CAWDLE FEN, MILDENHALL, OLD WEST, PADNAL & WATERDEN
AND WATERBEACH LEVEL
INTERNAL DRAINAGE BOARDS
NOTICE OF CONCLUSION OF AUDIT
(Audit Commission Act 1998
Accounts and Audit (Amendment) Regulations 2006)
Notice is hereby given that the audit for the year ended 31st March 2008 has been completed and the accounts are now available for inspection by local electors in accordance with Section 14 of the Audit Commission Act 1998.
The requisite information as defined by Section 12(4) of the Accounts and Audit (Amendment ) Regulations 2006 is not displayed alongside this notice.
If the requisite information is not displayed alongside this notice, it is available for inspection by appointment.
To arrange a viewing please contact Mrs. J.E. Heading, Finance Officer, Drainage Office, Main Street, Prickwillow, Ely, Cambridgeshire CB7 4UN between 9.00 a.m. and 5.00 p.m. on Mondays to Fridays (excluding public holidays).
Mrs. J.E. Heading 2nd October, 2008
Finance Officer
THE ELY GROUP OF INTERNAL DRAINAGE BOARDS
DRAINAGE OFFICE MAIN STREET PRICKWILLOW CAMBS. CB7 4UN
TEL: ELY (01353) 688296 FAX: (01353) 688561
ENGINEER: ROSS CHILVERS
Flood and Water Management Bill Team
Department for Environment, Food and Rural Affairs
Area 2C
Ergon House
London
SW1P 2AL
Our ref: RC/tlr Your ref: 21st July 2009
Dear Sirs
Re: Response to Draft Flood and Water Management Bill
Please find to follow comments highlighting our major concerns raised in the consultation on the Draft Flood and Water Management Bill.
Please also find attached our response to the Draft Bill Consultation Questions and responses to the Draft Bill Clauses.
The Ely Group of Internal Drainage Boards covers around 45,000 ha. of the South Level Fens situated largely in Cambridgeshire but extending into both Norfolk and Suffolk.
The Boards’ operations provide flood protection to over 2000 properties within the Group’s area and encompasses many “Fen island towns” such as Ely, Littleport and Soham along with smaller settlements.
Drainage Boards were established in this area of “special needs” in the 1700s and operate in a highly engineered regime of pumped discharges from the low level Fens to embanked high level rivers which discharge through tidal defences to the sea.
The area suffered from significant flooding in 1947 when people’s homes were lost along with significant disruption to agriculture in what is one of the most highly productive agricultural areas in the country. Substantial investment/engineering works have been undertaken since that time to
increase the standard of protection to the South Level. The whole system requires a high degree of maintenance and will need investment/improvement to meet the future demands of climate change.
The aim of the Floods and Water Bill is to increase the protection to people and property from flooding and better deal with the effects of climate change. The challenge will be to put in place a structure that retains the best of existing organisations such as IDBs and that any local authority given additional responsibilities, can deal with FRM responsibilities placed upon it.
The Group have a number of concerns with both the Bill and the consultation which we highlight here in addition to our detailed response to the questions in the consultation:-
- The deadline for comments on 24th July was too short a period to allow the necessary consultation and formulation of responses.
- The Floods and Water Bill is the government’s response to the recommendations in the Pitt Review. The Pitt Review did not promote such radical reforms to Internal Drainage Boards that are now being consulted upon.
- The principle of catchment management is something that has been promoted and accepted for Flood Risk Management to date. This principle is supported by the Water Framework Directive, Catchment Management Plans and by DEFRA in their guidance to IDBs. Local Authorities have been designated a lead role in local FRM to work in partnership with other authorities. River flows and run-off do not recognise county boundaries and it is essential that catchment management is continued and not compromised.
- It is necessary for IDBs to retain their supervisory role within their Districts and powers to make and apply byelaws to ensure the efficient operation of their areas. This would not conflict with any powers that local authorities may be given.
- If there were to be a change in responsibilities to make local authorities the sole body with a supervisory role in the area, care should be taken not to reduce standards of FRM/water level management in Internal Drainage Districts through the misguided approach of redirecting funding or resources elsewhere.
