PAC: Flood resilience eroded by poorly maintained defences with Government in the dark on progress
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Number of protected properties could continue to dwindle from
current levels of at least 40% fewer than planned Committee
concerned at development continuing in areas of clear flood risk
The Government does not know if it is making the UK more resilient
to flooding. In a report published today, the Public Accounts
Committee (PAC) warns that the Department for Environment, Food and
Rural Affairs (Defra) has no overall numerical target for the UK’s
level of long-term flood...Request free
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Number of protected properties could continue to dwindle from current levels of at least 40% fewer than planned Committee concerned at development continuing in areas of clear flood risk The Government does not know if it is making the UK more resilient to flooding. In a report published today, the Public Accounts Committee (PAC) warns that the Department for Environment, Food and Rural Affairs (Defra) has no overall numerical target for the UK’s level of long-term flood resilience, and so cannot know if it is progressing in its 2020 ambition to create “a nation more resilient to future flood and coastal erosion risk”. Flood protection will be provided for at least 40% fewer properties than planned, according to Environment Agency (EA) forecasts. This is due to factors including inflation and the bureaucracy associated with approving projects. With the programme’s success relying on the completion of many large projects where the EA has only medium or low confidence of delivering by 2027, the Committee is concerned that the number of properties better protected could turn out to be even fewer than the current revised-down forecast of 200,000. In 2022-23, there were 5.7 million properties in England at risk of flooding. The Committee’s report highlights a range of concerns in Government’s support and approach to flood resilience, including:
Due to a lack of funding, the Environment Agency (EA) has not been able to meet its target of maintaining 98% of its high consequence flood defences (which protect the most properties) at their required condition. The report highlights that 203,000 properties are at increased risk due to deteriorating flood defences, more than the 200,000 separate properties the Government expects to better protect through its ongoing capital programme by 2027. These figures illustrate that poor maintenance is undermining progress from new capital expenditure and Defra’s failure to establish what the appropriate balance is between building new defences and maintaining existing ones. Sir Geoffrey Clifton-Brown MP, Deputy Chair of the Committee, said: “With the reality of climate change and increasing rainfall, robust flood resilience must of course become an ever-increasing priority. As we have recently seen once again, the depredations caused by such disasters are a matter of life and death for communities up and down the country. This inquiry has uncovered the alarming truth that in a number of ways, the approach to keeping our citizens safe in this area is contradictory and self-defeating, not least in the continuing development of new housing in areas of high flood risk without appropriate mitigations. “The number of properties at risk of flooding from deteriorating defences eclipsing those benefitting from new ones is another case in point. This is emblematic both of the Government’s failure to strike the right balance between maintenance and construction, and of not considering the net number of properties at risk. One of the first steps in delivering any successful policy is clearly defining what success looks like. We hope the recommendations in our report help the Government to do so.” PAC report conclusions and recommendations Government has no overall measure of the resilience it expects to achieve and so does not know if it is making progress towards its ambition of a nation more resilient to flooding. The government’s 2020 policy statement sets out its ambition to create “a nation more resilient to future flood and coastal erosion risk”. Both the National Infrastructure Commission and the Committee for Climate Change call for long-term targets for the level of flood resilience and flood risk the government is seeking to achieve. However, Defra does not have an overall numerical target for the level of flood resilience in the long term. Defra committed to introduce a national set of resilience indicators by spring 2022 but has not yet done so. To monitor delivery of the programme and support its expenditure on the £5.2 billion capital programme, Defra uses a set of 18 metrics. The headline metric of “properties better protected” is a simple and easy-to-understand measure of progress but does not take account factors that undermine progress. Flood defence assets in poor condition and climate change reduce overall resilience but Defra does not report the net number of properties better protected. Recommendation 1: In its next annual report (for 2023-24), the Agency should provide a more holistic assessment of net progress towards a “nation more resilient to flooding”, taking into account properties less well protected as well as those better protected. Defra should develop a measure which shows the net change in the number of properties at risk from flooding in order to give the true picture of England’s resilience to future flood and coastal erosion risk and set a target for the net change it aims to achieve. The Environment Agency is forecasting that it will provide protection for at least 40% fewer properties than planned. When the programme was launched in 2020, the government committed to provide better protection for 336,000 properties by 2027 by investing £5.2 billion in new flood defence projects. The programme got off to a slow start and the Agency has now reduced its forecast for the number of properties that will be better protected by the end of the programme to 200,000. While inflation has been a major factor, the bureaucracy associated with approving projects, particularly for the increased number of small projects, seems to be another significant factor, and this could affect the viability of schemes in smaller rural communities. Defra is yet to complete a formal reset of the programme, and the Committee is concerned that the number of properties protected could turn out to be even fewer than 200,000. The programme’s success relies on local authorities and other risk management authorities, and also on completion of many large projects where the Agency has only medium or low confidence of delivering by 2027. Recommendation 2:
