House of Commons - Agriculture - Minutes of Evidence

Select Committee on Agriculture Minutes of Evidence

Memorandum submitted by the Wildlife Trusts and WWF-UK (F9)

5. COMMENT

5.1 Coastal protection and flood defence has too often led to undesirable development. Planners and developers have been lulled into a false sense of security in the risk zone with the effect that, in many places, while the probability of flooding or erosion has been locally reduced, the risks have increased. The effects have been unsustainable patterns of land use and development that cost progressively more to maintain and impair the natural ability of the environment to adjust.

5.2 The Environment Agency is well aware of the functional value of flood plains as the following quote demonstrates: "Rivers and floodplains are fundamental parts of the water environment. Generally, their existence is a result of natural forces and processes that must be respected if land drainage and flooding problems are to be avoided . . . Flood plain storage reduces peak flow in the river. The effect of this is to reduce flood levels and the risk of flooding downstream. Additionally, flood plains assist in the conveyance of flood waters, which can also have a bearing on flood levels and flood risk." (EA, 1997).

5.3 Indeed, over the past few years, both the EA and MAFF have increasingly published policy statements and guidance which indicate that these authorities have a growing appreciation of the functional significance of natural habitats in flood and coastal defence. However, major changes in practice at all levels as well as policy and guidance is required to effect a sustainable improvement in the state of the country's flood and coastal defences and to begin to reverse damages to the natural environment. It is far from clear whether the current arrangements for flood and coastal defence management will be able to accommodate such a change.

5.4 The Wildlife Trusts and WWF-UK concur with MAFF's overall priorities for flood and coastal defence as outlined in the Strategy for Flood and Coastal Defence in England and Wales (MAFF/WO, 1993), with top priority being the protection of human life and second priority the protection of the built environment (MAFF, 1993). We are also generally supportive of the overall aims and objectives of the Ministry namely:

— by encouraging the provision of adequate, technically, environmentally and economically sound and sustainable flood and coastal defence measures; and

— by discouraging inappropriate development in areas at risk from flooding or coastal erosion.

5.5 The chief weakness in MAFF's policy is a lack of any recognition that important parts of the natural environment actually depend on flooding in order to sustain their interest and ability to provide defence benefits. The interests of nature conservation and the human community may be served by increasing the risk and frequency of flooding in certain places where life and urban areas are not threatened. With that exception, MAFF's overall aim is well balanced.

5.6 The Environment Agency's stated overall aim relating to flood defence is:

"To provide effective defence and warning systems to protect people and property against flooding from rivers and the sea" (EA, 1997).

5.7 There is a subtle but crucial discrepancy between the aims of MAFF and the EA. MAFF makes no reference to any unqualified commitment to defend "property". This is significant since all land in the UK is someone's property[4]. In the EA's policy, there is clearly a leaning towards the old assumption that the taxpayer will pay for the defence of property per se. This amounts to a bias towards the maintenance of present land use practices. This presumption remains deeply ingrained in defence management on the ground despite many very good, rational and balanced policy statements orientated towards the maintenance and improvement of flood plains (EA, 1997). It is a particularly curious bias since The Agency has a legal duty to conservation[5], but only permissive powers to protect private property from flooding.

5.8 Despite a growing recognition that the maintenance of the status quo is incompatible with sustainable development, conservation commitments and the public interest, there remains a deep-seated reluctance to change. This reluctance is apparently enshrined in the attitudes and practices of the decision-making and implementation machinery of policy which includes the regional flood defence committees, local flood defence committees, internal drainage boards (IDB) and local authorities as well as the professional sector.

5.9 It is important to recognise that agricultural policy is changing and that land drainage to increase production now needs to be balanced with environmental objectives. CAP Reform and Agenda 2000 will include a changing emphasis towards support for rural communities and cross-compliance. Greater use could be made of agri-environment schemes in parallel with flood and coastal defence management.

5.10 This inquiry provides the Agriculture Committee with an opportunity to review the present arrangements with a view to recommending a new, balanced and efficient means of regulating the nation's responsibility to protect life and urban areas at the same time as meeting commitments to conserve the natural environment. These tasks are fundamentally inseparable. The lack of accountability for environmental impacts of IDBs and other drainage authorities, whose drainage consents fall outside the scope of EA reviews of abstraction licences, is no longer acceptable.

5.11 A number of inter-related paradoxes in recent policy and practice provide clues as to how the ills of the present system may be improved.

5.12 The Defence Paradox

The huge investment in engineering of coasts and waterways has undermined the natural functions of the environment to provide ecological and defence services.

These include:

— locking up important sediment sources

— impairing the ability of intertidal areas to stop wave energy and flooding

— increasing the frequency and magnitude of floods downstream from canalised stretches in rivers' systems which "peak" faster

— increasing frequency of spates caused by land drainage in the upper reaches of catchments

— increasing flood risk and foreshore erosion in tidal rivers and estuaries

— an increasing need to pump and drain as embanked areas shrink due to drainage and compaction and fail to accrete in pace with tidal areas.

