Executive
Report of decisions taken under
urgency procedure
Report by:
Derek Gadd
Date:
28 April 2008
Contact
Officer:
Derek Gadd
Telephone:
020 7934 9505
Summary
Job title:
Head of Governance
Email:
[email protected]
London Councils’ urgency procedure was used to secure a decision
on:

Recommendations
Item no: 10
The Pitt Review Interim Report: Learning Lessons
from the 2007 Floods
The Executive is recommended to note the decision taken under
the urgency procedure.
INTRODUCTION
1. The urgency procedure was used to secure agreement on the following item:
 The Pitt Review Interim Report: Learning Lessons from the 2007 Floods
2. Until the Regional Pitt Review Conference hosted by the Government Office for
London on 14 March 2008, the focus of London Councils’ engagement with the
Review was through the London Regional Resilience Forum (LRRF). However, the
conference raised the wider scope of the Review suggesting a need for a London
Councils submission in addition to any submissions made by the LRRF.
3. The date for the close of the consultation was 31 March. However, an extension
was granted to London Councils to submit a response by 14 April 2008. A
response was drawn up and sent to Elected Officers on 3 April 2008.
4. After amendment by the Elected Officers, the response attached at Appendix 1
was agreed.
Financial Implications for London Councils
There are no financial implications arising from this report. Financial implications of each
urgency report are contained within those reports.
Legal Implications for London Councils
There are no legal implications arising from this report. Legal implications of each
urgency report are contained within those reports.
Equalities Implications for London Councils
There are no legal implications arising from this report. Legal implications of each
urgency report are contained within those reports.
Appendices
Appendix 1: London Councils’ response to 2008/09 to 2010/11 Provisional Local
Government Finance Settlements.
Appendix 1
LONDON COUNCILS
02 APRIL 2008
London Councils represents all 32 London boroughs, the City of London, the Metropolitan
Police Authority and the London Fire and Emergency Planning Authority. London Councils
fights for more resources for London and for a fair deal for London’s 33 councils.
The following submission sets out our general observations and some of our specific
comments on the Interim Report, its Urgent Recommendations and the Interim
Conclusions. Thirty-four of the Review’s 92 Interim Conclusions are directed at local
authorities, underlining the crucial role that local authorities have in emergency planning,
communications, response and recovery as well as in regulation and enforcement relevant
to the management of flood risk.
London Councils welcomes this opportunity to contribute directly to this important Review.
Representation from London Councils on the Interim Report of the Pitt Review
Learning Lessons from the 2007 Floods
GENERAL OBSERVATIONS
1. London Councils welcomes the Interim Report and acknowledges the significant
effort that has gone into this work given the short timescale for reporting. The
effect of the July 2007 floods on London was less devastating when compared to
other parts of England. However, many London Boroughs were significantly
affected by surface water flooding on 20 July 2007 and the subsequent backflow,
with as many as 1,500 properties affected in the two London boroughs alone1 518
properties, 24 schools and parts of several hospitals flooded, despite London
receiving less than half the rainfall of other areas of the UK. Many roads were
forced to close, and much of the London Underground suffered severe delays,
highlighting the economic and social impact of the floods on the capital.
2. In London the effects of flooding are more intense due to the combined foul and
surface water drainage system which creates particular problems when the system
surcharges. This is not the case in the rest of the country. Some of the older
pumps are not automatic such as in the case of Lots Road, and operators were
delayed in reaching them by traffic disruption caused by the flooding. This meant
further surcharging into residential properties before the pumps could be turned
on.
3. London’s emergency response agencies were placed under considerable pressure
dealing with local response and recovery and providing capacity to other regions to
1
Royal Borough of Kensington and Chelsea and the London Borough of Hammersmith and Fulham
assist with the response and recovery effort. Impacts in the London region were
mainly due to inability of the surface water drainage infrastructure to cope with the
exceptional volume of surface water runoff. Apart from impacts on the transport
network, London’s critical infrastructure was largely unaffected. However, we
recognise that future occurrences may not prove so providential.
