Memorandum submitted by Natural England
EXECUTIVE SUMMARY
Natural England believes that climate
change is the most serious long term threat to the natural environment
and human well-being. Our natural environment is our greatest
asset, the basis on which we must build a future in a rapidly
changing climate. To secure a comfortable lifestyle in
a world which is likely to warm by between two and four degrees,
we must act to protect the long term health of the environment
and the ecosystem services which it provides. Consequently,
enabling the natural environment to adapt to climate change is
not an optional extra alongside the pressing need to safeguard
homes, infrastructure, livelihoods and human life. It must be
at the core of adaptation and future growth.
Working with natural processes
affords protection to homes, infrastructure, livelihoods, and
human life without substantial long term maintenance costs, set
to rise year on year, and without damaging the essentials for
life provided by a healthy natural environment.
This is a responsibility of all Government
departments, not just Defra.
Natural England has taken a lead in sustainable
adaptation, embedding it throughout its operations, establishing
demonstration projects to examine appropriate land management
responses to a changed climate.
Assessing the costs and benefits of adaptation
solely within individual departments exposes the Government to
the risks created by perverse incentives, resulting in unintended
consequences. Far more needs to be done towards ensuring the right
incentives are put into place. Additionally, there is a great
deal to be done to ensure that the costs of adaptation and savings
from sustainable adaptation are properly understood and accounted
for across the whole of Government, rather than within departments
alone, to prevent inappropriate short term or otherwise ill-informed
decisions on investment.
In the future, assessments of value for
money, and reporting of these, must be based on sustainable adaptation
and a healthy, resilient natural environment, if only to safeguard
present and future taxpayers.
There are practical mechanisms for sustainable
adaptation, drawing on expertise and departmental responsibilities
from across Whitehall. One of the most effective of these is green
infrastructure, and we have drawn the committee's attention to
this as a specific example of the cross-Whitehall (and cross sectoral)
issues which we must address.
Sustainable adaptation, predicated on
a healthy and resilient natural environment is a responsibility
which is shared across Government departments.
1. INTRODUCTION
Natural England is a statutory body created
in 2006, charged with the responsibility to ensure that England's
unique natural environment is protected and improved.
Natural England's purpose 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.
In our capacity as a statutory adviser to Government,
we offer advice on the making of national public policy through
our analysis, evidence, and lessons drawn from delivery experience.
As an NDPB, we then implement national public policy throughout
its own activities via the development of organisational policy
(specific to the activities of Natural England), guidance for
local delivery, and forward programmes of evidence gathering.
2. ADAPTATIONA
NATIONAL IMPERATIVE
2.1 Current efforts to address the causes of
climate change are to be welcomed. Natural England supports the
actions set in train through the Climate Change Act, and we support
the Government's commitment to the creation of a low carbon economy.
2.2 Measures taken must continue to work towards
reducing the severity of future changes to our climate. Because
it also supplies economically vital ecosystem services, we cannot
afford not to conserve the natural environment, and the policy
framework needs to be built upon this inescapable truth.
2.3 Despite collective efforts in recent years,
substantial change is already "locked" into our climate,
resulting from emissions made over many decades. Government and
civil society must plan and act to adapt to unavoidable climate
change in the short and medium term.
2.4 To fail to adapt, adapt poorly, or simply
adapt too late, will be more expensive, and less effective. It
is also far more likely to result in unintended consequences than
a planned programme for sustainable adaptation enacted now.
2.5 We still have an opportunity to adapt sustainably,
efficiently, effectively and towards well planned outcomes. Adaptation
remains largely a matter of political choice, not a question of
technical capability.
2.6 Enabling the natural environment to adapt
to climate change is not an optional extra alongside the pressing
need to safeguard homes, infrastructure, livelihoods and human
life. It is at the core of sustainable adaptation and future growth.
2.7 Working withnot againstnatural
processes, affords protection to homes, infrastructure, livelihoods
and human life without substantial long term maintenance costs,
rising year on year, and without damaging the essentials for life
provided by a healthy environment. Future monitoring and reporting
arrangements on progress towards successful adaptation must include
measures which enable Government and others to scrutinise the
degree to which adaptation is leading to a healthier and more
resilient natural environment. At present, these are not evident.
