IV. CONCLUSIONS AND RECOMMENDATIONS
115. As we described in paragraphs 2 to 4 of this
Report, our nation's history is one of continual intervention
in coastal and riverine processes, punctuated by occasional awesome
reminders of the power of the sea. It is not surprising that our
lexicon for describing the relationship between the land and the
sea is dominated by militaristic terminology: we speak of flood
and coastal "defence", of "reclaiming" or
"winning" land from the sea - even of the sea "invading"
the land. Hard-engineered defences remain essential to protect
many vital national assets, especially in urban areas. But, overall,
we believe that it is time to declare an end to the centuries-old
war with the sea and to seek a peaceful accommodation with our
former enemy. It is far better to anticipate and plan a policy
of managed realignment than to suffer the consequences of a deluded
belief that we can maintain indefinitely an unbreachable Maginot
Line of towering sea walls and flood defences.
116. For this reason, we welcome the recent change
in emphasis in flood and coastal defence policy instigated by
MAFF. It has set in place the foundations for a more sustainable
approach and, we believe, if properly managed will provide an
integral element in fulfilling other Government goals, such as
nature conservation objectives. However, concrete policy achievements
over the last five years have been meagre, and our satisfaction
with the change in national policy priorities is tempered by the
relative failure of MAFF to instil a sense of drive, purpose and
direction in the new policy among relevant operating authorities.
Our feeling is that, as a result, operating authorities have become
disengaged from strategic involvement in policy, and we have made
our recommendations for institutional change in this light, seeking
to knit these two elements together once more. Some of our recommendations
will require substantial change in existing legislation; however,
such change is imperative and, in our opinion, unavoidable if
a truly sustainable flood and coastal defence policy is to become
a reality. Making room for the sea at the coast and for rivers
in flood plains, fulfilling simultaneously environmental and economic
objectives, will only come about if the correct institutional
mechanisms are in place to direct the strategy.
117. Our other principal conclusions and recommendations
are as follows:
Human intervention in flooding and erosion processes
(a) We are of the
opinion that flood and coastal defence policy cannot be sustained
in the long term if it continues to be founded on the practice
of substantial human intervention in the natural processes of
flooding and erosion. Indeed, it is of great concern to us that
the legacy of flooding and erosional problems arising from this
practice - and the likely increase in future of climatological
and other environmental pressures on the UK's ageing flood and
coastal defence infrastructure - might combine to present flood
and coastal defence authorities with insuperable difficulties
(paragraph 9).
Government's plans for flood and coastal defence
expenditure
(b) We are encouraged
that the Government has seen fit to plan to increase spending
under the Comprehensive Spending Review on flood defence, and
has no immediate plans to cut global levels of flood and coastal
defence expenditure. From the evidence we have received, it appears
operating authorities are hard enough pressed as it is to maintain
vital local flood and coastal defence programmes. We also commend
the Government on the introduction of three year budgets for flood
and coastal defence expenditure, which should assist strategic
planning in this area (paragraph 30).
The changed policy context for flood and coastal
defence
(c) The lessened need
for domestic agricultural self-sufficiency, and the significant
costs of farm policies encouraging agricultural overproduction,
need to be explicitly acknowledged in the implementation of local
level responses to flood defence and coastal protection of agricultural
land, including, where appropriate, the managed realignment of
the coastline. Suitable compensation arrangements will need to
be put in place (paragraph 40).
(d) We believe that implementation of national
policy must now evolve to provide not only mitigation of the effects
of erosion and flooding, but also to embrace more holistic management
of our river systems and coastlines (paragraph 41).
Survey of flood defences
(e) The Environment
Agency is currently about half-way through a national visual survey
of the state of river defences: this survey is expected to be
completed in April 2000. We appreciate the scale of the task facing
the Agency - there are 31,000 km of 'main river' alone for which
it is responsible - but we believe that additional resources need
to be devoted to this survey to ensure it is completed at the
earliest possible date (paragraph 44).
