A. EFFECTIVENESS
OF MAFF POLICY
ON FLOOD
AND COASTAL
DEFENCE
This evidence will support the underlying principle
of the "Ministry of Agriculture, Fisheries and Food and Welsh
Office Policy which is aimed at reducing the risks to people and
the developed and natural environment from flooding and coastal
erosion by encouraging the provision of technically, environmentally
and economically sound and sustainable defence measures".
The proactive stance taken by the Ministry of
Agriculture, Fisheries and Food (MAFF) in issuing a framework
of guidance through its series of publications for the protection
of the coastline is welcomed, together with their financial contribution
towards the development of sustainable coastal defence policies
which is particularly welcomed.
The statement in the first paragraph of the
press notice "current issues of concern" has not been
expanded upon. Generally those Local Authorities, this Council
being one of those, who are promoting programmes of works feel
they respond fully to MAFF guidance.
The following evidence is given in support of
this statement:
1. Following the lead given by The Standing
Conference On Problems Associated With The Coastline (SCOPAC)
the Ministry has encouraged the creation of Coastal Groups around
the country. Local authorities generally have a proven record
in the delivery of the Flood and Coast Protection service.
2. The production of Shoreline Management
Plans (SMP's) has been welcomed by both the local authorities
and the Environment Agency, although more work needs to be undertaken
particularly in protecting the natural environment and the integration
of SMP's into the Planning system.
3. A more acceptable approach would be for
MAFF to openly state a commitment to protect the coastline by
formally adopting the policies in the SMP's. This would permit
a more transparent system at a regional level and permit the involvement
of politicians to agree and prioritise the allocation of resources
more effectively. This allocation would reflect local needs which
are set against a national policy context.
4. MAFF has issued draft guidance for preparation
of strategy studies which are now starting to be commissioned/implemented
by both local authorities and the Environment Agency. A similar
approach to that suggested for SMP's is required for strategy
plans.
5. A better understanding of our coastal
processes is now available throuth plans and strategies, which
are also identifying the ongoing monitoring requirements. This
is regarded as essential when considering the implications of
expected climatic change and the future requirements for coastal
defence.
6. The promotion of strategic research is
now undertaken on a co-ordinated regional basis. This already
involves the Coastal Groups working with the Environment Agency
and other key organisations.
7. The decision-making process is now subjected
to a national priority scoring system. This has highlighted national
requirements in terms of coast protection and flood defence and
provided transparency to the levels of coastal protection and
flood defence funding. This process has both identified schemes
required nationally and also highlighted schemes which may not
be sustainable as they are predominantly reliant upon benefits
rather than proven need.
8. The activities of the voluntary Coastal
Group, activities which promote co-ordination between local authorities,
the Environment Agency and other organisations, require continued
encouragement and support by MAFF. This support for the evolving
policy on the role of maritime local authorities and regional
Coastal Groups in promoting and managing coast protection programmes
is essential for their sustainability. MAFF's views and concerns
on how local authorities are preforming are best addressed through
the Coastal Groups to ensure a more balanced and comprehensive
discussion is held on this important matter.
9. MAFF have found themselves in a difficult
and resource constrained position for coast protection with currently
only £38m in MAFF grants available to local authorities in
England and Wales.
10. The new "National Priority Score"
system demonstrates that the Government require approximately
three times the level of investment to secure to a reasonable
level of protection for all local authority frontages from coastal
erosion and flooding. A similar position can be demonstrated for
frontages managed by the Environment Agency. However, it is the
case that the scoring system can lead to rural authorities reacting
to events, rather than planning strategically. The threshold score
is often only achievable as a result of a defence failure. This
is at variance with the strategic approach required by SMP's.
11. The current policy for the approval of
schemes requires operating authorities to allocate substantial
resources and funding to promote schemes without any definitive
understanding of MAFF's views on the proposal. This is as a result
of MAFF's reluctance to formally adopt SMP's or to give meaningful
feedback at a very early stage of scheme development. In view
of the scale and reluctance of expenditure relating to coastal
defence, it is necessary for Central Government to be involved.
12. MAFF have criticised local authorities
for not dealing with works associated with Category 4 schemes
identified in the Coast Protection Survey of England and Wales.
The need to decide what is required is accepted and should take
account of local knowledge, but in some cases action has not been
taken because of the need to complete SMP's which has delayed
the decision making process.
13. The present arrangements for implementing
and funding of works are seen by local authorities as being fully
accountable to the public through their locally elected representatives.
Any substantial weakening or changes in the role of local authorities
in the future management of both coast protection and allied flood
defence, will be seen as contrary to the powers conferred on local
authorities by the Coast Protection Act 1949.
14. A more balanced system needs to be struck
between economic and environmental factors/impacts.
B. EFFECTIVENESS
OF MAFF POLICY
ON SOCIAL,
ECONOMIC AND
ENVIRONMENTAL CONSIDERATIONS
MAFF, through their support of local authorities
and the Environment Agency in the preparation of the Shoreline
Management Plans (SMP's) has encouraged the identification of
sustainable coastal defence policies, which in turn also asists
in directing future development to the most suitable locations.
This approach reflects the potential excessive cost involved in
the protection of our coastline in comparison to the level of
benefits that are available.
The following issues need to be addressed:
1. The social benefits/dis-benefits cannot
be assessed easily under the present arrangements. Coastal defence
policy will also need to be reviewed against any significant environmental
impacts and any losses that may occur in and around our coastal
communities.
2. This process has begun to open up a dialogue
that many local politicians have felt uneasy with. It has however,
begun a process which has caused many to reflect upon coast defence
strategies which no longer accept as the norm the "status
quo" for future protection. This reflection will ultimately
inform the planning process and must be capable of accommodating
such advice.
3. The continuation of present policy objectives
may through the various plans, lead to higher flooding/erosional
risks and particularly where there is not a clear economic argument
for protecion of the coastal frontage. This policy may lead to
planning blight and the inability to obtain adequate insurance
cover to protect assets from loss or damage.
4. The production of SMP's has focused the
attention on a need for a national mechanism to cover the cost
of compensating for lost habitats, land and communities in appropriate
cases. Guidance is required on this issue, and also on the acceptability
of schemes for cliff restoration where coast protection works
are considered at risk.
5. Local Authorities, through their elected
Members, have already had significant input into future policy
when considering the SMP process and more specifically, strategic
defence options. This local involvement and understanding is paramount
in any development of MAFF policy, to ensure sustainable management
solutions are prepared that protect both rural and urban coastal
communities and are locally acceptable.
9 April 1998
