Memorandum submitted by Natural England
(FL 102)
EXECUTIVE SUMMARY
1. Increasing frequency of severe rainfall
events and rising sea levels due to climate change, mean that
we have to adapt our approach to flood defence. Traditional methods—building
concrete and earth embankments—may no longer be adequate
or sustainable.
2. Natural England's view is that multi-objective
schemes at the level of catchments, estuaries and coastal cells,
which work with—rather than against—natural processes,
should be more widely implemented through the Environment Agency's
flood-risk management programme. Integrated schemes, which take
account of catchment functioning, bring added benefits to biodiversity,
landscape and amenity, pollution reduction and carbon storage.
3. River restoration, floodplain storage,
blocking of moor grips and re-alignment of defences are key elements
of a catchment approach. Natural England is participating in pilot
projects on these separate elements. Appropriate land management
and drainage systems are important in reducing run-off and soil
erosion.
4. Catchment measures are unlikely to prevent
the sort of unprecedented floods that have occurred recently (1
in 1,000 year events), though they should reduce their intensity
and impact. In these circumstances, adaptation becomes important.
The flood management capital programme should include funding
for adaptation measures (eg as well as moving assets, such as
water-treatment plants and vulnerable dwellings, out of areas
of high flood risk). Planning control needs to be more robust
in refusing inappropriate new build in these areas (in accordance
with Planning Policy Statement 25).
5. Natural England fully supports the Government's
policy, as expressed in its response to Making Space for Water
(2005), to pursue a more strategic approach, and move to a wider
portfolio of responses to flood risk—with greater use of
rural land-use solutions, such as creation of wetlands and washlands,
coastal realignment, river-corridor widening and river restoration.
6. Shoreline Management Planning (SMP) was
formally introduced in 1995 and Catchment Flood Management Planning
(CFMP) in 2002, but we are disappointed that there has been very
little action on the ground in terms of integrated flood management
schemes. Managed re-alignment of sea defences in the Humber Estuary,
completed in 2006, is the only example of a strategic-scale flood
management scheme. We explore the reasons for inaction on sustainable
approaches and propose the following action:
6.1 Deadlines should be set for implementation
of integrated schemes identified in SMPs and CFMPs, and of the
policy to withdraw maintenance of uneconomic defences announced
in 2004;
6.2 A significant proportion of the EA's
flood-risk management budget should be earmarked for "sustainable"
schemes; and
6.3 Projects under Defra's Making Space
for Water should be prioritised, and those informing "integrated
schemes" should be completed and put into practice within
the next year.
INTRODUCTION
7. Natural England is a statutory body created
in 2006 under the Natural Environment and Rural Communities Act
by bringing together English Nature and parts of the Rural Development
Service and the Countryside Agency. Natural England has been charged
with the responsibility to ensure that England's unique natural
environment, including its flora, fauna, land and seascapes, geology
and soils are protected and improved. Natural England's purpose,
as outlined in the Act, is to ensure that the natural environment
is conserved, enhanced and managed for the benefit of present
and future generations, thereby contributing to sustainable development.
IMPACTS OF
CLIMATE CHANGE
AND INTENSIVE
LAND USE
8. More intensive rainfall at different
times of the year, including the summer, is leading to flash flooding.
Rainfall runs off drained upper catchments, with soils compacted
by intensive stocking of sheep, and removes topsoil from the ploughed
soils of river valleys. The soil ends up as silt in streams, rivers
and lakes, reducing their biodiversity and water-conveyancing
capacity. Run off follows drainage systems through farmed fields,
along tracks and roads—normally discharging into streams
and rivers. In urban areas, water runs off concrete and paved
surfaces, and can overload drainage systems.
9. At the coast, sea-level rise is exacerbated
by melting of ice caps and glaciers, caused by global warming.
Intertidal habitats, such as saltmarsh which can absorb wave action,
are squeezed in front of sea-defences. In Essex alone, 50 hectares
of saltmarsh are lost to coastal squeeze every year.
IMPACTS OF
FLOODING ON
THE NATURAL
ENVIRONMENT
10. In Natural England's view, undue emphasis
has been placed on possible harmful effects of flooding on the
natural environment, often to justify building new or higher flood-defence
structures, which are likely to be damaging to the natural functioning
of ecosystems. Some habitats and wildlife have suffered as a result
of the recent summer floods (e.g. the hay meadows in the valley
of the Yorkshire Derwent), but this is not due to inadequate flood
defences—rather to the habitats having adapted to an embanked
river and a system of floodplain drainage channels, with some
winter flooding.