Existing funding arrangements for flood and coastal
defence
(f) Our opinion is
that MAFF and the Department of the Environment, Transport and
the Regions should undertake a joint review of the current mechanisms
for public financing of flood and coastal defence works to ensure
that the funds made available by both Departments do not prejudice
decisions taken by local authorities against the maintenance of
existing infrastructure and in favour of the construction of new
works. The review should include an evaluation of the existing
maintenance heading of the Standard Spending Assessment to assess
whether it provides the most effective mechanism for delivering
funds for the maintenance of flood and coastal defence works.
We recognise the urgent need for extensive renovation, and, in
places, the replacement of existing works over the next decade;
but in order to safeguard life and property in the long term,
the piecemeal, reactive approach to maintaining defence works,
endemic in the current system, must be replaced by a considered
national strategy drawing the appropriate balances between maintenance
and new developments (paragraph 46).
(g) So far seemingly little attention has
been given by MAFF or the operating authorities to the setting
aside of contingency expenditure to address the financial ramifications
of the Ministry's more positive approach towards soft defence
and the managed realignment of the coast - for example, the likely
costs arising from compensation of land owners for loss of property
and land assets. If MAFF is genuine in its advocacy of a strategic,
sustainable approach to the UK coastline, action on these issues
cannot be put off (paragraph 47).
(h) Potentially, there are strong arguments
for the centralisation of all funding on flood and coastal defence
in a single national agency, which would enable spending to be
prioritised to fulfil national and regional objectives far more
effectively than can be achieved at present. However, we recognise
that, were this to come about, there would also be considerable
disbenefits in terms of the loss of political accountability,
especially at local and regional level, which is seen by some
as one of the existing system's enduring strengths. We therefore
urge the Government after proper consultation with operating authorities
radically to simplify the existing funding procedures for flood
and coastal defence activities, with the aim of achieving measurable
improvements in policy efficiency through cutting out unnecessary
bureaucracy and administration. As we are in favour of
devolving greater decision-making responsibility for flood and
coastal defence to the regional level, one possibility for consideration
may be to replace scheme-specific grant-in-aid from MAFF and the
Welsh Office with block grants, allocated to Regional Flood Defence
Committees or regional coastal groups, as appropriate (paragraph
51).
Constraints on flood and coastal defence projects
of current funding procedures
(i) We favour the
assumption by Regional Flood Defence Committees and coastal groups
of local authority competence for flood and coastal defence. We
recommend that MAFF liaise with DETR to assess the difficulties
confronting district councils in funding this policy area. Furthermore,
the ring-fence on local and regional precepts should be removed
to permit resources to be used flexibly in the context of national,
rather than local priorities (paragraph 53).
Project Appraisal Guidance Note (PAGN)
(j) As a matter of
priority, MAFF must develop methodologies addressing social and
environmental criteria for inclusion in PAGN. Operating authorities
should also be required to identify the best practicable environmental
option from among the range of choices submitted to MAFF, and
such options should be given increased weighting by the Ministry
in the project approval process. PAGN should provide greater encouragement
for projects with multiple functions - for example, defensive,
social and environmental - than at present; only by doing so can
MAFF's multiple goals for sustainability be realised. There must
also be far more transparency in the process by which MAFF's decisions
under PAGN are reached, and the Ministry should review ways of
simplifying and speeding up the whole process of project appraisal
(paragraph 60).
Rationalisation of legislative base of flood and
coastal defence policy
(k) In our opinion,
the Government should rationalise the legislative base of flood
and coastal defence policy in England and Wales as soon as possible,
with, among other aims, the ending of the artificial distinction
between sea defence and coast protection responsibilities. We
recommend that coastal groups take responsibility for sea defence
and coastal erosion. Similarly, the logical basis for dividing
responsibilities for main river and non-main river flood defence
between the Environment Agency and local authorities should be
re-evaluated by the Ministry. We recommend that the RFDCs take
on responsibilities for flood defence activities on non-main rivers
currently undertaken by local authorities and riparian owners
(paragraph 67).
