Select Committee on Agriculture Appendices to the Minutes of Evidence


APPENDIX 2

Memorandum submitted by the RSPB (L 4)

SUMMARY OF RECOMMENDATIONS

  The RSPB recommends that there be a high level target set for the preparation and implementation of strategic inland flood defence planning, along the lines of the high level target that already exists for strategic planning on the coast.

  The RSPB urges Government to undertake a review of the balance of interests represented in all Committees with an influence on flood and water management, including Regional Flood Defence Committees, Local Flood Defence Committees and Internal Drainage Boards.

  The RSPB recommends that the MAFF/DETR review of flood defence funding addresses the:

    —  constraints on strategic planning of flood defences due to ring-fencing of expenditure to Committee areas; and

    —  difficulty in funding schemes with multi-sector benefits for the environment and people, such as schemes to restore floodplains or create washlands.

  The RSPB recommends that the Government adopts a clear presumption against development in the floodplain, with clear criteria for when development will be allowed.

  The RSPB recommends that PPG25 requires local authorities to undertake a Strategic Environmental Assessment (SEA) or environmental appraisals of development plans as a means of dealing with such cumulative impacts.

  There must be changes in funding and institutional arrangements to deliver more environmentally sustainable alternatives.

  The RSPB recommends that MAFF assesses the scope for:

    —  using agri-environment schemes to provide a flood defence function through developing a new Floodplain Stewardship Scheme or creating a new "Flood Relief Option" in Countryside Stewardship, to allow the targeting of agri-environment payments to farmers who offer to manage their land for flood defence and conservation purposes; and

    —  allows the funding of flood defence schemes which incorporate costs for financial incentives for landowners managing their land for flood defence and biodiversity benefit.

  The Government should consider developing a national flood insurance programme.

1.  INTRODUCTION

  1.1  The RSPB welcomed the Agriculture Select Committee's 1997-98 report on Flood and Coastal Defence. The Committee inquiry identified that there were problems with implementing MAFF's flood and coastal defence policy and that major administrative and funding reforms were needed to facilitate this implementation. The RSPB was disappointed by the Government's response to the Select Committee report in that, with a few exceptions, it adopted a business as usual approach. This is unfortunate, as had the Government acted upon the Committee's recommendations in a more enthusiastic way, then some of the impacts of the most recent heavy rainfall might have been avoided.

  1.2  This response looks at the recent floods and analyses Government progress in implementing the Committee's 1997-98 recommendations, focusing on the following issues:

    —  Improving the delivery of national strategy for flood and coastal defence.

    —  Funding.

    —  Integrating flood defence planning within the planning system.

    —  Accelerating the implementation of soft-engineered approaches.

    —  Rewarding individual action benefiting the community.

    —  Role of the insurance industry.

2.  THE FLOODS OF OCTOBER/NOVEMBER 2000

  2.1  The devastating floods over the last month have been the worst for many years. More than 5,000 homes have been flooded resulting in hundred of millions of pounds worth of damage. It is distressing to think that our own management of water and land may have exaggerated these floods making a bad situation far worse. We have made ourselves increasingly vulnerable to heavy rain by

    —  Developing on floodplains: more than two million properties have been built in England and Wales over the last 10 years, paving over a massive area of our land to the extent that this increases run off. Development in the floodplain exacerbates this even further by reducing the natural ability of the floodplain to contain and hold back the flood water.

    —  Agricultural intensification: a long history of agricultural intensification has lead to extensive drainage so that water rushes off farmland much faster than ever before.

    —  Loosing floodplain wetlands: we've drained and filled in 60 per cent of our floodplain water meadows over the last 25 years, water meadows that once acted as a natural safety valve holding back floodwaters so reducing flooding risk downstream.

  2.2  Praise should go to the Environment Agency, emergency services and local authorities who have responded admirably to difficult circumstances. There are undoubtedly lessons to be learnt from these floods. The Government has announced an additional £51 million spending over four years for flood defence works, whole catchment area assessments and making an earlier start to improvements in flood warning. This investment is welcomed, however it must not result in a knee-jerk reaction of building flood defence walls even higher and wider. While some hard engineered solutions will be required for particularly vulnerable urban areas, any new flood defence work must be part of a strategic assessment of flood defence needs which considers both soft and hard engineering approaches.

