Memorandum by the Environment Agency (CT
50)
SUMMARY
The Environment Agency supports the sustainable
development of coastal towns to ensure their social and economic
viability and safety from environmental risks. Coastal towns and
their communities now face significant environmental challenges
from climate change and sea level rise in addition to the social
and economic challenges that face them.
— Scientific studies demonstrate that
climate change and sea level rise is an increasing threat to many
coastal settlements.
— Coastal habitats are rich in wildlife—a
significant proportion are protected by European Environmental
Directives. They are vulnerable to sea level rise and are of great
value to coastal protection. Policies that ensure the maintenance
and increase in these habitats are vital.
— The Environment Agency believes that
strategic policies and plans, including those for coastal towns
and communities, must take full account of long-term change and
the increasing risk of flooding and coastal erosion.
— Close co-operation between the Environment
Agency, Defra, ODPM, Local Planning Authorities and Regional Government
on strategic planning and investment decisions is essential for
the sustainable regeneration and redevelopment of coastal towns.
— The Environment Agency strongly recommends
that plans for coastal redevelopment, only be promoted where they
fully support the aims and policies of strategic planning frameworks
such as Shoreline Management Plans, Estuary Strategies and River
Basin Management Plans, especially for the maintenance and increase
in vital coastal habitats. This means the implications of those
strategic planning frameworks need to be better understood by
spatial (land use) planners and those making spatial planning
decisions.
— The challenge of future coastal flooding
and erosion will require consideration of innovative and maybe
radical solutions where coastal communities can no longer be sustained.
Existing spatial planning policy guidance (PPG20 Coastal Planning)
and coast protection legislation may need to be reviewed to reflect
the new challenges of climate change and sustainable development.
We welcome the consultation on draft Planning Policy Statement
PPS25 Development and Flood Risk—the ODPM is currently
considering consultation responses on this draft PPS.
1. INTRODUCTION
The Environment Agency is the Government's lead
agency for managing flood risk and depending on the Government's
new strategy for flood and coastal erosion risk management in
England, the Environment Agency may also become the lead agency
for coastal erosion risk management. It is also the sole competent
authority for implementing the Water Framework Directive and a
consultee for much of the land based spatial planning process.
Coastal towns will face increased risk from
unavoidable flood and erosion. How to support sustainable development
on such coastlines and protect internationally designated coastal
habitat and landscape is a major challenge for Government, planning
authorities and communities. Traditional approaches to investment
in coastal infrastructure have often left an expensive legacy
of maintenance. The Environment Agency is leading new thinking
on how to plan and deliver long-term sustainable solutions in
partnership with communities, and can contribute across the whole
spectrum of coastal investment policy.
2. SCIENCE TO
UNDERPIN PLANNING
AND DECISION
MAKING
The Government has funded a programme of science
research to evaluate the effects of climate change. Particular
emphasis has been on how sea level rise will impact our coastline
and the communities who live and work there.
2.1 The Foresight Flood and Coastal Defence
Project[69]
This £1 million study involving 40 researchers
and sophisticated computer models of climate and coastline has
confirmed that even under the most positive scenario, in which
the world takes substantial steps to reduce the impact of climate
change, the impact on the United Kingdom will be great.
Flood risk will rise by at least 30% around
our southern and eastern coasts. Under worst-case scenarios coastal
areas will become 30 times more vulnerable to devastating wave
surges, raising the annual economic costs of flooding from £1
billion to more than £20 billion. By 2080 the UK could be
facing major flood events once every three years compared to every
one hundred years in the past.
Because of the nature of this threat, it is
essential that any decision on how we respond to coastal change,
or plan to invest in areas that will be affected, must take full
account of our latest scientific forecasts on flood risk and coastal
erosion. In some instances this will mean retreating from existing
defences to allow habitat creation and room for estuaries to expand
in order to reduce flood risk overall.
A significant length of our coastline is internationally
important for wildlife, has enormous value in reducing flood defence
costs through wave energy absorption and is at great risk of loss
to coastal squeeze. Coastal squeeze occurs as sea level rises
against fixed defences and consequently reduces the area of inter
tidal habitat. Apart from the flood defence imperative, European
and UK wildlife law insists that such habitat is replaced which
largely has to be achieved through retreating existing defence
lines across agricultural land.
3. THE IMPORTANCE
OF STRATEGIC
PLANNING
Owing to the increased threat from sea level
rise and coastal erosion, and the need to invest public funds
wisely, a nationally consistent approach to coastal risk management
and decision making is essential. This must start with a science
based planning approach to future coastal defence and erosion
protection, which in turn will drive decisions about future sustainable
development. Close co-operation between government departments,
particularly ODPM and Defra is essential alongside regional and
local government and the Environment Agency.
