III. CURRENT PROBLEMS WITH FLOOD AND COASTAL
DEFENCE POLICIES
Social and environmental impacts of existing flood
and coastal defence policies
96. Arguably, the negative consequences of flood
and coastal defence policies have been greatest in the environmental
and social spheres, partly because of the length of time over
which human intervention in coastal and riverine sediment transport
systems and ecosystems has taken place, and partly because of
our inadequate scientific understanding of the human consequences
of modifying these complex natural systems to suit societal needs.
The appraisal procedure governing the approval of flood and coastal
defence projects, PAGN, also largely discounts these two issues
from consideration (see paragraphs 57 and 61).
97. In their evidence to us, the Wildlife Trusts
and WWF-UK commented that "flood and coastal defence has
too often been synonymous with the destruction of wetland and
coastal habitats. Ironically, it has also undermined the sustainability
of defences and increased risks by encouraging development in
flood plains and erosion zones and diminishing the capacity of
the environment to adapt"[145].
According to the RSPB, other environmental impacts arising from
existing flood defence policies include poor water quality, higher
flood peaks, low summer water flow, and decreased biodiversity[146].
98. However, the Wildlife Trusts and WWF-UK acknowledged
that since MAFF's 1993 review, "highly commendable improvements[147]"
had come about in national policy, and the rate of damage to the
natural environment from defence schemes had reduced in the ensuing
period[148]. We were
gratified that MAFF and the Environment Agency are beginning to
recognise flood defence needs and environmental protection are
not mutually exclusive aims and, indeed, that they can be mutually
supportive: the Environment Agency told us, for example, that
with an 80 metre width of salt marsh fronting an eroding coast,
coast defence costs would be of the order of £400 per metre;
without the buffering effects of this habitat, these costs could
rise to £5,000 per metre[149].
99. But while the principles of an environmentally
sustainable policy have been enunciated by MAFF in practice this
policy is still not apparent, according to witnesses[150].
English Nature also drew our attention to the need to replace
the preoccupation with defence, inherent in the current policy,
with the notion of management of coastal and riverine environments[151].
In our opinion, for this shift in emphasis to come about requires
recognition of the dynamic nature of these systems, by granting
adequate space for their natural evolution. Mr Andrew Lee of WWF-UK
spoke of the need for coasts and rivers to have the "space
in which to operate, the space for coasts to erode and accrete,
the space for rivers to move around and flood waters to spread
out where necessary...it is far more cost effective to recreate
some of the space for natural processes to operate which can form
part of flood defence than to continue a technological fix where
we have ratcheted up the costs year on year through hard engineering"[152].
Similarly, we were told by the RSPB that "by allowing more
flexibility back into the coastline, we will get [habitat] recolonisation"[153].
100. MAFF has instituted a number of mechanisms to
reverse the environmental damage caused historically by flood
defence works, principally drainage, and to bring about greater
integration of environmental requirements into current policy.
Some of these mechanisms were harshly criticised by witnesses
for their shortcomings - for example, the Wildlife Trust Cumbria
had "no faith" in the Ministry's Water Level Management
Plans (WLMPs), which were characterised as being reactive, restrictive
in scope and not adequately developed[154].
The Wildlife Trusts and WWF-UK also censored WLMPs for being "fundamentally
flawed by the false assumption that maintaining the status quo
is acceptable[155].
As these plans are designed to safeguard the very best of the
country's wetland and wildlife heritage, we believe there is an
urgent need for MAFF to examine the existing WLMP framework to
establish whether amendment is necessary.
101. While in 1996 the Ministry published its environmental
code of practice for operating authorities[156],
setting out best practice advice to these implementing organisations,
we are concerned that more has not been done to put into effect
an environmentally sustainable flood and coastal defence policy.
This is disappointing, as we heard from witnesses of a range of
options which, we believe, if implemented suitably, could immediately
strengthen the economic and environmental sustainability of policy.
At the coast, we heard powerful evidence for the development in
carefully selected areas of the still largely experimental policy
of managed realignment; while at the catchment level, we were
told of the likely benefits of strategic source control measures
and washlands creation in reducing the incidence and severity
of flooding of the sort experienced over Easter 1998.
102. Managed realignment involves the withdrawal
of coast defences at carefully selected points to allow the sea
to encroach inland to a pre-determined set back line. This need
only be a minor adjustment involving a small area of land, to
confer major benefits to flood and coastal defence, as well as
to the environment. There are clear limits on the applicability
of this technique; not all stretches of the coastline will be
appropriate. In their evidence to us, the RSPB estimated the total
area of land in east Anglia which might be suitable to be approximately
6,300 hectares[157].