2.8 Ecosystem servicesunnoticed until
they failinclude soil fertility; fresh water catchment
and storage; flood prevention and management; and summer cooling
in cities. The continued provision of ecosystem services depends
on a healthy and resilient natural environment, for which sustainable
adaptation is necessary.
2.9 Where ecosystem services can be brought
back into production, the costs are likely to be exorbitantfar
in excess of the costs associated with damage prevention, particularly
in the face of a rapidly changing climate. Where damaged beyond
repair, costs of replacement with man-made engineering alternatives
are likely to be beyond the reach for many economies, including
some in the developed west.
2.10 Current research indicates that the climate
may become four degrees warmer, not two which is the target towards
which our mitigation efforts are aimed.
2.11 It is responsible to aim at cutting emissions
so that the climate does not warm by more than two degrees. It
is equally responsible to plan for sustainable adaptation in a
world four degrees warmer. Sustainable adaptation offers a solution
addressing all the challenges faced in a changing climate, at
a potentially much lower cost than some traditional measures.
2.12 Achieving sustainable adaptation will require
exactly the sort of cross-Government response of interest to the
Committee, enabled by appropriate policies, funding, monitoring
and reporting arrangements.
2.13 In Annex 1(a), there are five examples
which illustrate the importance of natural systems and sustainable
adaptation in tackling some of the risks facing society and the
economy.
3. EXAMPLES OF
NATURAL ENGLAND'S
WORK ON
ADAPTATION
3.1 Since our inception in October 2006 we have
placed sustainable adaptation at the heart of our own operational
policy, decision making and advice.
3.2 Adapting to climate change is necessary
to protect ecosystem services, and the best way to secure adaptation
is working at landscape scale. In March 2009 we published landscape
scale climate change adaptation strategies for the Norfolk Broads,[1]
Cumbria High Fells, Shropshire Hills and Dorset Downs.
3.3 The reports illustrate how climate change
may affect some of England's most iconic landscapes, and their
wildlife and habitats, and suggest the practical measures needed
in each place to improve the resilience of the natural environment
to climate change whilst retaining its intrinsic value, and ability
to provide economic and social benefits. While the different areas
require a range of specific adaptation responses, there are some
broad actions common to all areas. For example:
improving the condition of existing habitats;
restoring lost and degraded habitats;
extending existing habitats into new
areas; and
adopting sensitive farming methodsfor
example, leaving vegetated buffer strips around fields and not
leaving fields bare.
3.4 The results from these studies will inform
Natural England's approach to adaptation at a landscape scale
across England, and will inform the advice we will provide to
our partners, in particular, the risk assessments and adaptation
response strategies that are required by the Climate Change Act.
We are working with partners to implement these strategies, and
during 2009-10 the project is being extended across England into
five more study areas: London, South East Northumberland Coastal
Plain, Humberhead Levels, Sherwood, and a regional scale study
in the South East of England.
3.5 Natural England plays a pivotal role in
the delivery of adaptation on the ground. We administer approximately
£0.5 billion per annum of agri-environment monies and have
integrated climate change considerations into Environmental Stewardship
schemes so that adaptation is increasingly well delivered by private
land managers and landowners.
3.6 We have opted to report voluntarily under
the new reporting power under the Climate Change Act and are undertaking
a risk assessment with regard to our business and climate change,
sharing lessons learned and data gathered with other reporting
bodies, Defra and stakeholders.
4. THE NATIONAL
POLICY FRAMEWORK
4.1 An effective, efficient and up-to-date national
framework for policy and delivery is needed if we are to successfully
contribute to timely and sustainable adaptation. Experience to
date suggests that there are a number of areas where the existing
policy framework warrants review and improvement.