4. London Councils is pleased to see that Government has accepted all the Urgent
Recommendations in the Interim Report. We believe that this underlines
Government’s understanding of the seriousness of this issue. We fully expect that
any new burdens on local authorities will be adequately funded to ensure full
implementation and will welcome reiteration of this principle in the Review’s final
report.
5. The Review’s ICs are not specific enough at this stage and are largely presented
as uncosted aspirations. The Interim Report acknowledges the need to firm up the
current list of conclusions. Many of the ICs, in particular those placing extra
burdens on local authorities are likely to carry considerable financial implications.
These conclusions will need more work before they can be reflected as useful
recommendations in the final report. Many of the conclusions need to be more
clearly focussed in terms what needs to be done and which organisation will be
responsible. Conclusions also need to be supported by robust cost/benefit
analyses and a considered assessment of the regulatory impacts.
6. References to involvement of local government bodies in delivery of the changes
required invariably focus on the Local Government Association (LGA) (e.g. IC42 &
84) without recognition of the role of regional representative organisations such as
London Councils, particularly in coordinating regional response and recovery.
7. London’s emergency response arrangements are different from arrangements
elsewhere in England because of the unique structure of governance in London.
Some of the ICs such as on the ‘Local Emergency Response (IC38- 41, 44 & 58)
and on the ‘Transition to Recovery and Normalisation’ (IC51, 90-92) reflect
arrangements already in place in London through the LRRF. It would be helpful for
the final report to take account of this and in some cases refer to current
arrangements in London where these represent exemplars of good practice.
8. Some ICs also refer to local authority scrutiny committees (IC26 & 60) without a
clear definition of what these committees are or should be. Whilst the Interim
Report makes some good points about the role that such ad-hoc scrutiny
committees can play, London Councils is keen that local management and review
of the effectiveness of response and recovery proceeds through existing
multiagency bodies and could more appropriately be a role for Local Strategic
Partnerships or existing joint committees of London authorities.
9. The Review is aware of ‘Drain London’, a multiagency project bringing together
representatives from organisations with the information and/or responsibility for
managing surface water drainage in London. Drain London has representation
from Greater London Authority, London Boroughs, London Councils, Defra,
Environment Agency, Government Office for London, London Development
Agency, Thames Water and Transport for London. Its aim is to better understand
the relative risk of surface water flooding to London and to develop a strategic level
surface water management plan for London. Drain London will provide a London
response to the Review’s Urgent Recommendation (UR) 2 and London Councils is
fully signed up to ensuring this project is successfully delivered.
COMMENTS ON SPECIFIC INTERIM CONCLUSIONS (ICs)
10. A number of the ICs are directed at local authorities. The following comments
consider some of these ICs in groupings reflecting areas of interest as set out by
the Review:
Climate Change
11. IC1 and IC2 present specific conclusions relating to climate change adaptation and
mitigation. However, these conclusions are rather woolly and as previously
indicated, need to be more specific about the measures required.
12. The interim report has recognised that the intense floods cannot be attributed
entirely to climate change. Further work such as the Hydrological Appraisal carried
out by the Centre for Ecology and Hydrology (CEH) and the British Geological
Survey (BGS)2 have supported this view. However, the impacts are an indication
of what can be expected as a result of extreme weather effects due to climate
change. Adaptation to climate change is about managing uncertainty as it is not
clear how severe the impacts, such as from increased flood risk will be. It would
be helpful for the final report to be clearer in drawing attention to climate change as
a thread that runs through many of the other ‘areas of interest’. Indeed, many of
the ICs such as the proposed building control and planning measures as well as
advice on flood resistance and resilience are clearly adaptation measures. This
point should be made at every opportunity.
Surface Water Flooding and Drainage
13. IC9 suggests the removal of the right of householders to lay impermeable surfaces
whilst IC10 suggests the removal of the automatic right to connect drainage for
new developments to the sewerage system. Whilst these conclusions are
welcome, the implications of requiring regulatory checks should be considered.