3.1 Shoreline Management Plans
Shoreline Management Plans (SMPs) are the primary
strategic planning mechanism for flood and coastal risk management,
combining scientific analysis, environmental assessment, socio-economic
assessment and community engagement. These plans provide a strategic
assessment of the threat to the coast and coastal towns from flooding
and coastal erosion and recommend the most sustainable management
options over the next 100 years considering the potential impacts
of sea level rise. Coastal groups comprising the Environment Agency,
local authorities, English Nature (Natural England) and Defra,
in consultation with coastal communities, will have fully reviewed
all SMPs by 2010. This review will incorporate the latest scientific
findings on climate change and decide the preferred management
policy for coastal risks over the next 100 years including managed
realignment where prudent so to do. The Government strategy for
flood and coastal risk management in England called Making Space
for Water may give the Environment Agency a national strategic
overview for all flood and coastal erosion risk management. Such
a move should ensure that all SMPs are consistent in their approach
to coastal planning issues.
3.2 Coastal and estuary strategies
These strategies consider how best to implement
the SMP coastal management policies. They undertake a more detailed
feasibility assessment of the practical solutions and identify
where viable actions can be taken to reduce the risks from flooding
and coastal erosion. These strategies promote detailed community
engagement and work with landowners, industry, councils and voluntary
organisations to promote measures such as coast/sea defences,
flood resilience and alternative land management to adapt to a
changing coastline.
3.3 River Basin Management Plans
The Environment Agency is the competent authority
for implementing the Water Framework Directive in the UK. The
Directive seeks to achieve "good status" for all water
bodies in environmental terms, and this includes coastal waters.
River Basin Management Plans (RBMPs) will be key strategic planning
mechanism in helping identify and deliver environmental improvements
for coastal towns and communities. The River Basin Management
Plans will identify a statutory Programme of Measures (action
plans). All government departments, RDAs and local authorities
will be important partners in delivering these RBMP action plans.
These plans will need to influence and take into account SMPs.
The government's future policy for regenerating
coastal towns must take full account of the Government's strategic
planning priorities for managing coastal flood and erosion risk.
Shoreline Management Plans provide a focus for the science and
socio-economics of long term sustainable coastal policy, and must
be fully reflected in any plans for future funding for social,
housing or environmental regeneration. There is also an urgent
need for a port strategy to balance expanding port development
pressures with the need for an integrated planning approach for
our coast and shoreline. Such measures are essential to ensure
a balanced approach to obligatory and necessary habitat creation
and maintenance alongside economic development. Any increased
development affecting coastal habitats will certainly be required
to provide additional compensatory land. This will need to be
considered in land use (spatial) allocation through the various
planning processes.
3.4 Spatial Plans—Regional Spatial Strategies
and Local Development Frameworks
Spatial development in coastal towns and communities
will be driven by spatial plans—Regional Spatial Strategies
(RSS) and Local Development Frameworks (LDFs). These plans are
to be soundly evidence based and subject to sustainability appraisal,
incorporating Strategic Environmental Assessment. Such appraisals,
and the plan evidence base, must take full account of strategic
coastal planning frameworks such as SMPs and RBMPs, including
emerging work on those frameworks where final plans are not in
place. It may be necessary to review RSS and LDFs on final publication
of SMPs and RBMPs. Above all, the complex relationship of plans
in the coast means that the implications of coastal strategic
planning frameworks need to be much better understood by spatial
planners and those taking spatial planning decisions.
It is essential that coastal spatial planning
issues are effectively dealt with at a strategic level. RSS should
provide a strategic approach to the spatial development and re-development
of the coast with LDFs being in conformity with it. Coastal planning
authorities should liase closely in developing their LDFs to ensure
they are consistent with other LDFs along the coast
Planning Policy Guidance note PPG25 indicates
that "it should be recognised that climate change is expected
to increase flood risk and some existing development in more exposed
locations may not be sustainable in the longer term and may need
to be replaced in safer locations. Local planning authorities
should consider ways in which the planning system might be used
positively to help tackle the legacy of past development in unsustainable
locations" (PPG25, paragraph 9). In preparing their LDFs
local planning authorities need to effectively address such difficult
challenges.
PPG25 is in the process of being reviewed. We
welcome the consultation draft of PPS25 and the continuing emphasis
it places on the sequential test—the objective of locating
new development in areas of lowest flood risk—and using
strategic flood risk assessments to search for suitable development
sites. The new PPS needs to reiterate the previous advice (above)
in PPG25 in respect of existing development.