4.2 The themes used by the National Audit Office
(NAO) usefully set the scene for a cross-cutting approach to the
assessment of adaptation policy across Government. The themes
are business and the economy; infrastructure; agriculture, food
security and the natural environment; homes and buildings (including
government estate); and public health.
4.3 The NAO report earlier this year suggests
that the natural environment, which underpins the security and
sustainability of the other themes, is too easily regarded as
the primary responsibility of Defra and not the responsibility
of other government departments. But, it is other government departments
which are responsible for the development of policy levers which
directly deliver and enable adaptation. For example:
(a) DCLG is responsible for measures on planning
and development control (including green infrastructure), spatial
planning, local government and its regulation, communities, and
housing. DCLG are already working closely with Defra.
(b) Her Majesty's Treasury is responsible for
the financial arrangements which fund and shape national delivery,
sending important signals to other sectors including local government
and the private sector about what does and does not constitute
effective and efficient use of public money. Unless these signals
support and enable sustainable adaptation, long term value for
money, and cross-government value for money, there is a danger
that the adaptation policy messages from Defra will not be translated
into action.[2]
4.4 The departmental approach to considering
climate change risks and adaptation needs is the first, and welcome,
step in the Government's overall task.
4.5 Persisting with a consideration of the costs
and benefits of adaptation on a departmental basis, however, runs
very significant risks to both the goals of sustainable adaptation
and good value for money across Government.
4.6 A potential solution is for the assessment
of costs and benefits to be undertaken on a whole-Government basis
in the future. This would also serve to improve inter-departmental
communication as well as practical collaboration toward the Government-wide
goal of adaptation, while reducing the risk of unintended consequences
across the Government's programme.
4.7 There are some adaptation options which,
because they are based on sustainable adaptation, address risks
apparent in several of the NAO's themes and draw upon the expertise
from across Government departments. Green Infrastructure[3]
is one such measure towards sustainable adaptation.
4.8 DCLG, for example, are making progress toward
safeguarding homes, communities, infrastructure, business and
economic interests, and the natural environment through the increased
importance attached to "green infrastructure".
4.9 A changing climate means that the majority
of our plants and animals will have to move inland, uphill and
north to find new, viable homes. They need green spaces and healthy
waterways to move through and to move toie connectivityif
they are to succeed. Green infrastructure provides this.
4.10 We particularly welcome the recent announcement
by the Secretary of State for Environment, Food, and Rural Affairs
on the forthcoming review of the ecological network. The work
will provide for greater connectivity, by ensuring landscape around
and between protected areas is ecologically coherent, improving
vital "wildlife motorways" as a cornerstone of adaptation.
4.11 Green infrastructure has enormous potential
to be a vehicle for effective and efficient adaptation of the
built environment. But it is a potential not yet realised.
4.12 The existing green space network was designed
primarily for amenity, recreation and conservation purposes. Consequently
much of it may not be entirely fit for purpose with respect to
optimising its adaptation functionsalthough green space
still has a value as a "wildlife motorway" linking urban
and rural habitats.
4.13 In future, adaptation functions need to
be built into green infrastructure, rather than green spaces being
continually rebadged, assigning climate-change functions to them
that are incidental rather than deliberate.
4.14 Within the existing policy framework, there
are a number of barriers to its potential being fully realised,
for example:
(a) Green infrastructure, the environment, and
climate change do not yet enjoy a high profile in any single conversation.
(b) None of the existing standards and codes
covering the built environment cover green infrastructure or factor
in its benefits to incentivise take-up; targets for delivery apply
only to new Ecotowns, a fraction of the potential and the need.
(c) The planning system does not look at whole-site
functionality and the contribution of green infrastructure to
immediate and future goals, leaving the underlying health of the
environment unprotected and undervalued.
(d) A fundamental worry for local authorities
regarding GI and green space, and a barrier to embracing adaptation,
is long term funding. There is no statutory duty on them to manage
green spaces and so funding is subject to regular cuts, especially
during a downturn.
4.15 There are developments on the national
policy front which are beginning to break down barriers to green
infrastructure delivery (see Annex 1(c)). Perhaps most importantly,
they will help to counter the culture within parts of the planning
and development sector which views green space as an optional
extra.