- There is concern that LAs do not currently have the necessary capabilities to carry out the lead role in local FRM with little expertise or funding. Greater clarity is needed on the roles and responsibilities of local authorities and partners.
- Funding is a significant issue for all involved in FRM. Funding streams currently available should continue:-
- The Environment Agency should make a general drainage charge in all areas (not just the Anglian Region).
- Internal Drainage Boards should be able to continue to charge an agricultural drainage rate to support the water level management aspect of their function that facilitates agriculture in this highly productive agricultural area, as well as providing FRM to people and properties in these areas.
- Internal Drainage Boards should be able to continue to levy District Councils for the FRM function in protecting the significant numbers of properties, industrial and commercial developments and infrastructure such as power stations/supply, water/sewage treatment plants, roads, railways and other utilities.
- Internal Drainage Boards have always accepted a Precept being charged to them for the maintenance of the High Level River System and tidal defences that protect their very existence. This demonstrates the commitment of Drainage Boards to the wider catchment management. Precept could only be abolished if funding for Main River maintenance was guaranteed/provided from other sources.
- Historically, Highland Water Contributions were a significant recognition of a long standing problem for some IDBs. It is recognised that the Agency receive Precept from IDBs and expend Highland Water Contributions. A review of this aspect of funding may be necessary but this should be part of a coherent policy to fund all aspects of FRM/water level management.
- It is assumed that local authorities, in taking certain measures, will result in a reduction of flood risk and thus produce savings to finance their lead role. This is unrealistic.
- It is proposed that local authorities in their lead role will produce a strategy for FRM for their area. It is important that all partners’ needs are considered and recognised in the formulation of such strategies and that there is wide consultation to produce common agreed objectives for delivery of FRM within each area and that these plans recognise catchment management.
- Burnt Fen IDB is situated partly in Cambridgeshire, Norfolk and Suffolk. It lies totally within the South Level Catchment. Very close co-operation will be required by the three local authorities (not to include District Councils such as East Cambs. District Council in Cambridgeshire, Kings Lynn and West Norfolk Borough Council in Norfolk and Forest Heath District Council in Suffolk) if effective FRM/water level management is to be maintained within this District. Each local authority will need to have similar “strategies” for dealing with this area.
There is a risk assessment that accompanies the consultation papers. This risk assessment makes a number of criticisms of Internal Drainage Boards.
- The objectives of IDBs are too narrow focussing relatively on drainage of agricultural land and too little on the broader requirements of FRM.
Internal Drainage Boards facilitate agriculture in highly productive areas such as ours. IDBs charge an agricultural rate for the service provided. The agricultural rate along with special levy contributions finances a highly maintained/engineered system that provides FRM to significant numbers of households, industrial and commercial developments along with significant infrastructure. IDBs in our area play a significant role in the planning process providing solutions in facilitating development and adopting works to ensure future maintenance.
The Cawdle Fen Internal Drainage District encompasses the lower areas of the City of Ely containing significant commercial and industrial developments. Virtually the whole of the Board’s function is directed at FRM in protecting and facilitating these developments. IDBs adapt their function to the requirements of land use.
- IDBs focus too little on the natural environment.
Whilst this may have been a criticism in the past many IDBs, to include our Group, accept their role in enhancement of conservation and biodiversity through their operations. It should be noted that we have significant new environmental projects within our area which can only be created through the FRM and water level management provided by IDBs.
- Inefficiencies largely relating to the number and size of IDBs.
- The aim of empowering the Secretary of State to restructure IDBs is to reduce inefficiencies.
We consider IDBs in our Group to be some of the most efficient, cost effective providers of FRM/water level management, performing to a very high standard. IDBs have made significant cost and efficiency savings in forming groups and consortia. Clarification of powers to form the same should be confirmed in the Bill.
Future amalgamations are likely within IDBs within our Group and these will evolve without the need for direction from others. Amalgamations should be based on local consultation and need.
IDBs within our Group promote the setting of targets and performance measures for IDBs to provide the solutions in meeting the same. This is opposed to the Secretary of State dictating solutions (amalgamation) which have no guarantee of the delivery of service required.
The Board wish to record that they support the comments of the Association of Drainage Authorities in addition to this response.
Yours faithfully,
R Chilvers
Engineer