk effectively, to monitor their needs “to avoid future shortfalls”.
Despite progress in flood-risk management, the Environment Agency’s FCERM strategy action plan for 2021 fails to acknowledge or address gaps between fluvial and surface-water management. It states that its measures reaffirm existing activities, recognise existing and new statutory requirements or voluntary funded actions and are cost neutral. We must readdress the balance, securing better data on surface-water assets. The National Audit Office report on managing flood risk reports that the Environment Agency maintains 71 per cent of England’s flood defences by length – this does not include surface-water assets.
A survey by LoDEG found that fewer than half the London boroughs produced flood-asset registers in 2022, partly as these have limited value if managers of surface-water assets are not obliged to gather and present that data accessibly. Drainage and waste-water management plans (DWMPs) driven by water and sewage companies are a move in the right direction. But plans being written now are for Amp 8, the 2025 asset-management period. These are not yet the joint plans envisaged, they focus on managing risk from foul flooding, and they haven’t helped improved understanding of surface-water assets or modelling of surface-water flood risk. That means little changes for areas most at risk from surface-water flood risk until Amp 9 in 2030.
Thames Water created a £1.5 million surface-water management programme fund under Amp 7. It aims, in DWMP Amp 8, to spend £300 million on SuDS to alleviate foul issues. But it relies on its LLFA to deliver. Resources for SuDS are already stretched. DEFRA has recently changed Ofwat’s priorities, to focus more on nature-based solutions SuDS and reducing pollution from storm overflows. LLFAs hope the regulator will press utilities to address surface-water risk and help them to develop the resources they need to deliver these plans. LLFAs have demonstrated the growing pressure they face to deliver, stretching their expertise across town planning, emergency planning, asset management, highways and other infrastructure and project management. LLFAs cannot manage these diverse demands and pressures without additional funding, resources, training and capacity-building. These need to be consistent across England, to manage local flood risk to a level that leaves communities secure, resilient and empowered.
In November 2021, the government asked the National Infrastructure Commission to assess how England’s responsible bodies can better manage and mitigate surface-water flooding. This should be complete by November. Defra should then review LLFA funding. But with climate impacts hitting us now, the Titanic is bearing down on the iceberg – are we moving quickly enough to avoid it?
LLFAs can do so much more to mitigate and adapt to climate change to support resilient communities. But only with the funding to better manage surface water, with recruitment and training programmes that develop surface-water management resources – and with supporting legislation and policy changes to deliver this.
Vicky Boorman is a specialist in flood and water management for London Borough of Hillingdon
This article also appears in the June edition of “Environment” magazine and the LGTAG website.