4.16 Considering green infrastructure, climate
change and health costs together may present fresh opportunities
for understanding and managing the costs and benefits of adaptation
in the long and short term.
4.17 For example, the currency used in healthcare
is the QALY (quality adjusted life year). The accepted cost to
add one year of life with good quality is about £30,000.
So it would be possible to calculate the number of QALY's saved
by increasing the amount of green space that offsets the urban
heat island and reduces heat related deaths.
4.18 The multiple benefits offered by some otherwise
simple-sounding measures like green infrastructure cannot be realised
for the community without understanding and valuing the full range
of its benefits to society, the economy, and the natural environment.
Rural "green infrastructure" (fully
operational, multi-functional landscapes)
4.19 Reducing the incidence and severity of
flooding in the long term rests on a mixture of measures according
to the needs of each geographic (not just administrative) area.
4.20 At present, much fluvial flood risk management
addresses the symptoms (often at very great cost) and not the
causes. If continued, it is likely that expenditure will continue
to rise in real terms.
4.21 To address the causes, we need adaptation
to climate change in the upper rather than catchments, and for
catchments to be understood properly as part of a living, fully
functional landscape.
4.22 The inclusion of catchment schemes in the
2009 Price Review (PR09) has been welcome, but the scale at which
adaptation and functionality is optimised is at the full landscape
scale, not just at the catchment scale.
4.23 The policy framework needs to demand and
enable catchment wide planning and decision making, which will
require that the multiple agencies involved collaborate effectively
on goals of joint importance, working across existing administrative
boundaries. EFRAComm's recent report on their pre-legislative
scrutiny of the Draft Floods and Water Management Bill made related
comments.[4]
Effective and transparent collaboration needs to be built on open
sharing of data between relevant agencies, also commented on by
EFRAComm.
4.24 Linking the benefits of urban, rural, coastal
and green infrastructure can be aided and embedded into local
practice through the establishment of area wide "adaptation
partnerships" similar to those which operate in some other
countries.
4.25 These may emerge from existing arrangements
to facilitate the requirements of the Water Framework Directive
or they may be entirely new.
4.26 Adaptation is not just the responsibility
of Government, although Government leadership will always be required.
Private land owners and home owners also have a responsibility
to enable the country to adapt sustainably.
4.27 The delivery of green infrastructure is
currently (and properly) a responsibility shared across several
departments of Government. A mechanism to ensure the delivery
of green infrastructure (securing the many benefits it offers)
across departmental boundaries could be usefully explored.
4.28 Defra have convened two groups drawn from
across Whitehall and statutory advisers on aspects of the environment,
one which co-ordinates the Domestic Adaptation Programme, and
the other which has acted as a stakeholder group to shape the
reporting power on adaptation. Both groups have underlined the
usefulness of cross-Whitehall collaboration and the need to monitor
progress on joint endeavours.
5. THE FUTURE
POLICY FRAMEWORK
5.1 There remain many other policy levers, eg
agri-environment schemes, CAP reform, regulation of the water
industry, which also play a vital role in translating national
adaptation policy into the delivery of adaptation. These policy
levers should be reviewed to ensure that they support and not
undermine sustainable adaptation.
5.2 Achieving our renewable and low carbon energy
targets must not run counter to the needs of sustainable adaptation,
and adaptation and mitigation must not be treated as competitive
or counter-weighted alternatives. Done well, adaptation aids and
speeds efforts on mitigation.
5.3 Future assessments of value for money should
be based on sustainable adaptation and a healthy, resilient natural
environment if the nation is to maximise the value of Government
investment and retain the use of naturally produced ecosystem
services.
5.4 Payment and grant schemes, such as regeneration
grants and European regional development funds, should in future
require applicants to plan for and report on sustainable adaptation.
5.5 In addition to reporting on financial probity,
government departments and the wider public sector should be required
to report on non-financial measures, which indicate the extent
to which their actions add up to sustainable adaptation, eg the
impact of policy and delivery on the capacity of the natural environment
to adapt successfully.