11. By their very nature, floodplains evolved
to absorb overflow from river channels. Before they were drained
for agriculture and urban areas, they were habitats for a rich
variety of wetland wildlife. In England, only a few areas of floodplain
habitat remain, mostly in nature reserves. Wetland creation projects,
such as the Great Fen in Cambridgeshire, are seeking to utilise
flood waters to re-wet agricultural land.
A CASE FOR
DEVELOPING MORE
SUSTAINABLE STRATEGIES
12. Natural England believes there is a
strong case for strategic approaches (at catchment, estuary or
coastal-cell level) and integrated flood-risk management schemes
that work with natural processes, rather than sole reliance on
traditional concrete or earth embankments. In the face of climate
change, we advocate adaptation—recognising that locating
housing and infrastructure in high flood-risk areas is increasingly
unsustainable. The Environment Agency website states "the
best way to reduce the risk of flood is to focus on ways that
work with nature, not against it, such as constructing flood barriers"—we
agree.
13. Land uses and management practices that
are "flood friendly" are usually also beneficial to
soil conservation, landscape, biodiversity, woodland management,
pollution reduction and carbon storage. They are not a replacement
for, but a complement to flood defences protecting particular
assets.
KEY ELEMENTS
OF AN
INTEGRATED APPROACH
14. River restoration: removal of in-channel
structures has multiple benefits. A current example is the River
Wensum, a European Special Area of Conservation (SAC) in Norfolk,
where the removal or lowering of three redundant mill weirs is
seen as the most cost-effective solution to flooding problems
in the upstream villages. This is also a key step in a river restoration
plan for the River Wensum SAC, 67% of which is backed up from
such structures. This is the first whole-river restoration strategy
in England. It is led by Natural England, in partnership with
the Environment Agency and the Norfolk Rivers IDB. It has synergies
not only with the flood-management strategy, but also with the
Fisheries Action Plan and the Wensum Catchment Sensitive Farming
(CSF) project.
15. Morphological impacts are recognised
in the Water Framework Directive, and a programme of physical
restoration on 18 river SACs and SSSIs in England has been costed
(at £39 million) in the WFD preliminary Cost-Effectiveness
Analysis conducted by Defra.
16. Floodplain storage: re-creation of wetlands
can, if properly designed, provide increased capacity at times
of peak floods and help protect urban areas. The benefits of floodplain
washlands and the requirements for their design were reviewed
in English Nature's research report no 598: Integrated washland
management for flood defence and biodiversity (2004). As wildlife
habitat, washlands need to be wet in winter (for wintering wildfowl)
and relatively dry in spring and summer (for breeding waders).
To provide maximum capacity for flood storage, they should ideally
be fairly dry at all times, and any flood water should be routed
back into the river as soon as possible. Therefore, the design
to meet both functions needs to be deep—or shallow but more
extensive. Although there are a few washland creation projects
(eg Beckingham Marshes at Gainsborough on the River Trent), it
has proved difficult to quantify their benefits in the present
flood-risk scheme appraisal system.
17. Natural England is a partner in the
50-year Wetland Vision project, which is seeking to recreate
floodplain wetland habitats—not just washlands—in
suitable localities. An example is the Great Fen project, intended
to link two National Nature Reserves (Holme Fen and Woodwalton
Fen) south of Peterborough. This will also contribute to the new
UK Biodiversity Action Plan (BAP) target to create 8 landscape-scale
wetland complexes. The intention is also that the Great Fen should
play a role in storing flood water.
18. Blocking of moor grips in upland catchments:
drainage of upland blanket bog was facilitated by Government grants
between the 1950s and 1980s and exacerbated by moor-burning. This
is having a damaging effect on the condition of designated conservation
sites and has resulted in a degraded landscape. A recent study
in the North Pennines AONB has identified 9,300 km of damaging
grips, and a total cost of £10 million to restore the blanket
bog affected. It is estimated that there are over 30,000 km of
grips above the 200-metre contour in England. A programme of grip-blocking
would deliver multiple public benefits by helping to restore biodiversity,
reduce run off, improve raw water quality (and thereby reduce
the cost of treatment), emphasise the role of land managers as
carbon managers and contribute to the Defra "peat project",
being developed as a key part of the Soil Strategy for England.
