House of Commons - Environment, Food and Rural Affairs

Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by the RSPB (FL 118)

1. SUMMARY

— The RSPB believes that operating authorities need a wider range of mechanisms to control growth in flood risk in a socially equitable, cost-effective and environmentally sustainable manner.

— The RSPB calls on government to take decisive action in its Climate change Bill to reduce our emissions of green house gasses by 80% by 2050.

— The RSPB believes that restoring river corridors and creating wet washlands will bring multiple benefits for flood risk, diffuse pollution control, biodiversity, landscape and amenity.

— The RSPB believes that the management of soils, vegetation and water storage in the rural landscape should be seen as the "first line of defence" against flooding.

— The RSPB calls for a fundamental overhaul of the funding and governance structures of drainage authorities to ensure Government investment delivers the greatest public benefits.

— The RSPB calls on Government, The Environment Agency and Local Authorities to protect floodplains from development.

— The RSPB calls on Government to address legal uncertainty over water company responsibility for the adoption and maintenance of SUDS.

2. THE IMPACT OF FLOODS ON PEOPLE AND WILDLIFE

2.1. As recent events have shown, flooding can have a devastating impact on communities, individuals and businesses, often lasting long after the waters have subsided. Although the greatest economic damage occurs in towns and cities, the impact and anxiety caused is no less real for those affected in more isolated rural locations, where it is often difficult to justify construction and maintenance of defences on economic grounds.

2.2. Wildlife can also suffer from floods. The RSPB reserve at Minsmere in Suffolk, for example, lost all but one of its bittern nests this year, a potentially serious impact upon the total UK population. At the same site, rare purple herons were prevented from nesting after the rainfall in May. In Cambridgeshire, over 500 pairs of wading birds were flooded out of the Ouse Washes.

2.3. There are other, less obvious environmental consequences of flooding. Raw sewage or other pollutants often contaminate floodwater, particularly where industrial complexes are inundated. This cocktail of chemicals from transport, industry and agriculture can have long-term implications for species and habitats[40].

2.4. Of course, flooding is an essential element of natural ecosystems and even in the heavily modified rivers and wetlands of England, this summers floods brought winners as well as losers. For instance, re-wetting after the dry April enabled early breeding wading birds to fledge successfully, and waterfowl appear to have been productive on the additional areas of shallow floodwater. However there is little doubt that the resilience of wetland species has been severely compromised by land drainage and flood defence policies that have destroyed, fragmented and isolated wetland habitats.

3. WHY FLOODS HAVE BECOME A PROBLEM

Climate change

3.1. Historic emissions of greenhouse gases have already committed us to a changing climate. The European Environment Agency[41] has reported that in the UK we are likely to face increased overall rainfall in winter and more frequent and severe storms throughout the year.

3.2. The Government's Foresight Future Flooding report[42] makes a clear case for the escalating likelihood and costs of extreme flood events to 2080 under any of the IPPC scenarios. Although this has been widely accepted in the scientific community, the UK government's climate, energy, transport and land use policies are not yet sufficiently integrated to tackle the many ways in which we all contribute to climate change.

Floodplain wetland fragmentation

3.3. Wetlands support a wealth of biodiversity and can provide a range of ecosystem services including pollution control and floodwater storage[43]. However, centuries of land drainage and flood defence have destroyed all but a few fragments of England's wetland ecosystems often leaving them isolated from rivers and each other. This has not only reduced the capacity of river corridors to store water and mitigate flooding. It has also made wetland wildlife increasingly vulnerable to catastrophic flooding as, faced with rising flood water levels, even relatively mobile species such as birds have little opportunity to find refuge in the surrounding landscape.