5.6 The regulatory frameworks overseeing key
sectors, eg the water industry, should also be reviewed to ensure
that they send the right signals, requiring sustainable adaptation.
5.7 Annex 1(b) provides two examples of issues
to be addressed in the water industry sector. These examples illustrate
the need to ensure that "second tier" policy makingwhether
through policy guidance or regulatory and financial leversis
fully aligned with sustainable adaptation, part of the Government's
overall policy objectives. At present, this is far from the case,
as the examples in Annex 1(b) illustrate, and it is in the misalignment
of policy objectives and second tier policy levers where failure
is most likely to occur.
5.8 Future legislationdomestic, European,
environmental and non-environmental, first and second tiertherefore
needs to be designed to ensure that it doesn't unintentionally
run counter to the needs of sustainable adaptation.
Annex 1(a)
6. THE ROLE
PLAYED BY
THE NATURAL
ENVIRONMENT IN
ENABLING ADAPTATION
FOR HUMAN
SECURITY
The role of woodlands
6.1 England is one of the least forested
countries in Europe, with only about 9% tree cover compared with
37% in the EU as a whole (Forestry Commission 2008). Tree planting
and appropriate woodland management is an effective and sustainable
contribution to achieving a wide range of climate change objectives.
6.2 Woodlands can manage important environmental
risks, which will increase with climate change, such as soil erosion,
agricultural runoff, rise in water temperature and consequent
declines in water quality, and flooding (Caissie 2006; Conlan
et al 2007; Sudgen et al 2008). Trees also regulate
the local climate and provide shelter from wind and storms to
protect crops, livestock and soils, as well as supporting important
pollinating insects (Sugden et al 2008; Escobedo et
al 2009; Merckx et al 2009a, 2009b). Growing trees
to produce timber or wood fuel help farmers spread the social
and financial risks from climate change (Sugden et al 2008).
All these services are likely to become even more important to
society under the extreme climatic changes that four degrees would
bring especially as flooding, water pollution, heat waves, droughts
and unpredictable conditions become more frequent and severe (Murphy
et al 2009).
6.3 Trees play an increasingly important role
for human health and recreation in a 4+ degree world. In cities,
there would be vital shade and temperature regulation benefits
for people by increasing the number and area of trees in urban
landscapes (Gill et al 2007; Escobedo et al 2009).
In the countryside, woodland areas may become increasingly important
as cool places where people can enjoy the outdoors, away from
the summer heat.
6.4 In addition to its adaptation benefits,
woodland provides a major carbon sink by sequestering carbon within
its timber and maintaining soil carbon stores (Choudrie et
al 2008); in some cases mitigation may be best achieved by
sustainable timber harvesting for fuel and materials (Nabuurs
et al 2007). Even where such wood is used for fuel it saves
carbon by substituting for fossil fuels, and where wood is used
in construction there is a double savingstored carbon in
the timber, and the savings arising from reduced use of steel.
Keeping blanket bog in good condition tackles
both adaptation and mitigation
6.5 Blanket bog is found across the UK, including
in the English uplands where high rainfall and poor drainage frequently
result in waterlogged conditions; the largest areas are in the
Pennine Hills.
6.6 Blanket bog provides a number of ecosystem
services with a direct bearing on the quality of human life (O'Brien
et al 2007); two of the most important are carbon storage
and water supply.
6.7 The peat is a substantial store of carbon,
which has built up over thousands of years and healthy bog continues
to steadily remove carbon from the atmosphere, although there
may be small releases of methane through decomposition (Thompson
2008).
6.8 Catchments covered with blanket bog are
a major source of water supplies for large numbers of people in
the Midlands and north of England. They are also areas which can
support low intensity sheep grazing and contribute to a highly
valued landscape with a well developed tourist industry (Usher
& Thompson 1988).