Improving the delivery of national strategy for
flood and coastal defence
(l) We recommend that
MAFF and the Environment Agency, as appropriate, provide clearer
guidelines for Regional Flood Defence Committees and coastal groups
to ensure that, while local needs are respected, the regional
targets set through Shoreline Management Plans at the coast, or
Local Environment Agency Plans inland, also advance relevant national
strategic requirements. These guidelines should be updated in
the light of the latest scientific research, and be monitored
by MAFF or the Environment Agency at regular yearly or biennial
intervals to ensure that they are being observed (paragraph 70).
(m) We have a national flood and coastal strategy
in principle, but not in practice. More must be done by the Ministry
to ensure operating authorities translate national strategic priorities
into positive action on the ground (paragraph 70).
(n) We propose a reorganisation of institutional
and administrative responsibilities for flood and coastal defence
which we urge the Government to consult upon with relevant parties
(paragraph 75).
(o) We are firmly convinced that the functions
of Local Flood Defence Committees and Internal Drainage Boards
would be more appropriately discharged by Regional Flood Defence
Committees, which should be responsible for the delivery of all
inland flood defence policy nationally working under the guidance
and supervision of the Environment Agency. The decision on how
policy should be implemented in particular regions - for example,
by bodies represented within the RFDC, or by letting contracts
- would be the responsibility of the relevant Committee in consultation
with the Environment Agency and, where appropriate, Regional Development
Agencies. This does not necessarily imply the abolition of IDBs,
although the decision whether or not to devolve duties relating
to the implementation of inland flood defence policy would rest
with the appropriate RFDC. They would remain in existence and
would retain, at the very least, an important consultative role.
We believe a higher proportion of RFDC funding should be provided
from central Government, which need not necessarily involve higher
expenditure: indeed, it might provide some savings though reducing
the convoluted bureaucracy of the current financing system. An
element of local level funding should, in our view, be retained
for permissive projects agreed by the RFDC. Membership of RFDCs
should be vetted to ensure they fully reflect stakeholder interests
and that the levels of democratic accountability offered by the
existing administrative arrangements are not in any way compromised
(paragraph 76).
(p) On balance, we think it inappropriate
to introduce a single agency with sole responsibility for flood
and coastal defence policy, taking into account the Government's
plans for enhancing decision-making responsibility at the regional
level and the implications that this will have for the delivery
of flood and coastal defence. Our general view is that, with the
appropriate mechanisms to ensure local level accountability, flood
defence responsibilities should instead be enhanced at the regional
level and through the Environment Agency assuming new powers,
for example to discourage inappropriate property development on
land liable to flooding (paragraph 79).
Improving co-ordination between competent agencies
in the coastal zone
(q) If Shoreline Management
Plans are to play the strategic role in coastal defence and foreshore
management originally envisaged by MAFF, thereby contributing
to the creation of a genuinely sustainable national coastal policy,
we believe their guiding provisions should be given full statutory
status in the local and regional planning process (paragraph 81).
(r) Advancing the integrated sustainable national
coastal strategy advocated by MAFF will require greater effort
by the Ministry and DETR and all relevant parties to develop and
implement Coastal Management Plans, and to ensure the objectives
of relevant Shoreline Management Plans are prioritised within
them. As sponsor of national policy in respect of coastal defence,
the Ministry should liaise with DETR to identify ways of facilitating
this process where there are difficulties, and of speeding up
development and implementation of Coastal Management Plans where
these plans have been agreed, but not yet put into practice (paragraph
84).
