Select Committee on Agriculture Minutes of Evidence


Memorandum submitted by the Local Government Association (F45)

  The Local Government Association (LGA) represents nearly 500 local authorities in England and Wales with a population of over 50 million. It welcomes the opportunity to respond to the House of Commons' Agriculture Committee's inquiry into current issues of concern relating to flood and coastal defence.

  This statement has been prepared in response to the Press Notice, dated 6 March 1998. Section A of this evidence comments on the effectiveness of MAFF's current expenditure and policy on flood and coastal defence; provides evidence as to how local authorities respond to MAFF guidance and makes some suggestions for improvement of the current arrangements. Section B comments on the effectiveness of MAFF policy in relation to the social, economic and environmental implications of existing flood and coastal defence policy and the sustainability of such policy in those terms. Section C, the conclusion, suggests a way forward.

A.   EFFECTIVENESS OF MAFF POLICY ON FLOOD & COASTAL DEFENCE

  This evidence will support the underlying principle of the "Ministry of Agriculture, Fisheries & Food & 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 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 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 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.  This could be achieved if MAFF were 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 through 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 of 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 performing are best addressed through the Coastal Groups to ensure a more balanced and comprehensive discussion held on this important matter.

  9.  MAFF have found themselves in a difficult and resource constrained position for coast protection with currently only £38 million 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 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.  As the Statutory Spending Assessment (SSA) is based on local authority budgets in the previous year, the "cost" to authorities of flood defence spending is less than the cost of other services—any increased spending is compensated for through the SSA and grant system. One might then expect local authorities to "overspend" on flood defence compared to other service areas. However, this does not appear to happen in practice.

  13.  It would be reasonable to retain the existing SSA methodology (as it would be difficult to develop a robust distribution formula which was free from bias) with additional safeguards to reflect within year changes in local authorities' spending on their own flood defence schemes in the SSAs for subsequent years. This would allow for consistency and certainty within the SSA procedure and for strategic planning for flood defence.

  14.  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.

  15.  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.

  16.  A more balanced system needs to be struck between economic and environmental factors/impacts.

B.   EFFECTIVENESS OF MAFF POLICY ON SOCIAL, ECONOMIC & 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 assists 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.

  There is a case for a more cohesive regional response to deliver Government Policy on flood and coast protection. The relationships between local authorities and other bodies and the necessity to prioritise and allocate resources more effectively is also important.

  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.  In relation to development on flood plains, it would be helpful to local authorities to have specific, good quality planning policy guidance. This would require the Environment Agency to complete its revision of inland flood defence strategies to discriminate more selectively between the protection of life and built property on the one hand, while on the other, setting standards of flood defence in flood plains appropriate to the combination of agricultural, environmental and sustainability objectives set for these areas. The current planning system is effective for major developments but guidance is needed where there are existing developments in areas where there is no flood defence scheme in operation.

  3.  In addition, Government should consider compensating land owners if areas suited to flood storage associated with flood plains are cheaper to use than funding flood defence capital works. Arrangements should be made to offer positive incentives for beneficial management of those areas for national Biodiversity Action Plan targets, where management for conventional agricultural production is not cost-effective.

  4.  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 which must be capable of accommodating such advice.

  5.  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 protection 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.

  6.  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.

  7.  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.

  8.  The complexities of coastal management and associated protection of the coast are such that it is highly desirable that the system is not run on a centralised basis, although there is a necessity for Central Government to be involved. The system needs to be run on a decentralised basis with local decision making, in order that protection of the coast can be married with other coastal management issues. Priorities should be decided at a regional/local level, with a system of bids to central Government, based on agreed strategic policy documents [Regional and SMPs] ideally with resources distributed to enable a three year programme to be progressed. This would then avoid prolongation of scheme approvals where MAFF's staff have to undertake a detailed vetting of individual schemes.

  9.  Central Government expects local authorities to develop a sustainable and holistic approach to the integration of environmental and economic needs. There is an important relationship between the management of flood and coastal defence and the environmental stewardship and economic regeneration of local areas. With the responsibility for coastal defence, local authorities have the ability to influence and co-ordinate plans and proposals for local sustainability. The co-ordination of specific local authority responsibilities such as planning and tourism could not be embraced effectively without this local involvement.

  10.  It is recognised that the current system is far from perfect. There could be an improvement in the definition of roles of local authorities and other bodies with responsibilities for coast protection and flood defence as the demarcation of responsibilities between flood defence and coast protection can be artificial. However, improvements should not be at the cost of democratic control.

  11.  Priorities are set to allocate limited resources in accordance with specific land use categories. Therefore, the service is not an end in itself but rather a means of meeting wider community needs. This has been a fundamental aspect in the preparation of River Catchment Area Plans and Shoreline Management Plans.

C.  CONCLUSION

  The current arrangements for flood and coastal defence are complex and many agencies are involved. Within this complex set of arrangements, there is scope for local government to improve the efficiency and effectiveness of its responsibilities. There is also scope for more joint working and collaboration between the bodies involved with a view to balancing their different interests and there is a need to balance national and local considerations in putting into place coastal and flood defence measures. Local government's involvement (through the LGA, which is committed to working with local government) is central to ensuring that communities are represented in a balanced way.

  An appropriate means of taking work forward in this area could be by the establishment of a stakeholders's group, which would examine the issues in a collaborative way in order to produce a workable solution to deliver a strategic programme. The involvement of local government in such a group would add value to the process and lead to best practice.

5 May 1998


 
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