The Chartered Institution of Water and Environmental Management (CIWEM) is an independent professional body representing managers, and other professionals, who are responsible for the stewardship of this country's environmental assets. CIWEM's agreed purpose is to develop and promote improved and integrated management of the environment; to foster a better understanding of water and environmental issues and to enhance the quality of people's lives. This is achieved through CIWEM's Royal Charter; education training and development; dissemination of information; conferences and events; research and publications; contact with Government, agencies and other bodies; partnerships with other organisations, and the publication of Policy Position Statements (PPS).

  CIWEM welcomes the opportunity to comment on the Environment Sub-committee's Inquiry into the work of the Environment Agency.

  CIWEM believes that there is a need for an effective and powerful environmental regulatory body in England and Wales. It is essential that such a body have the powers to regulate effectively and to command respect from those who interact with the environment.

  Whilst there are many on-going challenges, CIWEM believes that the Environment Agency has become, in a short period of time, an effective environmental regulator. It is a leader in many fields of expertise and has displayed excellence in developing practices such as public consultation, integrated management and advocacy.

  The Environment Agency has, in its current form, a broad remit and a wide range of statutory functions. CIWEM believes that this is desirable for a national environmental regulator. However, the Institution believes that the Sub-committee's review of the work of the Agency offers an important opportunity to examine the scope and remit of the Environment Agency, and to consider whether its operation might be optimised by some revision of the Agency's functions in the long term. A national strategic overview is crucial in dealing with the many environmental problems which exist.

  The Institution believes that the Agency has, since its creation, overseen significant improvements in the health and quality of the environment and the communities it serves. However, there are areas where environmental protection work could be developed and enhanced, especially through training and awareness programmes.

  Certain expert Panels of the Institution (whose membership includes respected practitioners in environmental management) have expressed concerns about some aspects of the Agency's operation and remit. In putting forward these diverse views to the Sub-committee, CIWEM does not claim to represent all or any of these views, but merely to raise awareness of them. The Institution believes that such views should be made available to the Sub-committee for its consideration.

WATER RESOURCES: SUPPLY STRATEGY AND PLANNING

  There is concern amongst some members of the Institution, particularly those who are employed in industry regulated by the Agency, that the augmentation and development of water resources does not receive due attention. It is also suggested that there appears to be little consideration of the needs of water undertakers as part of the Agency's operations, and that undue emphasis is placed upon water savings over the development of new water resources, in order to meet future demand.

  There is concern regarding the Agency's commitment to the twin-track approach of water resource development. The evidence is in its approach to the water companies' long-term water resources plans where the EA is perceived as being minimalist in its approach to source development. Unfortunately the evidence is not in the public domain and as such is hearsay. It could take over 20 years to promote a new water resource. In the minds of many professionals not enough is being done. However, this is difficult to prove without public domain information. CIWEM suggests that the Sub-committee should call for evidence to be submitted by both the water companies and the Agency on this topic.

  The Agency seems to be very set in its approach to minimising pressure on the water environment by reducing abstraction and implementing demand management. As an instance, this means pressing water companies to reduce leakage. These are beneficial policies, however, a more holistic approach is needed, so as to improve consideration of the impacts on the whole environment. For instance, metering can result in people not being able to afford to water their trees, shrubs and other plants, which as a result may die. This will have an impact on the quality of the urban environment.

  Of great importance to the urban environment are the trees in our streets. In heavily built up areas, trees are often set in footpaths, with tarmac right round the base of their trunk. In many instances the only way they can get sufficient water to survive is from leakage from the water pipes along the streets. Already there is evidence (Prof Chris Binnie, Keynote speaker at CIWEM Presidential Conference 1999) that urban trees are now dying due to lack of water. The Agency should be required to revisit this policy and to take a proper holistic approach. This is a view which has been advocated by the Arboricultural Association and the Local Government Association (LGA) for some time.

FLOOD DEFENCE

  It is believed that sustainable development needs to be defined in terms of flood and coastal defence. There may, at present, be a multi-disciplinary approach to river works, with conservationists and landscape architects becoming involved, however, this is a long way from a holistic approach to the environment. It is suggested that there needs to be increased interaction between functions at the grass roots level, and there is still much potential for improvement in the holistic treatment of issues within Local Environment Agency Plans.

  Whilst progress has undoubtedly been made, it is proposed that the Agency has some way to go before it can be regarded as a successful flood and coastal defence authority. The Agency's earlier focus tended to be on organisational change and environmental protection, to the detriment of flood defence and it took the Easter floods of 1998 to bring flood defence back to the corporate mind.

  The attention now being given to asset management and flood warning is commendable and similar emphasis is required to develop effective maintenance strategies and programmes to restore rivers degraded by past insensitive maintenance practices.

NAVIGATION

  The Agency's Navigation function allows it to consider wider issues and implement integrated catchment management more effectively. Yet this function is geographically fragmented, with many other navigation authorities holding responsibility for large stretches of river and man-made waterway. The justification for the existence of an Agency navigation function appears to be more historical than any more considered reason. It is suggested that the Sub-committee should investigate the justificaiton for an Agency navigation function, and examine whether the Agency is able to deliver effectively against both the requirements of navigation and those of environmental protection.

  The need for the existence of two independent and powerful navigation authorities (British Waterways being the other main navigation authority in this country) is questioned and it is proposed that the Sub-committee should examine the costs and benefits of unifying responsibility for navigation across the country. If this is deemed to be unworkable, it is proposed that different navigation authorities should be required to develop much closer working relationships than exist at present, particularly when their respective watercourses converge.

  Having conveyed the views of selected elements of its membership, CIWEM would wish to qualify these statements by adding its support to an alternative view that there is a need to allow the Agency a period of stability in order to properly assess the performance of many mechanisms and structures. CIWEM does not propose that there would be benefit in significant organisational change at this time. However, the Institution does believe that all areas of concern should be examined in a study such as this, in order that consideration can be given to the optimal form of an environmental agency in the long-term.