5.13 The Environmental Paradox

Huge investment in "improving" the environment has caused:

— worse fisheries—freshwater fish prefer clean, full rivers to polluted drains and many marine species depend on tidal areas as nursery or feed areas

— reduction in water storage capacity

— lower water quality as natural vegetation filters are removed or damaged

— soil loss (erosion and peat oxidisation)

— additional CO2 emissions from peat oxidisation

— less aquifer recharge

— a loss of landscape diversity and quality

— massive habitat destruction as outlined above

— loss of natural biodiversity.

5.14 The Economic Paradox

Natural systems, by definition are taxpayer-friendly—they maintain themselves at no cost to the Treasury. In contrast, every pound invested on capital works for land drainage, coast protection and flood defence has ratcheted up, in perpetuity, the maintenance costs of an increasingly artificial system. In addition, many millions of pounds of public money continue to be spent annually maintaining intensive, environmentally damaging agriculture on flood plains in addition to which the public also pays for defence, all of which produces fewer "public goods".

5.15 The Institutional and Financial Paradox

The Environment Agency is accountable to the Department of the Environment, Transport and the Regions (DETR) but the flood defence budget is controlled quite separately by Flood Defence Committees which are largely funded by, and accountable to, MAFF. The EA lacks the capacity to deploy money that is ring-fenced for flood defence on more integrated water management no matter what its judgement about the desirability of doing so. Most flood defence committees and internal drainage boards maintain a bias in their composition and modus operandi in favour of agricultural interests. Such bodies are unlikely ever to endorse a reduction in public investment in the protection of their own sectoral interest even if it were manifestly in the greater public interest to do so.

5.16 Coastal protection is vested with the maritime district authorities under the Coast Protection Act 1949 but funded by MAFF, although the principal beneficiaries are neither agriculture, fisheries or food interests. Coast protection and flood defences are intimately related by physical processes, which sustain natural defences. However, the Environment Agency is only a consultee in the matter of coast protection with limited influence. Because it is perceived to be a good thing to draw national money into an area, it makes political sense for maritime district authorities to maximise central government expenditure in their areas regardless of the greater public interest. Even on a local level they do not have to ask themselves whether money would be better spent on schools or emergency services, for example, or "coast protection". They are therefore always likely to lean on central government to invest in their area regardless of the strategic balance of interests. Shoreline management plans have begun to paper over this issue but they are unlikely to solve it.

5.17 Weaknesses in the system are too deeply ingrained to allow it to implement even the present policy objectives. The spirit of MAFF's policy is too often dampened by local practices. The effect in many cases, five years after considerable improvements in policy, is business as usual. The most notable exception to this has been on internationally protected nature conservation sites. On such sites the Habitats Directive[6] has forced an adjustment of old practices. However, here the issues are far from resolved. Indeed, constructive solutions are often impaired by the background of ongoing degradation of the coastal and fluvial environment that is a legacy of flood and coastal defence management.

5.18 It is difficult, if not impossible, to see how the present system will allow the UK even to meet its international obligations to nature conservation, let alone its commitment and aspirations as manifest in the Biodiversity Action Plan. Rising sea levels threaten the integrity of many sites protected by European designations. In some cases these areas have been rendered incapable of adapting due to defence works. It has been estimated that 12,750 hectares of intertidal habitat, much of it enjoying European protection, will be lost to rising sea levels between 1993 and 2013. In order to maintain a favourable conservation status, habitat creation or restoration must offset these losses. The present instruments are manifestly failing to even offset losses and doing nothing to reverse them. In the past four years since MAFF introduced its Salt-marsh Creation Habitat Scheme, only four schemes covering 58 hectares have been implemented. In the same time it is estimated that at least 500 hectares of salt-marsh has been lost to rising sea levels.

5.19 Under the UK Biodiversity Action Plan a number of costed Habitat Action Plans have been, or are being, agreed. These plans set targets to stop the loss of important natural assets and where, appropriate, reverse historic damage and loss. Many will depend on a level of integration between natural resources management and flood and coastal defence that is inconceivable under the present system.

6. THE SOLUTIONS

6.1 The four paradoxes outlined above constitute an unsustainable treadmill. This is as much a factor of the machinery of decision-making and the balance of vested interests as policy. It is to the great credit of both MAAF and the EA that they have attempted to improve the present system with a degree of strategic thinking. However, these attempts have largely failed. In the view of The Wildlife Trusts and WWF-UK any tinkering with the present machinery is unlikely to substantially improve the situation. We need a new paradigm of coastal and wetland resource management in the national public interest.

6.2 A new approach would begin to resolve the old paradoxes but it would create a paradox of its own; that increasing the area and frequency of flooding and allowing coastal erosion to continue where possible could actually reduce risks and form the basis of a genuinely sustainable defence strategy. Until defence engineers and decision-makers realise and act on this truth, the goal of sustainable management will remain elusive. We need a conscious decision to reverse the legacy of excessive unsustainable engineering in favour of restoring the natural capacity of coasts and wetlands in the wider public interest. Some of the components of a rational and balanced system exist within the present framework but the framework itself needs to be rebuilt.