The existing Planning Policy Guidance note PPG20
Coastal Planning was published in September 1992. It may now need
to be reviewed to reflect increased understanding of the potential
impact of climate change on the coast and the associated challenges
of achieving sustainable development in coastal locations.
4. INNOVATION
AND PARTNERSHIP
TO DELIVER
SUSTAINABILITY
Because of the escalating storminess arising
from climate change, traditional coastal engineering solutions
may no longer be appropriate. The erosive forces are greater and
more persistent. Extreme events are likely to occur more often
and place even more people and coastal communities at risk from
flooding and coastal erosion. Many of our traditional hard defences
are increasingly being undermined and overtopped, and when they
fail it is often catastrophic. Building bigger does not solve
this problem; it merely buys time and places an escalating financial
repair and maintenance burden on the public purse. We need to
find more affordable and sustainable approaches to managing these
risks around our coastline. Examples will include restoring inter
tidal marshes, sand dunes and shingle ridges to provide a natural
coastal buffer zone. This will include no longer maintaining some
of the rural defences around our coastline where economics and
environmental objectives must be achieved.
Whilst coastal agricultural land has an existence
value its greater future role may be in providing vital increased
flood and coastal erosion protection capacity. Retreating to historic
coastlines even in developed areas will in some places be the
only sustainable option.
5. APPROPRIATE
POWERS AND
PLANNING MECHANISMS
Some coastal legislation, policy and practice
no longer fully reflect the need given the challenges posed by
sea level rise and climate change. Legislation, for example the
Coast Protection Act 1949, Land Drainage Act 1976 and the Food
and Environmental Protection Act 1985 need to be replaced with
a combined Act, providing more flexible powers to the Environment
Agency and coastal authorities to reflect the challenge of sea
level rise and coastal erosion. Similarly, PPG20 is now 14 years
old and may require updating.
This problem is recognised in the Government
strategy for flood and coastal risk management, Making Space for
Water. The work streams that underpin Making Space for Water include
analysis of the barriers to sustainable development and one on
adaptation toolkits. This will consider the adaptation of policy
and legislation needed to address necessary but controversial
decisions made on the coast, such as setting back of defences
or coastal cliff erosion leading to property loss. The Environment
Agency is actively contributing to these programmes. Delivering
new strategic solutions to support coastal communities during
a time of adaptation and change will demand streamlined and innovative
legislation and we look forward to the results of the current
work and on its consequential delivery. Key policies promoted
in Making Space for Water include, a single authority for overseeing
the management of the coast, better mapping of coastal erosion
and flood risk, one body with an overview of all flooding (including,
urban, highway, sewerage and groundwater), improved mechanisms
for funding and planning the future of the coast, better acknowledgement
of the multiple benefits that can accrue to society from flood
risk management expenditure, and different approaches to land
management in upper reaches of river systems to reduce flooding
problems lower down the river.
6. RECOMMENDATIONS
6.1 The Select Committee recognises the
importance of understanding the future effects of climate change
and sea level rise, and adopts the scientific recommendations
of the Foresight Report as a foundation for any new initiative
to help sustainable regeneration or redevelopment of coastal towns.
6.2 Shoreline Management Plans, coastal
and estuary strategies, River Basin Management Plans and spatial
plans are recognised as key strategic plans in the formulation
of regional and local regeneration or redevelopment initiatives.
This needs to be reflected through effective integration of these
plans and a review of existing spatial planning policy , for example
the potential production of a new style Planning Policy Statement
on Coastal Planning.
6.3 The Environment Agency is recognised
as a source of expertise in the development of innovative coastal
solutions and as the key body to oversee the strategic management
of the England and Wales coast.
6.4 The Select Committee supports the approach
in Making Space for Water and the issues listed in 5 above, especially:
— The need for new legal measures to
update existing legislation and provide greater powers to control
land use in flood and erosion risk areas.
— More integrated policy and process
to assist the delivery of sustainable coastal management in response
to increasing sea level rise and coastal erosion.
— Recognition that the coast supports
internationally important habitats and species. These areas may
provide protection for the coast, and the communities that live
there, but are sometimes at risk from unsustainable development
— That new and innovative approaches
are investigated to facilitate coastal erosion and managed realignment
where it is appropriate to do so.
— Due to the complex relationship of
plans in the coast, the implications of coastal strategic planning
frameworks need to be much better understood by spatial planners
and those taking spatial planning decisions.
— Recognises and promotes the huge
value of coastal habitats and the economic, social and biodiversity
drivers for their maintenance and enhancement.
69 Future Flooding, Foresight Programme, DTI, 2004. Back
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