Rural land management

3.4. There is little doubt that farming has changed in ways that could be hydrologically significant such as:

— loss of hedgerows and larger fields

— cultivation practises compacting soils reducing their water storage capacity

— land drains connecting the hill top to the channel

— cracks and mole drains feeding overland flow to drains and ditches

— unchecked wash-off from bare soil

— plough lines, ditches and tyre tracks concentrating overland flow

— tramlines and farm tracks which convey run-off quickly to watercourses

— channelised rivers with no riparian buffer zone

3.5. Defra-sponsored research into flooding and land management[44] found substantial evidence linking agricultural intensification with surface run-off at a local scale. Although run-off of soil and water is not likely to be seen as a problem by farmers[45], the effect on those impacted by "muddy flooding" can be devastating. In his paper on muddy flooding in the South Downs, Butler[46] assessed the impacts of the floods of winter 2000 in seven local settlements: property damage was estimated at £1 million, with traffic disruption and clean-up operations running to £5 million.

3.6. Although the local impacts are clear, the same Defra research found little direct evidence linking changes in land management to increasing flood risk at a catchment scale. However it is important to note that the authors stress this may be because there have been very few studies.

3.7. This remains a very active area of research and work carried out by WWF Scotland[47] points to a very positive relationship between flood generation and the management of the river Devon and its catchment.

Land drainage and river engineering

3.8. Historically, the over-riding emphasis of land drainage policy has been to move water off land into rivers and out to sea as quickly as possible. Defra's review of land use and flooding touched briefly on this issue and cited a study by Baily and Bree[48] which demonstrated that flood peaks were 60% higher on rivers that have been arterially drained in comparison with unmodified rivers. Similarly, Robinson[49] showed that whilst the impact of sub-surface land drains is dependent on soil type, overall

"studies of flow records from individual catchments indicate that the combined effect of field drainage and arterial works is to increase streamflow peaks (and dry weather flows) whether or not maximum flows are increased or decreased at the field scale. At the regional scale artificial drainage was a statistically significant parameter shortening catchment responses times."

3.9. Therefore, while land drainage and river engineering may be effective in reducing water levels and flood damage at a local scale, there is little doubt that the loss of natural attenuation through floodplain storage increases the speed and size of flood peaks as they propagate downstream.

Urban planning

3.10. Rivers and floodplains have attracted settlements for millennia leaving a long legacy of building floodplain development and defence. The growth in value of defended land (both because of increased prosperity and new development) makes the economic justification of defences easier while the construction/improvement of defences encourages further development. This self-perpetuating loop locks society into escalating costs as maintenance and improvement struggle to keep pace with climate change and sea level rise. The apparent control of flooding also hides a growing residual risk that must be dealt with when, inevitably, defences fail or are overtopped.

3.11. Urban areas are not just at risk from river and coastal flooding. British towns and cities rely on drains and sewers to dispose of surface water and, as the flooding in Hull demonstrates, when these are overwhelmed the damage can be devastating. Damage from intra-urban or pluvial flooding is set to grow dramatically as our ageing sewer and urban drainage infrastructure struggles to cope with connections from urban expansion and, most significantly, the heavier rainfall associated with climate change.

4. WHAT NEEDS TO BE DONE

4.1. A portfolio of responses: The RSPB believes that operating authorities need a wider range of mechanisms to control growth in flood risk in a socially equitable, cost-effective and environmentally sustainable manner.

4.2. The Government's Foresight report highlighted how climate change could drive flood risk to unacceptably high[50] levels. Relying on hard defence and flood warning will do nothing to tackle underlying drivers of rising flood risk and are unlikely to be cost effective, socially equitable or environmentally sustainable into the long-term.

4.3. As a result we believe it is time for the portfolio of measures described in the Government's strategy "Making Space for Water" (MSfW) to be translated into action. We envisage a system that continues to prioritise areas where flood risk poses the greatest social, economic or environmental problems but where the selection of the solution is aided by cost-effectiveness analysis looking at a broad range of options to reduce flood risk and deliver wider Government policy objectives including:

— Land use change

— Increasing housing and infrastructure resilience

— Flood defence schemes

— Migration of assets (e.g.: of caravan parks or property)

— Flood and coastal erosion assurance schemes.

— Purchase of property.

4.4. These may not all be directly funded by the Environment Agency, Defra or even Government, but they must work in an integrated manner to reduce risk.