6.9 Blanket bog can be degraded by a range of
factors including drainage, over-grazing and air pollution (O'Brien
et al 2007). In a degraded state, soil erosion leads to
the release of carbon and a changed hydrology with poorer quality
and more variable water supply and increased risk of flooding
downstream, increasing the costs borne by householders, water
companies, water bill payers and local authorities.
6.10 Climate change is likely to exacerbate
this degradation particularly if summer droughts become more frequent.
6.11 The solution, restoring blanket bog,
safeguards service provision and increases resilience of these
services to climate change as well as protecting conservation
interests. There are already efforts being made to block grip
drains and increase water levels in some moorland areas to improve
bog condition in order to maintain carbon storage and water resources.
Management of rivers and catchments to safeguard
homes, communities, infrastructure and economically vital ecosystem
services
6.12 Appropriate management of rivers and catchments
is crucial to both the provision of clean water and the management
of flood risk, along with a range of associated services.
6.13 Climate change projections (Murphy et
al 2009) suggest that we will see both an increase in summer
droughts and in extreme flooding events and these are likely to
be increasingly severe as we approach a 4+ degree world.
6.14 Where rivers and their catchments have
been degraded by channelisation, pollution, excessive water abstraction
and destruction of riparian vegetation, they will be less able
to provide the services society requires.
6.15 Restoration of floodplains with healthy
natural ecosystems which naturally regulates flow will greatly
improve their ability to store and absorb large flooding events.
This affords protection to built-up areas and greatly reduces
the scouring impacts of large water flows down rivers (Wheater
2006). Restoring riparian vegetation can also guard against water
pollution, the risk of which is likely to increase with climate
change (Caissie 2006; Sugden et al 2008)
6.16 Elements of natural floodplain ecosystems
such as wetlands also have the potential to store water at times
of excess and gradually release it back into the environment,
reducing the frequency and impact of local drought and flooding.
Managed realignment of coastlines to protect communities
and infrastructure long term
6.17 In a 4+ degree world, sea-levels may rise
substantially, threatening large parts of England's coastal areas
with inundation, particularly those on the eastern and south-eastern
coasts. Hard defences, such as sea-walls will be very expensive,
become increasingly costly to maintain, and potentially unsustainable,
against the continued erosive forces of the sea.
6.18 Working with nature, using salt marsh and other
coastal habitats to create more storage space for high tides and
to reduce the energy of the sea before reaching such defences,
can cut costs and greatly increase sustainability (Defra 2005).
6.19 Managed realignment involves breaching
sea walls and letting the sea advance to cover the land behind
it. In most cases, new flood banks are constructed behind the
wall that is breached; the sea covers the land between the old
and new defences and intertidal habitats are gradually established
(Dixon et al 2008).
6.20 The techniques are neither new nor untested.
There have been over twenty realignment projects in the UK designed
either for habitat conservation or flood risk management or both,
the largest of which, at Alkborough on the Humber estuary, protects
90,000 hectares of land and 300,000 properties from sea level
rise. In addition, it has produced new recreation opportunities
to benefit the local community both directly through increased
tourism, as well as significant conservation benefits (Environment
Agency undated; Dixon et al 2008).
Maintaining and increasing biodiversity to increase
resilience and protect ecosystem services
6.21 Living with extreme climate change will
demand our leaders to make some very difficult decisions about
society, our economy, and the environment on which are lifestyles
are based. The natural environment performs a number of functions
and provides multiple benefits through these, but in advocating
the role of nature conservation as a way of ensuring the continuation
of a fully multi-functional natural environment, we accept that
this presents decision makers with many hard choices.
6.22 If policy makers use the existing language
of trade-offs, they will need to better understand the costs and
benefits (not just monetary, but ecological and social) of the
likely trade-offs between different services and to develop decision-making
models to help make the optimal choices.
6.23 If the trade-off debate persists, then
the evaluation of trade-offs must fully recognise the cost-effective
benefits that natural environments provide and will increasingly
provide in a 2+ and 4+ degree world.
6.24 Sustainable adaptation will ensure
that while safeguarding life, property, and economically vital
ecosystem services, the intrinsic value of the natural environment
is protected for future generations too.