(s) We warmly endorse the co-ordinated approach
to coastal management through coastal groups, and believe a more
strategic approach could be taken to larger stretches of the UK
coastline if coastal groups were given statutory status and granted
formal powers to assume the responsibilities and resources of
their constituent local authorities in the sphere of coastal and
sea defence policy. Membership of existing groups should be vetted
to ensure they represent the full spectrum of stakeholder interest.
Furthermore, they must work within the much more clearly defined
set of national guidelines already mentioned. These guidelines
should be reflected in the content of the pertinent Shoreline
and Coastal Management Plans. Periodic monitoring of these plans
should be undertaken by MAFF to ensure that these guidelines are
being observed, and that national objectives are being furthered
through action on the ground (paragraph 85).
Integrating flood defence requirements within
the planning system
(t) We believe that
a clear presumption should be made against future development
in flood plain land where the flooding risk attached to a particular
development, as determined by the Environment Agency, is deemed
to outweigh the benefits. In such cases, the Agency should intervene
at all stages of the planning process in such a way as to deter
inappropriate development, including, where necessary, referring
the matter to the Secretary of State for his or her determination.
Such powers would be more likely to be exercised in relation to
sizeable and significant developments and the constraints should
apply primarily to new development of land in coastal and inland
flood plains, rather than redevelopment of existing urban or industrial
land, undesirable as the latter may be in some cases. We also
urge local authority planning departments to have regard to both
the individual costs of flooding - loss of lives, property, and
assets - and costs to the community, for example, the expenditure
incurred by emergency services, and through increased insurance
premia, that the granting of planning permission for inappropriate
development inevitably brings (paragraph 89).
Financial obligations on private developers
(u) In future, in
those exceptional circumstances where planning permission on land
liable to flooding is considered, the Environment Agency should
have powers to require developers to set aside sufficient monies
for the provision of the required flood defence works both at
the point of development, and upstream and downstream of it, before
planning permission is granted. This does not mean that private
developers should be able to evade or over-ride national or regional
flood defence strategy (paragraph 90).
Dissemination of information to the public and
acceptance of flood and erosion risk
(v) Our view is that
much greater emphasis must be placed on the dissemination to the
public of locally-appropriate information on the degree of risk
to persons and to property presented by flooding and coastal erosion.
Our belief is that this is a fundamental component in any national
strategy seeking to minimise the hazards posed by these processes,
and we are surprised that more effort in this direction has not
been made already by relevant agencies. It is only on this basis
that informed judgements can be made by the public as to the most
appropriate method for managing flood and erosion risks at the
individual level, leading to acceptance of ultimate responsibility
for personal actions. Title deeds of properties at risk of inundation
should be amended to show clearly and unambiguously that this
is the case, and this information must be relayed to potential
purchasers as part of the property conveyancing process. Insurance
companies should be obliged to provide advice to individuals in
flood risk areas as to how to mitigate the effects of flooding,
and how to address property and asset claims afterwards to ensure
their rapid settlement. The Environment Agency and local
authorities should ensure that persons at risk from flooding are
made thoroughly aware of the warning procedures in place and the
action to be taken in the event of emergency (paragraph 92).
Longterm adaptive policies at the coast and inland
(w) We strongly urge
MAFF to give its fullest possible attention to the formulation
of long term adaptive policies, for example encouraging the gradual
managed abandonment of certain coastal areas, possibly over the
course of many decades, and conferring residual life on defence
works currently protecting assets which are untenable in the long
term (paragraph 93).
(x) We believe there is a need to reduce long
term downstream flooding and erosion risk through the gradual,
phased removal of some hard-engineered constraints on rivers and
flood defences now deemed to be obsolete, and their replacement
with more environmentally sustainable alternatives, for example
washlands and source control measures (paragraph 93).
Departmental responsibility for flood and coastal
defence
(y) We believe that
the issue of where departmental responsibility should lie for
national flood and coastal defence policy to be more superficial
than substantial. Far more important is that the sound progress
of recent years is built upon, that organisational relations and
collaboration between MAFF and DETR are improved and deepened,
and that sustainability objectives are built into all aspects
of flood and coastal defence policy. We also note that, with the
publication of the Comprehensive Spending Review and the allocation
to MAFF of increased expenditure for flood defence, the policy
of the Government on this matter has apparently been settled (paragraph
93).