19. Rainfall runs off quickly through the
moor grips and eroded gullies. Sediment is transported into rivers
and lakes. Streams and rivers can often be seen discoloured by
the concentration of peat in the water. Studies in Upper Wharfedale
by the Environment Agency and—as part of a Defra-led partnership—on
the streams above Ripon by Natural England, have estimated up
to 15% reduction in peak flood flows, by strategic grip-blocking.
Successful projects are being undertaken—in the Peak District
by Moors for the Future, and in the Bowland Fells by United
Utilities (in a partnership with Natural England, RSPB and the
Environment Agency). Techniques of grip-blocking have improved,
and there are some specialist contractors. The HLS stewardship
option offers £3.40 per metre of grip blocked, but actual
costs vary between £1 and £4.50 per metre, depending
on the degree of erosion.
20. The effects of grip blocking on peak
flood flows have not yet been demonstrated in large-scale experiments;
these would entail flow meters on streams fed from blocked and
unblocked grip systems in upland catchments, which is a very expensive
monitoring programme—and flood peaks may not occur for another
ten years or more. However, grip-blocking has multiple benefits
and is worth pursuing as part of an integrated approach to catchment
flood-risk management. In particular, upland restoration has the
potential to enhance the capacity of the uplands as a major carbon
store. We estimate that England's peat uplands currently have
the capacity to store 3 billion tonnes, and that restoration of
upland peat bogs could save around 0.4 million tonnes of carbon
per year equivalent to around 2% of the UK's Kyoto commitment.
21. Managed re-alignment at the coast: sea-level
rise means that many sea defences (particularly in the south and
east, where much land was originally reclaimed from the sea) are
unsustainable. This is a viable sea-defence reason for implementing
managed re-alignment schemes, which would also achieve the delivery
of key biodiversity targets. There is a good example of set back
as an integral part of the Environment Agency's flood-risk management
strategy for the Humber Estuary (eg Alkborough, Paull Holme Strays).
22. Managed re-alignment has been undertaken
elsewhere for other reasons (eg at Freiston Shore RSPB reserve
on the Wash in 2002 to help meet the Defra high-level target requirement
for EA Flood Risk Management to create 200 ha a year of BAP priority
habitat, at least half of which should be saltmarsh). The achievement
to date has been approximately 50 ha a year of saltmarsh creation
(100 ha a year is lost to "coastal squeeze"). Set back
of defences has also been undertaken at Wallasea Island in Essex,
as compensation under the EC Habitats Directive for habitat excluded
from protection at Lappel Bank in the Medway.
ADAPTATION
23. Climate change is posing an increasing
challenge to our flood defences. As well as adopting more sustainable
land management and a catchment-approach, we also need to adapt
to increasing sea-levels and storminess by locating housing and
infrastructure outside areas of high flood risk. This will require
action by local authorities, public utilities, the Highways Agency
and others responsible for authorising or undertaking infrastructure
development. The principles are set out in Planning Policy Statement
25- Development in Flood-risk Areas, revised in December
2006. Defra is leading a project under Making Space for Water
to develop an "adaptation toolkit".
GOVERNMENT POLICY
24. Defra has been moving towards a more
sustainable flood-management policy over the last two decades.
Firstly, the focus of flood defence schemes has moved from agricultural
land drainage—which dominated from the 1950s to 1980s—to
the protection of lives, property and infrastructure, and a greater
emphasis was placed on flood warning. Defra introduced strategic
approaches through Shoreline Management Plans (1995) and Catchment
Flood Management Plans (2002). In March 2005, they published Taking
forward a new Government Strategy for flood and coastal erosion
risk management in England, as a response to the consultation
on Making Space for Water. The response announced the intention
to pursue a more strategic approach, and move to a wider portfolio
of responses to flood risk. These would include greater use of
rural land-use solutions, such as creation of wetlands and washlands,
coastal realignment, river corridor widening and river restoration.
Natural England fully supports this approach to flood-risk management.
