Memorandum by the National Farmers' Union
NEW PLANNING POLICY GUIDANCE NOTE 25: DEVELOPMENT
AND FLOOD RISK: CONSULTATION DRAFT
The National Farmers' Union (NFU) welcomes the
opportunity to submit views on the new planning guidance which
has been issued for consultation. We represent some 70,000 agricultural
and horticultural businesses for which the issues presented by
flooding, whether inland or from the sea, are of crucial importance.
2. COMMENTS IN
The recent storms have been the worst in 200
years in some areas and there has been extensive damage to farms
and operational losses. We are compiling a report of the impact
of the weather on farmers to submit to the Agricultural Minister
and we welcome the Government's commitment to help.
However, there have been a number of articles
in the national media suggesting that agricultural practices are
responsible for this year's floods. The main points that are being
1. the increase in winter cereals;
2. overgrazing in uplands; and
3. increased land drainage.
Many of these points are inaccurate for the
In total the area under winter wheat has only
increased by 25 per cent in the past 20 years and has hardly changed
since 1984. Many of the flooded areas have very little winter
cereals and this year only 30 per cent of winter cereals have
been sown. Also, we believe that the assumptions of enhanced run-off
from winter cereal fields is based on a very limited dataset.
Indeed, the experience of many farmers is that as crops such as
winter wheat are sown in September/October the established root
system prevents erosion by the time the autumn rains occur.
It is also important to note that when rain
falls on saturated ground it will run-off irrespective of land-use.
We do not believe there is evidence to support
the theory that this years floods have been caused (or significantly
augmented) by overgrazing. Indeed, the flooded river catchments
include many rivers with "undergrazed" uplands, such
as the Derwent.
However, "overgrazing" is widely perceived
as a major environmental concern in upland areas. In our experience
"overgrazing" covers a broad range of environmental
scenarios from a few isolated cases of agricultural overstocking
to concerns about the loss of regular shepherding. Undoubtedly
the continuing pressure on upland farm incomes has only accentuated
the loss of experienced upland shepherds, with the result that
sheep flocks can become concentrated in more sensitive upland
habitats. In summary, declining farm incomes and consequent restructuring
cannot be disassociated from the extensive problems caused by
grazing upland habitats.
Farmland is drained to allow access and increased
productivity. This practice has been carried out for hundreds
of years. It is clear that land drainage will increase the peakiness
of hydrographs. However, we would point out that drainage from
agricultural land is slower than that from hardstanding in urban
areas and that the lack of sustainable urban drainage systems
(SUDS) is probably a more important factor in flooding. We would
contend that the flooding in areas such as York have been significantly
augmented from urban run-off.
3. GENERAL POINTS
All human activity near river systems will have
an impact on run-off however the reason for these floods is the
exceptional rainfall. The NFU believes that in future the climate
will become more extreme and consequently we are taking action
to mitigate against both droughts and flooding.
The NFU is in discussion with a number of NGOs
over long-term proposals that will deliver a more sustainable
method of flood defence such as multi-functional flood storage
on farmland. It may be possible with adequate funding to recreate
riparian wetlands. These could act as flood storage, de-synchronise
farm run-off, increase aquifer recharge, have a biodiversity benefit
and act as a barrier to diffuse pollution. However the development
of any such policy would have to be fully thought through and
rigorously assessed, with the full participation of the farming
community, to ensure long-term sustainability of the solution
and to ensure that adequate funding was in place.
Environment Policy Adviser
17 November 2000