  2.3  Climate change is likely to mean more and more unusual weather and more floods. With more than 90 per cent of the £380 million spent on flood defence coming direct from the taxpayer the public has a right to ask that this funding is spent in the most sustainable and cost effective way.

3.  IMPROVING THE DELIVERY OF NATIONAL STRATEGY FOR FLOOD AND COASTAL DEFENCE

  3.1  The Committee recommended that:

    —  MAFF and the EA provide clearer guidelines for Regional Flood Defence Committees to ensure that while local needs are respected, the regional targets set also advance relevant national strategic requirements (recommendation l); and

    —  more must be done by MAFF to ensure operating authorities translate national strategic priorities into positive action on the ground (recommendation m).

  3.2  Since the inquiry MAFF have adopted a series of high level targets with operating authorities to ensure that local and regional targets advance national flood defence priorities and that these priorities are translated into action on the ground. These targets have been a useful way forward, especially in helping flood defence operating authorities in translating existing targets into action on the ground. The RSPB particularly welcomed the high level targets to assist with the implementation of the UK Biodiversity Action Plan and Water Level Management Plans and the target requiring operating authorities to produce a policy statement setting out plans for delivering the Government's policy.

  3.3  The RSPB is disappointed that a high level target has not been set to encourage a strategic approach to inland flood defence planning to ensure the potential benefits to society are fully realised. MAFF promoted a strategic approach in its recent Project Appraisal Guidance on Strategic Planning. However, no framework exists for delivering strategic planning for inland flood defence works. The current piecemeal approach ignores the downstream impacts of hard engineering flood defence works, such as the increased flood risk and the possible subsequent need for more costly flood defence works. In response to the most recent floods, MAFF and the Environment Agency are to look at the scope for introducing a catchment based approach for inland flood defence planning. This is welcomed but is important that this take a truly strategic approach and is developed quickly. This can be done by adopting a similar framework to that which already exists for strategic planning on the coast, through the preparation of Shoreline Management Plans (SMPs).

  3.4  The RSPB recommends that there should be a high level target set for the preparation and implementation of strategic inland flood defence planning, along the lines of the high level target that already exists for updating SMPs and preparing strategy plans for implementing SMPs.

  3.5  The Committee recommended that:

    —  the functions of LFDCs and IDBs would be more appropriately discharged by RFDCs, working under the guidance of the EA (recommendation o).

  3.6  There have been few, if any institutional changes, to the make up and structure of the flood defence systems in England and Wales. In our view, the Government missed a major opportunity to reform institutional arrangements and achieve better implementation of flood and coastal defence. Current arrangements are not representative of all local interests and all stakeholders. This particularly applies to members of Internal Drainage Boards who receive funding from local landowners and the local authority on behalf of all rate payers in the district. Membership of IDBs is limited to landowners within the Board area, where the larger the landholding and the higher grade the value of the agricultural land the more votes you have; and to local authorities, whose representatives tend to have agricultural interests. This system has not worked where the objectives for IDBs go beyond agricultural interests, and wider public benefits has been under-represented or ignored.

  3.7  The RSPB urges Government to undertake a review of the balance of interests represented in all Committees with an influence on flood and water management, including Regional Flood Defence Committee, Local Flood Defence Committees and Internal Drainage Boards.

  3.8  The Committee recommended that:

    —  MAFF must develop methodologies for assessing social and environmental criteria for inclusion in PAGN and PAGN should give greater encouragement to projects with multiple functions (recommendation j).