Defra has not established what the appropriate balance is between building new defences and maintaining existing ones. The Agency is responsible for maintaining its existing assets and has assessed that optimal value for money is achieved when 98% of its high consequence assets are maintained at their required condition. A lack of funding means the Agency has not been able to maintain assets at this level. 203,000 properties are at increased risk because assets are below their required condition, more than the 200,000 better protected through the capital programme. Because of the slow start to the capital programme, the Agency spent £310 million less than planned in the first two years. Neither Defra nor the Agency considered whether to use some of this underspend to meet the shortfall in maintenance funding and instead agreed with HM Treasury to defer it to the remaining four years of the programme. For 2023-24, Defra has provisionally agreed with HM Treasury to transfer £25 million from the capital programme to maintenance. This is only enough to get to 94.5% of assets in target condition, still well below the Agency’s target of 98%. Recommendation 3: For the remaining years of the capital programme, the Agency should set out the value for money of different options for the balance between capital and maintenance budgets, and whether there is a case for transferring funds between the two. This should be reviewed annually. The results of the review should be reported to the Committee as soon as completed and used to inform Defra’s and HM Treasury’s funding decisions. The risks from surface water flooding are increasing, but Defra is not providing the necessary leadership and support for local authorities on how this will be addressed. Surface water flooding is a growing issue with 3.4 million properties at risk in England. In July 2021, parts of London received a month’s rainfall within a couple of hours and more than 1,500 properties were flooded as a result. An increase in non-permeable surfaces (such as paved driveways) adds to the problem and action to tackle surface water flooding is hampered by a lack of local authority resources. Under Schedule 3 to the Floods and Water Management Act 2010, any construction work that has drainage implications requires approval before it starts. But this has not yet been implemented in England. Defra expects it to be implemented by the end of 2024. Section 3 will require lead flood authorities to oversee the correct design and implementation of sustainable drainage systems (SUDS). This is important in preventing flooding and pollution from mainly new developments. Surface water flooding cannot be predicted as reliably as other types of flooding, but the Agency’s new national flood risk assessment model (NaFRA2) will improve the data on surface water flood risk. The Agency says that there are some local authorities that do excellent work on surface water flooding but there are others that do not have the expertise needed in hydrology or the resources to plan appropriately. Recommendation 4a: Defra should urgently work with DLUHC to identify the skills and resources local authorities will need to implement Schedule 3 and where there are likely to be gaps particularly relating to the proper installation of sustainable drainage systems (SUDS).
Defra does not have sufficient understanding of the impact of its capital investment decisions on geographical distribution and we are concerned that smaller communities are losing out. In response to a prior Committee recommendation, Defra undertook by July 2021 to identify areas which are likely to lack enough local authority resources and private sector contributions to manage flood risk, but Defra still has not done so. Defra is insistent that the level of investment in an area is determined by the level of flood risk, but we are concerned that some parts of the country and some location types may be losing out on funding for other reasons, for example because they are less able to secure partnership funding. Defra published guidance for government on rural proofing in 2017 (updated in 2022) to help departments to ensure that rural areas receive fair and equitable policy outcomes. The guidance states that policy makers should be considering the effect of their policy on rural areas and how it might need to be implemented differently. However, the Committee understands that the current method for prioritising projects favours the more population dense urban locations, and that there is a lack of provision for smaller communities of fewer than 100 houses that can nevertheless be devastated by the impact of flooding. Defra highlighted how it believes its £100 million Frequently Flooded Allowance would mitigate some of this, but we consider this a drop in the ocean. Recommendation 5:
We are concerned that Flood Re is not providing the protection that was envisaged and that 2039 will likely be too soon to close down the Flood Re scheme given the increasing risk from flooding and slower progress on protecting properties. The Committee has concerns over the number of high-risk households Flood Re protects. It is unclear what number of the 265,000 policies ceded to Flood Re in 2023 were from the top 2% of at risk properties nationally. Flood Re was introduced to allow enough time for properties to become more flood resilient but the Committee doubts the UK is going to be in a sufficiently strong position by 2039 for Flood Re to close. The Agency says Flood Re is working well: in 2022-23, Flood Re provided cover for some 265,000 household property policies, and more than half a million households have benefited since the scheme was launched. Prior to Flood Re being introduced, some 9% of policyholders with a prior flood claim could obtain flood insurance quotes from two or more insurers. None could get quotes from five or more. Most can now get over 10 quotes. However, increasing flood risk and slow progress on the capital programme mean Flood Re will be needed beyond 2039. Defra told us that a transition plan was in place but that it needed to be reviewed and undertook to write to the Committee with details of the transition plan and the review. Recommendation 6: Defra should write to the Committee within 12 months setting out how it is working with Flood Re to understand the implications of closing Flood Re in 2039, Defra’s role in the transition plan, and where flood risk must get to in order for this to happen. We are concerned that new housing continues to be built in areas of high flood risk without adequate mitigations. Although the Agency is a statutory consultee for planning applications, it does not have powers in the planning process to prevent any development on flood plains without mitigation. The Agency told us that 99% of new homes’ planning applications complied with the Agency advice. The problem is that the Agency only examines a proportion of planning applications to build in a flood plain due to its own lack of resources. But over half of Local Planning Authorities said they rarely or never inspected a new development to check compliance with flood risk planning conditions due primarily to a lack of resources. Despite the clear risk, the Committee believes that there is still a lot of development continuing in areas of flood risk without adequate mitigations. It is unforgivable to permit the building of houses in the flood plain without effective mitigation measures. Recommendation 7a: The Agency, working with DLUHC and local planning authorities, should develop plans, including an assessment of any additional resources needed, to strengthen its follow-up process to ensure that the Agency’s planning advice has been fully implemented.
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