Defra has just commissioned a review of the current framework for flood risk governance in England and Wales. Here’s my take on the current state of play, starting with a little retrospective glance.
Flood risk governance in England and Wales has been the subject of a number of previous analyses. The Pitt Review[1] highlighted that, at the time of the summer 2007 floods, well-established arrangements already existed for the Environment Agency to manage flood risk from rivers and the sea, but there were no mechanisms in place to enable an integrated approach to planning and managing the impact of local sources of flood risk. The Flood and Water Management Act 2010 implemented recommendations from the review to address this issue, principally through the designation of upper-tier local authorities as the Lead Local Flood Authority (LLFA) for their area.
Since the 2010 Act, significant improvements in flood risk governance have been recognised. Alexander et al (2016)[2] referred to the system as having become ‘highly stable and there has been a general formalisation of flood risk governance arrangements and increasing professionalism in flood risk management’. CAG’s national evaluation of the arrangements for managing local flood risk[3] found that implementation of the provisions of the 2010 Act had contributed to ‘a more comprehensive understanding of local flood risk and a more proactive and coordinated management of this risk’. It also found that the Act had ‘led to significant progression in the levels of partnership working’ between some Risk Management Authorities.
CAG’s more recent review, focused on surface water flood risk management[4], suggested that some of this progression had continued. It found that there had been ‘significant steps forward in the management of surface water in recent years, underpinned by closer and more effective partnership working between Risk Management Authorities and others’.
Previous analyses have also identified significant weaknesses in flood risk governance. Much of these relate to two key, related aspects of the current arrangements:
- The complexity and fragmentation of the arrangements.
- The misalignment of responsibilities with the resource and/or incentive to fulfil those responsibilities.
Complexity and fragmentation
A common theme in previous analyses relates to the number of organisations with flood risk management responsibilities and the complexity of the relationships between them. The Environment, Food and Rural Affairs Committee (2016)[5], for example, referred to ‘a proliferation of flood risk management bodies’. CAG’s surface water management review contrasted the integrated nature of the drainage network with the fragmented nature of the governance of that network.
Complexity is not, in and of itself, a weakness and both Alexander et al (2016) and Hegger et al (2013)[6] acknowledged the benefits of the diversity of interventions which this complex system helps to facilitate. Nevertheless, Hegger et al suggested that the complexity of arrangements was leading to high transaction costs and highlighted the risk that ‘diversification of Flood & Coastal Erosion Risk Management strategies may lead to fragmentation between actors, levels and sectors, causing inefficiencies and ineffectiveness and possibly undermining societal resilience’.
The fragmentation of responsibilities can only be overcome through effective partnership working and whilst, as already noted, significant improvements in partnership working have been identified, challenges remain. The national evaluation of the arrangements for managing local flood risk found that ‘differing, objectives, priorities and regulatory environments’ undermined progress. Tensions between partners over the responsibility for assets or required interventions were also found to be a contributory factor.
Geographical challenges are also apparent. Whilst larger-scale, integrated catchment management approaches have emerged, such approaches have to overcome the significant challenges presented by the fact that organisational responsibilities rarely align with catchments. Effective partnership working at the catchment level therefore requires significant efforts across both organisational and geographic boundaries.
Misalignment of responsibilities with resources and incentives
Whilst the roles and responsibilities in flood risk management have become better understood, these responsibilities are not always accompanied by the resource and/or incentive to fulfil them.
Numerous resourcing issues have been highlighted in previous analyses. The national evaluation highlighted particular concerns about funding and capacity for LLFA governance, whilst the more recent review of surface water flood risk arrangements highlighted the impacts of wider local authority resourcing issues on flood risk management. As already noted, the costs of flood risk governance for all parties are heightened by the fragmentation of the system, although Alexander et al (2016) did identify that this had been countered to some degree through institutional restructuring and increased cooperation.
Resourcing the delivery of interventions is a further challenge. Whilst partnership funding has the potential to lessen the public sector burden, significant further work is needed to enhance private sector contributions.
The misalignment of responsibilities to act with the incentive to do so may be an even greater challenge. The challenge was articulated in our surface water management review. It found that, whilst the 2010 Act might have lead responsibility for ensuring surface water flood risk is managed, many of the ‘tools’ for taking action to address that risk lie with other agencies: with the EA through providing Flood Defence Grant in Aid (FDGiA); with Water and Sewage Companies through improvements to their network and through their funding for schemes; with Local Planning Authorities through their setting and discharging of planning conditions; and with Local Highways Authorities through their highways maintenance activities. However, whilst these agencies may have the most scope to influence the management of surface water at its source they are not necessarily those who are most impacted by it and are therefore not always incentivised to do so.
The complex and inter-connected nature of the drainage network mean that the actions of one actor in the system may have implications for a range of other actors. Individual actors are often reliant on the action of others in order to deliver their responsibilities or achieve their aims but those ‘others’ may not always be resourced or incentivised to recognise this and respond accordingly.
Importance of the current review
Defra’s newly-commissioned review responds directly to this context. Given the complexity and fragmentation described, there is a need to examine and clearly understand the current framework for flood risk governance. The roles and responsibilities of all actors, the relationship between them and the effectiveness of their contribution to flood risk management needs to be better understood so that opportunities for strengthening governance arrangements can be identified.
Flood risk management is a dynamic field which is increasingly broad in scope, as illustrated by the increasing focus on integrated catchment management, natural flood management, property-level resilience, economic growth, spatial planning and community-led initiatives. The outcomes of the research will help to inform the development of the governance approaches which can best support these approaches and support the development and implementation of Defra’s 25 Year Environment Plan and the updating of the Flood & Coastal Erosion Risk Management (FCERM) strategies for England and Wales.
Given the rising threat posed by flooding and the increasing strain on the resource to manage this threat, this review is both important and urgent.
[1] Pitt, M. (2008) The Pitt Review – Learning lessons from the 2007 floods.
[2] Alexander, M., Priest, S., Micou, A.P., Tapsell, S., Green, C., Parker, D., and Homewood, S. (2016) Analysing and evaluating flood risk governance in England – Enhancing societal resilience through comprehensive and aligned flood risk governance. STAR-FLOOD Consortium. Flood Hazard Research Centre, Middlesex University.
[3] Maiden, T., Anderson, M., Kirkup, B., Fawcett, J., Wilson, N. (2015) Evaluation of the arrangements for managing local flood risk in England. Defra.
[4] Maiden, T., Jones, E., Wilson, N. (2018) Review of local approaches to surface water flood risk management. Defra.
[5] Environment, Food and Rural Affairs Committee (2016) Future flood prevention. Second Report of Session
[6] Hegger, D.L.T, Green, C, Driessen, P, Bakker, M, Dieperink, C, Crabbé, A, Deketelaere, K, Delvaux, B, Suykens, C, Beyers, J.C, Fournier, M, Larrue, C, Manson, C, Van Doorn-Hoekveld, W, Van Rijswick, M, Kundzewicz, Z.W & Goytia Casermeiro, S, (2013) Flood Risk Management in Europe: Similarities and Differences between the STAR-FLOOD consortium countries, STAR-FLOOD Consortium, Utrecht, The Netherlands.