  3.9  Since 1998, MAFF have developed a series of flood and coastal defence project appraisal guidance (FCDPAG) documents designed to provide advice on best practice for the appraisal of flood and coastal defence projects. The full list of titles to be published in this series are: FCDPAG1 overview; FCDPAG2 strategic planning and appraisal; FCDPAG3 economic appraisal; FCDPAG4 approaches the risk; FCDPAG5 environmental appraisal; FCDPAG6 post project evaluation. Not all of these documents have yet been published and it is not clear what, or if, any FCDPAG takes precedence over any other. While not explicit, the signals sent so far suggests that economics still takes precedence. FCDPAG3 on economic appraisal was one of the first to be published. The RSPB was not consulted on this, despite the fact that in some cases this sets the framework for other FCDPAGs. For example, FCDPAG3 set the funding criteria for water level management plans on designated European nature conservation sites and national sites.

  3.10  The RSPB welcomed the publication of a specific Project Appraisal Guidance note for environmental issues since the single focus on economic appraisal in the previous Project Appraisal Guidance Note did not reflect MAFF's policy to "encourage the provision of technically, environmentally and economically sound and sustainable defence measures". However, the strong focus on economic appraisal of environmental assets in this document suggests that as with the previous PAGN, the greatest weight will still be afforded to the economic appraisal. This focus on economics is also is reflected in the draft FCDPAG2 on strategic planning which fails to make full reference to the recently published guidance on environmental appraisal (FCDPAG5), even though full referencing has been made on economic appraisal (FCDPAG3). This again sends the signal that economic appraisal take precedence over environmental appraisal in strategic planning. This discourages multi-dimensional or multi-beneficial solutions.

4.  FUNDING

  4.1  The Committee recommended that:

    —  MAFF and DETR undertake joint review of the current mechanisms for public financing of flood and coastal defence works, to move away from the piecemeal, reactive approach to maintaining defence work towards a considered national strategy (recommendation f); and

    —  the Government radically simplify the existing funding procedures for flood and coastal defence activities, one possibility may be to replace scheme specific grant-in-aid from MAFF and the Welsh Office with block grants (recommendation h).

  4.2  The Government agreed that it should review the current financing mechanisms for flood defence. However, this review has only just started, almost three years on from the Committee's report.

  4.3  The RSPB recommends that this joint review of flood defence funding should address the:

    —  constraints on strategic planning of flood defences due to the ring-fencing of expenditure to Committee areas; and

    —  difficulty in funding schemes with multi-sector benefits for the environment and people, such as schemes to restore floodplains or create washlands.

  4.4  While the Environment Agency is structured to take an integrated approach assessing all the benefits of its work, delivery of this approach is constrained by legislation which ties funding to flood defence alone. The current flood defence funding arrangements present a fundamental block to taking a more integrated approach to flood defence management. Innovative schemes such as washland creation and source control measures designed to serve multiple environmental benefits have great difficulty in getting funded.

  4.5  The funding obstacles the RSPB has encountered include:

    —  government grant-aid for flood defence work can only fund schemes that deliver a flood defence benefit. So while past land drainage and flood defence schemes which resulted in environmental damage attracted government grant aid, schemes and non-scheme solutions which make good environmental losses do not attract grant aid, except where the scheme is to protect a designated European nature conservation site. Schemes are excluded which might be slightly more expensive but are actually more beneficial in that they meet both flood defence needs and wider environmental needs such as enhancing water resources or water quality and restore wildlife;

    —  cost benefit appraisals of flood defence schemes only take into account short term costs and benefits. This can often exclude more innovative schemes which while being more expensive in the short-term, might actually prove more cost effective in the longer term, for example because a shorter length of hard flood defences would need maintaining; and

    —  grant aid only applies to engineering based flood defence schemes. There are other solutions to flooding problems which may be more cost effective than solutions based solely on engineering but which are not considered because they are not eligible for grant aid. For example where flood defences protect isolated properties, it may be more cost effective to use grant aid to help re-locate the people at risk, and then re-align the defences.

5.  INTEGRATING FLOOD DEFENCE PLANNING WITHIN THE PLANNING SYSTEM

  5.2  The Committee recommended that a clear presumption should be made against future development in the floodplain (t).

  5.1  Many floods occur or are exacerbated because of inappropriate development on the floodplain. It is thus vital that floodplains are protected from damaging development. Unfortunately, there are still numerous instances where local planning authorities approve development in the flood risk area in spite of objections by the Environment Agency. Each year planning authorities consent to around 20 per cent of the 1,000 or so applications to which the Agency objects on flood risk grounds. Such decisions only serve to reduce the capacity of the flood plain and ultimately lead to increased flood risk for the development and areas downstream of the development.