Annex 1(b)
7. OFWAT'SREGULATORY
REGIMETHE
PRICE REVIEW
PROCESS
7.1 Ofwat have tried to set up a longer term
25 year framework in this current price review (PR09) through
introducing a requirement for water companies to produce 25 year
Strategic Direction Statements.
7.2 This process has helped water companies set out
longer-term adaptation/mitigation needs, but investment is still
constrained within the five-year process and is dependent upon
cost benefit analysis and must be supported by customers.
7.3 In reality the costs and benefits of longer
term planning are not always easy to describe and customer priorities
tend to focus on the immediate provision of good quality drinking
water. At this current stage in the PR09 process a number of water
companys Strategic Direction Statements are no longer consistent
with Ofwat' draft decisions (Draft Determinations).
7.4 The Price Review five year investment cycle
is not alignment with the Water Framework Directive (WFD) cyclewhich
runs over six years and made an attempt to align with the statutory
Water Resource Management Plan (WRMP) cycle introduced this timebut
so far only 10 (out of 22) company WRMPs have been approved by
the Secretary of Statethe remainder are going to inquiry,
appeal or need to provide further information, therefore will
not complete in time to inform Ofwat's final determinations on
PR09.
7.5 The WRMPs are 25 year plansand once
signed off by the Secretary of State companies need to deliver
thembut they only have commitment through the Price Review
process to investment for five years.
7.6 Suggested remedies:
(a) Need to align the Periodic Review process
with River Basin Management Plans and Water Resource Management
Plans.
(b) There needs to be a more flexible approach
to investment within the 5 year cycle to enable longer term adaptation/mitigation.
(c) Should Ofwat have less stringent cost benefit
analysis (CBA) requirements or better define their CBA requirements
to enable longer term investment planning? Our preference would
the latter because Ofwat's CBA methodology in general is not clearly
defined.[5]
7.7 An EfraComm report into PR09 (July 2009)set
out a recommendation that Defra provide Ofwat with clear guidance
on the application of CBA and that Ofwat's guidance should be
clear and unambiguous. The report also included a recommendation
that Defra should consider if changes are needed to the regulatory
regime to ensure that water companies have incentives to take
early action to adapt to climate change.
7.8 OFWAT's current regulatory focus has been
said to discourage green infrastructure solutions in favour of
hard engineering solutions which have an asset value and so are
better able to boost shareholder value than "soft" engineering
solutions. Yet in many instances "soft engineering"
measures may be far more sustainable and increase the resilience
of our natural systems, in contrast to the consequences of some
hard engineering alternatives.
Annex 1(c)
8. GREEN INFRASTRUCTUREBARRIERS
WITHIN THE
POLICY FRAMEWORK
8.1 The existing green space network was designed
primarily for amenity, recreation and conservation purposes. Consequently
much of it may not be entirely fit for purpose with respect to
optimising its adaptation functionsalthough green space
still has a value as a "wildlife motorway" linking urban
and rural habitats.
8.2 In future, adaptation functions need to be built
into green infrastructure, rather than green spaces being continually
rebadged, assigning climate-change functions to them that are
incidental rather than deliberate.
8.3 Within the existing policy framework, there
are a number of barriers to its potential being fully realised,
for example:
(a) Green infrastructure, the environment and
climate change do not yet enjoy a high profile in any single conversation,
so the synergies are unrecognised and so undervalued.
(b) Although the Code for Sustainable Homes standard
for new homes includes "ecology" in the mix of criteria
at the higher levels, this is not framed in a way which fully
acknowledges the contribution of green infrastructure to climate
change adaptation. This is a weakness because it fails to make
the social and economic case for sustainable urban adaptation
and deprives home owners of those benefits as design features
when they make a purchase.
(c) The zero-carbon homes standard is largely
about insulation standards, and doesn't allow developers to factor
in the climate change benefits of green infrastructureso
do not count towards the zero carbon targets. This is a weakness
because it does not encourage developers to retain or create adequate
areas of green infrastructure.