Fulfilling the Government's national strategic
aim for flood and coastal defence
(z) Our examination
of the existing institutional arrangements for the delivery of
flood and coastal defence policy has led us to reach a number
of conclusions and recommendations designed to improve the formulation,
implementation and financing of that policy. We would describe
our central recommendations as the following:
(i) the establishment
of a clear distinction between inland and coastal issues, reflected
in the administrative structure;
(ii) integrated management of flooding
issues for main rivers, non-main rivers and in Internal Drainage
Board Areas;
(iii) integrated management of flooding
and erosion issues on the coast;
(iv) strategic direction of policy
at the national level by MAFF, as now, with the Environment Agency
responsible for all flood and coastal defence issues in an advisory
and supervisory role, and implementation of policy executed at
a regional level (paragraph 95).
Water Level Management Plans
(aa) During this inquiry,
Water Level Management Plans were harshly criticised by witnesses
for their percieved shortcomings. 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 Water Level Management Plan framework to establish
whether amendment is necessary (paragraph 100).
Rewarding individual action benefiting the community
(bb) 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 benefit of the community.
This mechanism will ensure 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 (paragraph 104).
Accelerating the implementation of soft engineered
approaches to flood and coastal defence
(cc) 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 (paragraph
105).
Habitat conservation and recreation
(dd) We strongly approve
of MAFF's policy to safeguard Special Areas of Conservation, designated
under the EU Habitats Directive on rapidly eroding coasts, 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 (paragraph 106).
Difficulties in predicting floods
(ee) We express the
hope that the Meteorological Office will always have access to
the resources necessary to improve its forecasting techniques
in line with best international practice. If flood warnings are
not to be devalued, it is crucial that they are issued in a prudent
and timely way, and only when there is a strong likelihood that
floods will occur. Obtaining the evidence to establish this likelihood
depends on a number of factors including the accuracy of weather
forecasts, but we accept that, for the foreseeable future, it
will remain considerably easier to predict storm tides than often
highly localised inland rainfall (paragraph 110).
Environment Agency's flood defence priorities
(ff) With the extra
finance which is expected to be made available for flood warning
following the Comprehensive Spending Review, we urge the Environment
Agency to broaden its flood warning coverage to areas at moderate
flood risk, as well as those at high risk, urgently and to make
further improvements to the flood warning systems already in place
(paragraph 111).
Availability of flood risk information
(gg) The production
of flood warning hazard maps and their delivery to local authorities
must be made the Environment Agency's highest priority. Only when
these maps are completed can the process of standardising flood
warning procedures across the country be begun. We recommend
that in future the Environment Agency takes a strategic approach
to managing runoff within whole river catchments as part of Local
Environment Agency Plans, treating it as a cause of flooding rather
than a consequence of it (paragraph 112).
MAFF flood disaster contingency fund
(hh) In our opinion
a contingency fund should be established by MAFF with funds disbursed
to local authorities to meet the longer term costs associated
with the disruption to persons and property after catastrophic
flooding events have occurred (paragraph 113).
Flood warning dissemination
(ii) We believe more
must be done to standardise interorganisational procedures for
flood warning, both regionally and nationally. Co-ordination between
the Environment Agency, local authorities and emergency services,
although good, must be further improved. We believe a crucial
element in improving dissemination is to raise public awareness
of the inherent risks of living in flood prone areas, and to provide
accurate, straightforward information to people on what to do
and whom to contact in the event of a flood emergency. We were
particularly surprised that it was not already obligatory for
all local public and commercial radio and television stations
to carry flood warnings on air, and would urge MAFF to make this
a requirement in future (paragraph 114).
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