At present, managed realignment has been confined to experiments
carried out on a relatively small scale[158],
although we were was made aware of the example of Pagham Harbour
on the south English coast, where an accidental breach in coast
protection works in the last century led to the inundation of
land below sea level, effectively bringing about a retreat in
the coastline, and creating an area of high nature conservation
value[159].
103. In their evidence to us, the National Farmers'
Union expressed concerns regarding managed realignment, chiefly
because this technique is most suited to the low-lying rapidly
eroding east coast of England, where much of the country's Grade
1 agricultural land is concentrated. However, Mr John Lloyd Jones,
Chairman of the Union's Parliamentary and Land Use Environment
Committee, commented that the NFU was in favour of its introduction,
"as long as it was done through...voluntary means and as
long as the people affected were compensated in a proper manner"[160].
English Nature recognised that, if progress were to be made in
developing the existing experimental approach into a fully fledged
national mechanism, the "generally insufficient[161]"
financial incentives currently on offer to farmers would have
to raised.
104. On this point, the Wildlife Trusts and WWF-UK
suggested to us that such incentives should not be regarded as
compensation: "if in the greater good it...make[s] sense
to retreat someone's land, and in order to facilitate that the
farmer receives some form of compensation, it should be perceived
as an investment from a national point of view"[162].
In his evidence Mr Elliot Morley MP, Parliamentary Secretary (Commons)
at MAFF, showed a reluctance to be drawn on this matter[163];
however, we are firmly convinced of the need to put in place a
robust financial mechanism for the reimbursement of property holders
and landowners whose assets are sacrificed for the wider interests
of the community. This mechanism will ensure that a major step
is made towards attaining the economically and environmentally
sustainable coastal policy MAFF aspires to, while recognising
the important role played by individuals in securing this wider
social goal. In our opinion, the Ministry has postponed this task
for too long and should investigate the practicalities of such
a mechanism urgently.
105. We also believe considerably more could be done
to end the reliance on hard engineered flood defences in urban
areas, through the provision of source control and washlands creation.
Source control seeks to slow the passage of water through catchments
by introducing water-retaining habitats and features, such as
wetlands and woodland, into farmed areas. Washlands might include
fields which remain in productive agricultural use but where the
crop grown would not be harmed by periodic flooding - for example,
wet pasture. We were told that both options could assist in lessening
the intensity of flash floods, and reducing the impact of downstream
flooding[164]. In this
way in RSPB's words "we...use natural processes and work
with them rather than struggling against them, which is much harder
and more expensive"[165].
The Environment Agency and MAFF must give greater priority
within national policy to managed realignment, washlands creation
and source control than has been the case hitherto. In each case,
the total area of land which would be affected represents only
a tiny fraction of the national land surface, and the associated
costs could be diminished by implementing managed realignment
of the coast and reorganisation of flood plains over long time-scales.
At the same time, alterations to the planning system should be
gradually phased in to deter inappropriate development on flood-prone
land and in rapidly eroding coastal areas. Through advice and
exhortation to relevant operating authorities, and the introduction
of a reimbursement mechanism along the lines we have suggested,
MAFF must ensure that over the next five years a start has been
made on the national implementation of these techniques in appropriate
locations.
Habitat creation
106. We welcomed Mr Morley's announcement to us that
in future MAFF will safeguard all nature conservation sites, designated
under the EU Habitats Directive, which are threatened by the sea,
or recreate habitats elsewhere should the original site prove
indefensible[166].
This new measure is intended to address the seemingly intractable
problem of defending one set of nature conservation interests
on an eroding coastline at the expense of another. At Brancaster
in north Norfolk, for example, protection of freshwater marsh
designated under the Directive can only be achieved at the expense
of loss of intertidal habitat which is similarly designated. In
our opinion, MAFF should ensure that where ever possible management
of semi-natural habitat and habitat recreation objectives are
fully integrated with those of flood and coastal defence. We
strongly approve of MAFF's actions in this area, and urge the
Ministry to bring forward proposals for implementing the new policy
as soon as possible, including provisions for recreating wetland
habitats elsewhere, and the means of monitoring policy progress.
145 Ev p110 Back
146
Ev p99 Back
147
Ev p110 Back
148
Ev p111 Back
149
Q 58; see also Q 317 Back
150
Ev p 110 Back
151
For example Ev p 156 Back
152
Q 290 Back
153
Q 336 Back
154
Appendix 16 Back
155
Ev p 111 Back
156
MAFF, 1996 Code of Practice on Environmental Procedures for
Flood Defence Operating Authorities Back
157
Ev p 136 Back
158
Ev p 175 Back
159
Q 337 Back
160
Q 364 Back
161
Ev p 159 Back
162
Q 305 Back
163
Q 613 Back
164
Ev pp 100-101 Back
165
Q 347 Back
166
Q 549 Back
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