  5.3  Earlier this year DETR published a draft of "PPG25 Development and Flood Risk". This offered Government a prime opportunity to adopt the Committee's recommendation t. The draft PPG states that the susceptibility of land to flooding is a material consideration in determining planning application. However, it goes on to say that where other material considerations outweigh this the permission might be granted for a development on the floodplain. The RSPB believes that the Government has failed to adopt a clear presumption against development in the flood plain, unless there are demonstrable interests of overriding importance. The PPG has also fails to provide criteria for when development may be allowed in the flood plain. With too many poorly defined exceptions to the general rule, the PPG will fail to give a clear steer to local planning authorities.

  5.4  The RSPB recommends that the Government adopts a clear presumption against development in the floodplain, with clear criteria for when development will be allowed.

  5.5  The cumulative impact to increased flood risk of new development on the floodplain is not currently assessed by local planning authorities. The RSPB recommends that PPG25 requires local authorities to undertake a Strategic Environmental Assessment (SEA) or environmental appraisals of development plans as a means of dealing with such cumulative impacts. While cumulative flood risk is raised as an issue, the PPG does not provide local authorities with answers as to how to deal with it.

  5.6  As well as preserving the extent of the current floodplain the draft PPG offers an opportunity to bring the floodplain back in some catchments to provide a natural flood defence function. This would allow for "a more holistic approach" to be taken to river management. This could be achieved if the draft PPG encouraged local authorities to allocate those areas of floodplain land that should be used in the future for floodplain purposes.

6.  ACCELERATING THE IMPLEMENTATION OF SOFT-ENGINEERED APPROACHES

  6.1  The Committee recommended that:

    —  There is a need to reduce long term downstream flooding through the gradual, phased removal of some hard engineering constraints on rivers and flood defences now deemed obsolete, and their replacement with more environmentally sustainable alternatives, for example washlands (recommendation x).

    —  The EA and MAFF must give greater priority within national policy to washland creation and source control than has hitherto been the case (recommendation cc).

  6.2  It has been clear from the Government's response to the Committee's report that, while they recognise there could be a greater role for such less interventionist approaches, there is limited action or measures to support implementation of this approach. As a result delivery of this approach is painfully slow. Such schemes are either not being considered as an option, and where they are there they often have great difficulty in being approved. Current administrative and funding arrangements have so far failed to demonstrate that they are capable of delivering integrated flood defence and environmental objectives, and the present attitudes of some flood defence committees and Internal Drainage Boards where agricultural interests remain disproportionately strongly represented can also act as a barrier to such approaches.

  6.3  There must be changes in funding and institutional arrangements to deliver more environmentally sustainable alternatives.

  6.4  There are some examples of such schemes being implemented, see case studies below, although they tend to be smaller scale schemes rather than the larger schemes that have the potential to bring wider environmental benefits through improving water resource security and water quality.

Case study 1: Great and Long Eau, Lincolnshire

  The Environment Agency undertook a small scheme in 1996 to restore the floodplain to enhance flood protection and improve wildlife habitat in the river channel, banks and floodplain. The original flood banks were set back from the river creating an additional 425,000 cubic metres of flood storage at a cost of £60,000. A variety of river and wetland feature were created. The Farming and Wildlife Advisory Group worked with the Environment Agency to help affected farmers present successful applications for compensatory funding from the Countryside Stewardship scheme. This resulted in a more sustainable flood defence system and improved wildlife value.

Case study 2: Bear Brook, Buckinghamshire

  The Environment Agency undertook a small scheme to alleviate flooding problems in Aylesbury. This was achieved by increasing the area of low level wetland beside the river which increased the flood storage capacity to 90,000 cubic metres. The flood storage area was enhanced for wildlife by creating a permanent pond, seasonal pools and scrapes. This resulted in a more sustainable flood defence system and improved wildlife value.

