The Draft Flood and Water Management Bill - Environment, Food and Rural Affairs Committee Contents


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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