London Councils would like to see a regime that required developers to proactively
provide an assessment of the ability of the existing drainage system to cope with
the additional load before new, non-compliant surfaces are laid or before new
connections are made.
14. IC17-26 would seek to place a range of obligations on local authorities. Planning
Policy Statement (PPS) 25 requires local authorities to produce strategic flood risk
assessments (SFRAs) taking a strategic approach to flood risk at all stages of the
planning process. London Councils share the view that local authorities should
lead on coordination of key activities in their locality. However, information on and
responsibility for surface water drainage in a local authority area is the
responsibility of a variety of organisations including all those listed in IC17. The
extent and/or limitations of these various responsibilities have been unclear for
some time and have contributed to the current state of affairs. Further, the loss of
Marsh, T. J. and Hannaford, J. (2007) The summer 2007 floods in England and Wales – a hydrological appraisal. Centre for Ecology &
Hydrology. 32pp. ISBN: 978-0-9557672-4-1
2
control by local authorities over local drainage infrastructure has led to a loss of
expertise in drainage within local government. Drainage engineers in local
government are now a dying breed. Environmental Health Officers who were once
involved in inspecting and enforcing maintenance requirements on householders
have seen this area of their work de-prioritised over a number of years. Any
recommendation that assumes local authorities are in a position to take on these
roles effectively in the short to medium term is doomed to failure. The final report
must put forward recommendations that are workable in the short term, taking
account of where the limited available expertise currently lies (i.e. with consultants
to Sewerage Undertakers) and set out the case for rebuilding capacity by reskilling of local authority engineers and public health officials to enable them take
on the roles envisaged by these interim conclusions.
Local Emergency Response
15. On IC30, London Councils welcomes the Review’s call for the development of a
single national set of guidance on the use of sandbags and other alternatives. We
however also agree with the Review’s findings that deploying sandbags in flood
situations can be ineffective and inefficient compared with other self resilience and
resistance measures. London Councils urges the Review to promote, more
vigorously, the installation and use of alternatives such as floodgates and airbrick
covers which are more useful in surface water flooding incidents.
16. With regards to IC42, London Councils would like the Review to consider the role
of regional local government representative bodies and how they could work within
a national arrangement in dealing with wide-area emergencies. Regional bodies
can coordinate sub-regional arrangements where this is the appropriate scale of
mutual aid required.
Public Awareness before Emergencies
17. IC72 calls on Government to make public information and advice on flood
prevention and mitigation to householder and businesses clearer. London
Councils agrees and would like to see less technical jargon in such
communications. The likelihood of flooding currently expressed as a ratio (e.g.
1:100) is largely meaningless to people and should be replaced with expressions
that people understand and that fit with their experiences. It might be useful, for
example to talk about the level and intensity that might cause flooding, but be clear
that these expressions are dependent on a host of other factors such as ground
conditions. The risk of flooding should be clear to people.
Funding
18. IC86 suggests that local authorities should revisit their reserves and insurance
arrangements in the light of the floods. Local authority performance and resilience
in terms of reserves and levels of insurance is variably for reasons of management
competence and history. If the Review’s Final Report calls for a review of reserves
and insurance arrangements, it should give a clear indication of what it considers
to be an acceptable level of reserves to be held.
19. London Councils agrees with IC50 in calling for improved speed, simplicity, and
(most importantly) certainty in Government’s provision of financial assistance to
local responders in relation to both response and recovery. Government
messages that the CLG Flood Recovery Grant and the Department for Children,
Schools and families’ (DCSF) grant should not be seen as precedents were
unhelpful. London Councils considers that in response to these types of incidents,
urgent commitment by Government to recovery funding is crucial. Recovery
funding should in fact be seen as long term, potentially bridging financial years.
London Councils would like to see strong recommendations along these lines.
Contact:
Michael Ojo
Head of Environment
London Councils
59½ Southwark Street, SE1 0AL
Tel: 020 7934 9945
Fax: 020 7934 9946
Email: [email protected]
Website: www.londoncouncils.gov.uk