25. Since then, Defra has led a programme
of 25 projects under the Making Space for Water banner
and initiated an Innovation Fund of £1.5 million over three
years to stimulate sustainable approaches. The first six projects
to be supported by the Fund were announced in January 2007. They
included "development of an educational tool for shoreline
management", "farming floodplains for the future in
Staffordshire", "restoring floodplain woodland for flood
alleviation" by the Forestry Commission and a study on "ways
of integrating ecology and sustainable flood-risk management into
the planning for the Thames Gateway". As a separate initiative,
Natural England is leading a project with the Association of Drainage
Authorities to develop Biodiversity Guidelines for Internal Drainage
Boards.
FROM POLICY
TO IMPLEMENTATION—SLOW
PROGRESS
26. Despite the policy initiatives outlined
above, the integration of strategic and sustainable approaches
into the flood-risk management programme is barely in evidence.
To most appearances, it is "business as usual". Defra
perceived that there were barriers to—and lack of incentives
for—implementation of the new policy. They made an assessment
of the reasons through a project under Making Space for Water.
Natural England has contributed to this project. We suggest some
possible reasons why there have not been more integrated schemes:
26.1 Schemes need to be devised and
proposed. In the case of the Environment Agency, this involves
identifying a flood-risk problem, commissioning consultants to
develop a solution, and determining priorities for funding through
a Regional Flood Defence Committee (which has an inbuilt majority
of local authority members). At none of these stages is there
any incentive to propose catchment solutions, and very few consultants
or flood-defence engineers would feel confident about proposing
land management solutions, particularly as they would need to
involve other partners at an early stage.
26.2 Hard defences are a tried-and-tested
protection against flooding (if built high enough), while catchment
solutions are new territory for the flood-defence engineer. Results
are likely to be longer-term and may not protect property from
the next flood, if that occurs before new processes have had a
chance to take effect. Nevertheless, catchment solutions could
be used as part of an integrated approach. Some re-training may
be desirable, aided by demonstration projects.
26.3 At the coast, set-back of sea
defences has been shown to be a viable flood-management option.
Although several SMPs include managed re-alignment schemes, there
is an apparent reluctance to implement them, because of perceived
opposition from local interests. The continued maintenance by
the Environment Agency of uneconomic sea walls in Essex, despite
the Government's policy announced in April 2004, is a case in
point. The Environment Agency recently produced guidelines for
withdrawal of maintenance from flood defences—so we hope
that action is imminent. Funds saved can be redirected to sustainable
approaches.
26.4 The Defra cost-benefit appraisal
scheme for capital flood-management schemes—and the way
in which the assessment of a scheme is expected to be put together
by the Environment Agency—appear to militate against inclusion
of sustainable solutions and adaptation to climate change. The
appraisal methodology is currently under review. It may become
easier to develop an economic case for integrated schemes in future.
26.5 Major changes in the administration
and supervision of the flood management capital programme took
place soon after the announcement of the Making Space for Water
policy. In 2006, Defra started to give the Environment Agency
a block grant for flood-risk management (£436 million in
2007-08), though it can direct it to spend some of this on particular
types of work and still approves schemes over £50 million
(one or two a year). Before this, Defra Regional Engineers approved
schemes and could reject those that did not include environmental
and social elements. As part of downsizing of Defra Flood Management
Division, the Regional Offices have been closed. It is imperative
that the same strategic overview (economic, technical and environmental)
is exercised consistently in all Regions of the Environment Agency.
26.6 There are 25 projects under Making
Space for Water. Several of them are crucial to the implementation
of sustainable approaches to flood-risk management, including
adaptation to climate change. The number of Defra staff working
on Making Space for Water has been gradually reduced—and
key staff members have recently been seconded to working on the
Government and EFRACOM inquiries into the handling of the 2007
floods. This, combined with all the other pressures on the funding
available to the Environment Agency to play its part in the programme,
argues for prioritising those projects which will help to deliver
integrated schemes and sustainable solutions.
RECOMMENDATIONS
27. In the light of the slow progress in
implementing a strategic and sustainable approach to flood-risk
management, Natural England makes the following recommendations:
27.1 Target deadlines should be set for implementation
of integrated schemes identified in SMPs and CFMPs, and of the
policy to withdraw maintenance of uneconomic defences announced
in 2004;
27.2 A significant proportion of the EA's
flood-risk management budget should be earmarked for "sustainable"
schemes; and
27.3 The 25 projects under Making Space
for Water should be prioritised, and those informing "integrated
schemes" should be completed and put into practice within
the next 12 months.
Natural England
September 2007
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