Memorandum submitted by CPRE (DFWMB 18)
1. The Campaign to Protect Rural England
(CPRE) is a charity that promotes the beauty, tranquillity and
diversity of rural England. We advocate positive long-term solutions
for the countryside, and have more than 60,000 supporters,
and a branch in every English county. We work on a variety of
policy areas affecting the countryside, and are strong advocates
of a plan-led approach to development and land use that recognises
the importance of protecting and enhancing environmental and social
assets in the countryside, as well as delivering economic development.
2. We are pleased to be able to make a short
contribution to the pre-legislative scrutiny of the draft Flood
and Water Management Bill. We are part of the Blueprint for Water
Coalition aiming to achieve sustainable water management by 2015,
and hope that the Flood and Water Management Bill will help to
deliver some of the Blueprint's aims. In addition, we coordinate
our own country-wide network of volunteer water specialists who
campaign for better water management at local and regional level.
Our brief contribution to this inquiry, which focuses on question
three on whether the proposals are workable, efficient and clear
and whether there are any omissions in the draft Bill, draws on
the comments of that network. Our response refers both to relevant
parts of the consultation document and the draft Bill
SUSTAINABLE DRAINAGE
3. The draft Bill proposal on Sustainable
Urban Drainage Systems (SUDS) introduces an element of fragmentation
for county councils. For these two-tier areas, clauses 222-224 propose
that the body approving a drainage system which will have to comply
with the national standards of sustainable drainage will be the
county council. On the other hand, the body implementing it will
be the district council planning authority. We suggest that careful
consideration should be given to how this might work in practice,
and to whether or not the district council would be the most appropriate
body to approve a sustainable drainage system as part of a planning
permission, as well as to implement it.
PROTECTING AGRICULTURAL
LAND
4. Section three.one of the Consultation
Paper, discusses the future role of Internal Drainage Boards (IDBs)
although there are no proposals for their reform in the draft
Bill. Any significant change in the way river drainage is managed
will have significant implications for farm businesses.—Many
years of capital investment and management practice could be subject
to radically different objectives. New priorities to prevent the
flooding of settlements, for example, is likely to introduce a
major reversal of the hitherto dominant conception of removing
water from agricultural land as quickly and efficiently as possible.
5. Change will need to be managed carefully
and the investment cycle of the farming community taken into account.
We are concerned that the discussion about a shift needed from
the "Boards" historical drainage function to a broader
flood risk management role does not give due weight to protecting
high quality farmland for food production. In the short term,
CPRE believes that protection of Grades 1, 2 and 3a agricultural
land should be a policy priority; climate change impacts are increasing
concern about food security world-wide, heightening the importance
of domestic food-growing capability. In the longer term, we need
a refreshed system for assessing land capability based on a revised
agricultural land classification system taking account of wider
considerations such as water storage, flood management and the
enhancement of wetland ecosystems.
6. We are concerned by the unqualified statement
in paragraph 366 of the Consultation paper that IDBs have
been operating "for agricultural efficiency to the detriment
of nature conservation". The focus on "natural processes
such as flood meadows and wetland recreation" to improve
biodiversity will be important in some places (and could deliver
landscape and recreational benefits too), but it can also sometimes
be incompatible with maintaining the drainage of adjacent farmland.
In our view, the IDBs need to reconcile nature conservation interests
with the protection of high quality farmland and settlement protection,
and should not automatically give primacy to one over the other;
a case-by-case approach will be needed in this area.
CPRE
May 2009
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