Tackle climate change: The RSPB calls on government to take decisive action in its Climate change Bill to reduce our emissions of greenhouse gasses by 80% by 2050.

4.5. The Foresight study makes it clear that reductions in emissions across all sectors of society would substantially help to manage future flood risk[51]. We have now reached a point where urgent mitigation and adaptation are required to address the climate crisis, and it is widely acknowledged that for the UK to contribute its share in keeping global warming below a 2 degree average, we must reduce our emissions by 80% from the 1990 baseline by 2050. This commitment must be made now, on the face of the Climate Change Bill.

4.6. Restore floodplains and river corridors and create wet washlands for multiple benefits: The RSPB believes that restoring floodplains, river corridors and creating wet washlands will bring multiple benefits for flood risk, diffuse pollution control, biodiversity, landscape and amenity.

4.7. Although the impact of river and floodplain restoration is site specific, in general it offers an opportunity to slow the movement of water and increase storage in a catchment. In general this will bring give communities more time to respond to flood warnings and increase resilience and effectiveness of existing defences, particularly in the face of climate change.

4.8. Wetland creation and the "re-naturalising" of river corridors will also play a key role in helping wildlife adapt to a changing climate, providing corridors for species to move through and creating a network of semi-natural wetlands for populations to disperse to in response to cycles of drought and flood.

4.9. Connectivity between floodplains and rivers has also been shown to be extremely important for fish, riverine invertebrates and plants[52]. Creating a more natural flooding regime in some rural areas could be important for restoring a thriving river ecology and achieving the objectives of the Water Framework Directive.

4.10. Of course there is nothing new about using storage as a tool for flood risk management and there are a number of urban areas that rely on engineered "washlands" for their defence. Historically these have been designed to remain dry in order to maximise storage at the expense of biodiversity. However, as the Agency/RSPB scheme at Beckingham Marshes shows, the creation of wet washlands offers significant potential for habitat creation, contributing to the delivery of UK priority BAP targets alongside flood risk management; in effect delivering multiple land use outcomes.

4.11. Reward responsible land management: The RSPB believes that the management of soils, vegetation and water storage in the rural landscape should be seen as the "first line of defence" against flooding.

4.12. Filling the evidence gaps on catchment scale effects of land use and management change should be a priority for Government's response to the floods of 2007. The lack of direct evidence must not be used to justify inaction but instead encourage an adaptive approach that allows the flood risk and land management community to "learn by doing". Such an approach could benefit people across a catchment, not just those communities that qualify for hard defences, and the measures could also benefit biodiversity, diffuse pollution control amenity and landscape.

4.13. Flood risk management is identified as a secondary objective of the existing Environmental Stewardship scheme and many of the options have the potential to deliver some benefit for run-off control. However, it cannot be assumed that the application of the current Environmental Stewardship scheme will automatically deliver significant flood management benefit by default. Where success in controlling muddy flooding has been reported, this was achieved through the direct targeting of measures including the use of set aside[53], an option which is no longer available to farmers.

4.14. That is not to say that the current cross-compliance and agri-environment model cannot be adapted to deliver run-off control and local flooding benefit. However, it is important to recognise that the current budget is limited and that there is little scope for increasing the range of objectives without undermining delivery of current SSSI PSA targets, Natura 2000 condition and biodiversity targets. Any new or extended scheme for flood risk management would require significant new funds to be made available to the Rural Development Programme through treasury, modulation and, ultimately, further reform of the Common Agricultural Policy.

4.15. Manage rural land drainage for maximum public benefit: The RSPB calls for a fundamental overhaul of the funding and governance structures of drainage authorities to ensure Government investment delivers the greatest public benefits.

4.16. There is little doubt land drainage will continue to play a significant role in managing flood risk in certain locations. However it is estimated that 500,000 hectares of agricultural land are currently defended where it is uneconomic to do so, while drainage and inappropriate ditch management have been identified as among the top ten issues impacting on SSSI condition by land area. Given this background, it would be difficult to argue that the governance or practice of land drainage is fit for purpose today, let alone ready to take on the challenge of climate change.