(d) The planning system does not currently look
at whole-site functionality and the contribution of green infrastructure
to immediate and future goals. Therefore the assets, eg natural
watercourses and drainage patterns, boundary and shade trees,
encapsulated areas of mature woodland, wetlands, and the underlying
health of the environment is not protected and its functionality
is too often compromised.
(e) Accessible Natural Greenspace Standards (ANGSt)
is the only widely promoted standard, but it is not about adaptation,
and only has advisory status at present. Green infrastructure
provision within "Accessible Natural GreenSpace" Standards'
has been largely related to accessibility for health and recreation.
As such, the standard is not related to the area of GI needed
to provide climate change adaptation benefits, for which there
is no standard available, but one we believe is required.
(f) The evidence base on how much green infrastructure
is needed remains weak and incomplete, exacerbating the problems
with developing and setting any improvement to the ANGSt.
(g) Although Government policy provides general
support for green infrastructure (eg PPS 9, PPS 17, Ecotowns prospectus)
there is no binding national policy requirement nor statutory
standard for the provision of green infrastructure associated
with new housing development. Consequently, developers and local
planning authorities may not understand Government expectations
in terms of provision for green infrastructure.
(h) Furthermore, with pressures on budgets for
infrastructure, and the removal of ring-fenced funding for green
space in the Growth Area Funding programme for 2008, local authorities
may be unwilling to prepare green infrastructure strategies; and
developers unwilling to pay for habitat creation, enhancement,
or long-term management.
(i) A fundamental worry for local authorities
regarding GI and green space (and therefore a barrier to them
embracing adaptation) is long term funding. There is no statutory
duty on them to manage green spaces and so funding is often described
as hand-to-mouth and subject to regular cuts, especially during
an economic downturn. Vesting green spaces in not-for-profit Trusts
(as per Milton Keynes) is one alternative but not appropriate
or achievable everywhere.
8.4 There are developments on the national policy
front which are beginning to break down barriers to green infrastructure
delivery (see below). Perhaps most importantly, they will help
to counter the culture within parts of the planning and development
sector which views green space as an optional extra.
(a) All of the designated Growth Points[6]
must, as a condition of their Growth Point status and extra funding,
prepare GI strategies.
(b) Planning Policy 12 (Spatial Planning) now
references GI alongside other infrastructure needs that should
be addressed in Local Authority Core Strategies.
(c) The Government's Quality of Place Strategy
published earlier this year committed Government to producing
new Planning Policy Guidance for GI. This should be included in
the new Planning Policy Statement which will combine PPSs 7, 9
and 17.
5 October 2009
Local authorities' strategiesDefra
must explain how the national plan will relate to local spatial
planning. Local authorities are already responsible for the spatial
planning process, and this Bill also gives them a remit for flood
and coastal erosion risk management planning. Authorities will
have to fit the two together and synchronise the cycles for revising
and updating their plans.
Recommend that Defra consider whether guidance on data
sharing, including the safeguards that should be in place, should
be provided for in secondary legislation.
1 Formed by peat excavation over many centuries past,
which at the time released of green house gases and reduced that
region's carbon sink capacity-but long before either became an
issue. Back
2
The costs of non-adaptation, mal-adaptation and delayed adaptation
were detailed at a global scale in the report from Sir Nicholas
Stern. Back
3
Green infrastructure refers to a suite of urban and rural land
engineering measures such as porous paving and sustainable urban
drainage; sub-surface flood attenuation; public and private buildings
orientated to benefit from summer shade and winter wind breaks;
water catchment and storage; carbon capture and storage; as well
as the more familiar elements such as more tree cover, enriched
biodiversity, and more open green space. Back
4
EFRAComm Report on the draft Floods and Water Management Bill
September 2009 Back
5
References:
Defra's Social and Environmental Guidance for Ofwat (August 2008)
http://www.defra.gov.uk/environment/quality/water/industry/review/documents/ofwat-guidance080922.pdf Back
6
The 49 areas where local planning authorities are willing to
pursue housing numbers over and above what they are obliged to
deliver. Back
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