7.  REWARDING INDIVIDUAL ACTION BENEFITING THE COMMUNITY

  7.1  The Committee recommended that:

    —  a robust financial mechanism be put in place for the re-imbursement of property holders and landowners whose assets are sacrificed for the wider benefit of the community (recommendation bb).

  7.2  The Government has not altered it's position that compensation will not be payable in relation to those who suffer the effects of flooding, though payments may be available to landowners in circumstances where quantifiable benefits arise.

  7.3  The RSPB has called on Government to provide financial incentives to farmers to manage their agricultural land for flood defence purposes. For example, the land could be deliberately managed to take flood waters during times of heavy rainfall to reduce flood risk in downstream urban areas. The payments would pay landowners to encourage them to maintain these "washlands" and manage them for wildlife. As well as reducing flood risk, this has the added benefit of improving water quality and water availability in summer months and helps Government meet its obligations in the Biodiversity Action Plan.

  7.4  Case study 1 shows that this can be delivered through targeting of agri-environment schemes, such as Countryside Stewardship and Environmentally Sensitive Areas. However, these schemes have limited funds which might restrict the scale of the project considered. In addition, the lack of strategic planning for flood defence and the apparent lack of co-ordination between the various Divisions in MAFF makes it difficult to target agri-environment schemes to areas of greatest flood defence need.

  7.5  Financial incentives to farmers for maintaining their land for flood defence purposes could be built into the capital costs of a new flood defence schemes. For example, where the Environment Agency has identified that washland creation is the most sustainable solution to a flood defence problem the Agency may consider offering financial incentives to the landowners who will be required to manage their land as a washland. Rather than locking themselves into annual payments, the Agency may consider paying the farmer a lump sum to offset the production loss the farmer will incur over, say, a 20 year period. This should only be payable on the grounds that the farmer accepts this change in land-use and manages the land for flood defence purposes and biodiversity benefit. This will allow the cost of this being included in the capital cost of the scheme, so easing the scheme's progress through MAFF funding requirements.

  7.6  The RSPB recommends that MAFF assesses the scope for:

    —  using agri-environment schemes to provide a flood defence function through developing a new Floodplain Stewardship Scheme or creating a new "Flood Relief Option" in Countryside Stewardship, to allow the targeting of agri-environment payments to farmers who offer to manage their land for flood defence and conservation purposes;

    —  allows the funding of flood defence schemes which incorporate costs for financial incentives for landowners managing their land for flood defence and biodiversity benefit.

8.  ROLE OF THE INSURANCE INDUSTRY

  8.1  The Committee made no recommendations on the role of the insurance industry, but might wish to consider this issue as a result of the recent floods.

  8.2  The current system of private insurance for flooding locks people into a vicious cycle of repair and flood. It does not encourage people to take measures to protect their own property from future floods or to sell and move out of properties in high flood risk areas. For example, in the most recent floods some people found their homes had been flooded two or three times in the last eighteen months. These peoples had only just got their homes in order from the last floods when they were flooded again. The Government should consider developing a national flood insurance programme to break this cycle.

  8.3  The development of a national flood insurance programme could help increase responsibility for flooding and reduce the level of payout insurance companies have to make. People with properties in flood risk areas would be eligible for the scheme. After a flooding event, rather than simply funding the repair of the property back to its original state, the scheme would help finance improvements to properties to reduce the impact of floods and provide assistance when flooding occurs. For example rather than paying to return the house to its original state the insurance company could pay to reduce the risk of damage by redesigning homes against future floods. For example it could pay for: moving all electricity points on the ground floor from ground height up to four feet high; the provision of specially waterproofed wooden boards; to ensure no carpets on the ground floor. The insurance premiums from a housing estate could also pay for the creation of washlands upstream to reduce the risk of flooding in the first place. By paying for such measures, the insurance companies could find they save money by reducing the level of payout from subsequent floods, either because the impact of flooding on homes is less or because the risk of flooding in the first place is reduced. In extreme cases of repeated flooding, the insurance scheme could help people move away from isolated properties in the flood risk area. The United States have developed a scheme along these lines, called the Federal Flood Insurance scheme.

20 November 2000


 
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