4.17. We see a new role for operating authorities with the emphasis shifted from simple "drainage" to "water level management" that delivers the greatest benefits to society rather than perpetuating historic practices and local interests. This step change in approach will be a challenge for the Environment Agency and require a fundamental overhaul of funding and governance structure of Internal Drainage Boards.

4.18. Avoid development in areas of high flood risk: The RSPB calls on Government, The Environment Agency and Local Authorities to protect floodplains from development.

4.19. The RSPB supports the tougher policy on development and flood risk signalled under PPS25 and its supporting guidance. In particular, we welcome new call in powers for the Secretary of State where Environment Agency advice is ignored. However, we are concerned a significant gap still exists between the policy and practice. For example in the Aylesbury designated growth area for instance, 11% of the housing will still be built in high-risk areas beyond the ABI's guarantee of affordable insurance[54].

4.20. This "business as usual" approach simply stores up problems for the future for the sake of expediency now.

4.21. Drain urban areas with sustainable drainage systems: The RSPB calls on Government to address legal uncertainty over water company responsibility for the adoption and maintenance of SUDS.

4.22. Modern British towns are essentially impervious to water but this does not need to be the case. A number of UK and international examples have demonstrated how, rainwater recycling, green roofs, settling ponds and porous paving can play a role in storing and cleaning water before passing it on, at a controlled rate, to rivers[55]. These "Sustainable Urban Drainage Systems (SUDS) also offer improved amenity in the urban landscape and, unlike traditional piped systems, they can be designed to fail safe so that residents have ample warning before their capacity is exceeded.

4.23. Despite the obvious advantages of SUDS, their use in England remains the exception rather than rule. One of the key stumbling factors is that SUDS do not fall within the legal definition of "sewers", so water companies are not able to adopt their ownership and maintenance easily. We call on Government to address this at the earliest opportunity.

5. THE WAY FORWARD

5.1. As the Government's "Foresight" report noted, public opinion and "outrage" expressed in the wake of a widespread disaster can be significant factors in policy development. We are concerned that recent flood events will put pressure on government to apply short term "fixes" to flooding by reverting to the more "visible" option of raising defences, increasing channel dredging and the improving the "efficiency" of rural drainage networks. This "business as usual" model will do nothing to tackle fundamental issues underlying the growth of flood risk, will lead to further damage the environment and, ultimately may exacerbate problems now and into the future.

Instead the RSPB calls on Government to accelerate delivery of the reforms promised by Making Space for Water. Only then will the benefits of sustainable flood risk management be recognised by the public.

RSPB

September 2007

40 Howe, J. and White, I. (2003) Flooding, pollution and agriculture; International Journal of Environmental Studies, 60, 1, pp19-27, and D'Arcy et al, (2000), Diffuse pollution impacts: the environmental and economic impacts of diffuse pollution in the UK, CIWEM publication. Back

41 European Environment Agency Report No. 2/2007 "Climate change and water adaptation issues". Back

42 Foresight Future Flooding, Office of Science and Technology: www.foresight.gov.uk Back

43 See Millenium ecosystem Assessment (2005) Ecosystems and Human Wellbeing: Wetlands and Water. Back

44 O'Connell et al (2004), Review of impacts of rural land use and management on flood generation Defra Publication FD2114. Back

45 Morris, J. and Parkin, A. (2004) Review of impacts of rural land use and management on flood generation: Annex D: Socio-economic dimensions of flood generation from agricultural land. Joint Defra/EA Flood and Coastal Erosion Risk Management Report available on Defra Website. Back

46 Butler, J. (2005). Muddy Flooding on the South Downs, online papers archived by the Institute of Geography, School of Geosciences, University of Edinburgh. Back

47 WWF (2007) Floodplanner: A manual for the natural management of rivers and floods, WWF report. Back

48 Bailey, A.D and Bree, T (1981) The effect of improved land drainage on river flood flows, in The Flood Studies Report; five years on, ICE, London, pp131-42. Back

49 Robinson, M (1990) Impact of improved land drainage on river flows Institute of Hydrology Report No. 113. Back