6.3 Effective risk management also requires strong links between flood and coastal defence and land use development. The Environment Agency's present policies and practices for the protection of flood plains (EA, 1997) are good but they depend on the co-operation of local authorities, which is not always forthcoming. The national planning policy guidance documents on coastal development (PPG20) and development and flood risk (DoE Circular 30/92) are also good but their intent is hampered by a lack of integration between development and flood and coastal defence. Therefore, integration of the flood and coastal defence management sector needs to be complemented with improved working practices within and between that sector and land use planning authorities together with catchment management that promotes sustainable water use.

An effective system of administration would:

— integrate coast protection, flood defence and drainage;

— plan and act strategically in the widest public interest;

— integrate the management and restoration of fluvial and coastal systems with defence and risk management; and

— be orientated towards providing environmental and socio-economic dividends in tandem with managing risk.

The products of such a system would be:

— more sustainable and cost effective flood and coastal defences with a reduction in public expenditure;

— better protection of human life and urban areas;

— habitat conservation and restoration in line with UK's commitments and obligations;

— improved landscapes with a greater capacity to provide a wide range of socio-economic benefits;

— less intensive farming in flood plains and improved fisheries; and

— a general improvement in environmental quality.

6.4 The present system has a clear bias in favour of agricultural interests and against environmental interests. It also carries the legacy of professional attitudes and approaches that are outdated by changing circumstance in society and an improved scientific understanding of coastal and river systems. Any change that fails to replace the old biases, attitudes and approaches with a more modern and balanced institutional framework is unlikely to be successful.

7. RECOMMENDATIONS

7.1 For many years The Wildlife Trusts and WWF-UK have advocated the case for a holistic and integrated approach to coastal and river management. We continue to believe that the very real imperative of protecting people from flooding can best be served by taking a long-term strategic approach to the management of coastal areas and flood plains. Strategic and balanced planning of flood and coastal defence management will need to review and, where necessary, reverse past policies and practices in order to be effective. Only by the integration of flood and coastal defence management with environmental objectives will it be possible to turn around the unsustainable and increasingly expensive legacy described above.

7.2 Our specific recommendations are as follows:

— Integration of coast protection, flood defence and drainage in a single authority[

— That authority to employ the necessary interdisciplinary expertise to ensure the implementation of these plans;

— Strengthened integration between flood and coastal defence management and land use planning with the former able to veto development in the risk zone;

— Flood and coastal defence project appraisal to be judged primarily on conformity to integrated strategic objectives;

— A review of the cost benefit appraisal system to ensure that environmental benefits and cost of all possible alternatives are properly considered;

— A change in the policy of spending public money on the protection of property per se, with particular reference to farmland;

— Give powers to the defence authority to remove defence structures for which it is responsible where this is in the interest of strategic flood and coastal defence management and nature conservation.

REFERENCES

Biodiversity: The UK Steering Group Report (2 volumes) (Cm 2428) HMSO (1995).

Costanza, R d'Arge, R de Groot, R Farber, S, Grasso, M, Hannon, B, Limburg, K Naeem, S, O'Neill, R, Paruelo, J Raskin, R G Sutton, P & van der Belt, M (1997). The value of the world's ecosystem services and natural capital. Nature, Vol 387, 15 May 1997.

Desbonnet, A, Lee, V., Pogue, P, Reis, D, Boyd, J, Willis, J, & Imperial, M (1995). Development of Coastal Vegetative Buffer Programmes. Coastal Management, Vol 23, pp. 91-109.

Desbonnet, A Progue, P Lee, V & Wolff, N (1994). Vegetated buffers in the coastal zone: A summary review and bibliography. Coastal Resources Center Technical Report No. 2064. Narragansett, RI: University of Rhode Island Graduate School of Oceanography.

English Nature (1997). Wildlife and Freshwater—an agenda for sustainable management. EN

Environment Agency (1997). An Environmental Strategy for the Millennium and Beyond. EA Bristol.

Environment Agency (1997). Policy and Practice for the protection of floodplains. EA Bristol.

Environment Agency (1998). River Habitat Survey Report No. 2 March 1998.

MAFF (1993) Strategy for Flood and Coastal Defence in England and Wales.

National Rivers Authority (1995). A guide to the understanding and management of salt-marshes. R&D Note 324. NRA Bristol.

Pye K, & French, P W (1993) Targets for coastal habitat recreation. English Nature Science No 13. English Nature. Cambridge Environmental Research Consultants Ltd. Report ES21.

Rendal Geotechnics (1998). Investigation and Management of Soft Rock Cliff. MAFF.

FIGURES

Ecosystems most likely to be affected by flood and coastal defences are blocked in black.

g C/m2/yr = gram of carbon per square meter per year; the figures have been derived from dry biomass and converted to carbon on the assumption that biomass is 45 per cent carbon. (Whittaker, R H, and Likens, 1973. Carbon in the biota. In Woodwell, G M, and Pecan, E V (eds) Carbon and the Biosphere. Washington DC.)