Written evidence submitted by (FLO0101)

The Wildlife Trusts previously contributed to evidence submitted by Blueprint for Water, the water-focussed Working Group of Wildlife and Countryside LINK. This response builds on some of the key points made in Blueprint’s submission and adds further evidence drawing upon the experiences and recommendations of Wildlife Trusts across the country, who are actively involved in delivering natural flood management schemes, and in undertaking conservation land management which also delivers flood risk and other benefits.

Our key recommendation is that a more integrated approach to land and water management must be taken in order to deliver multiple benefits and more cost-effective outcomes. The Nature Recovery Network (NRN), being established under the Environment Bill, will provide a key means of identifying opportunities to deliver schemes which work with natural processes to reduce flood risk, and also provide biodiversity and other public benefits. As recognition increases that activities to reduce flood risk can be undertaken across catchments, rather than just in locations vulnerable to flooding, the forthcoming Environmental Land Management (ELM) scheme will be a significant potential source of funding that can support both specific interventions (e.g. Natural Flood Management techniques, NFM) and wider land management (e.g. soil health) that work with natural processes to deliver flood benefit. Any barriers to the pooling of funding to support such techniques need to be resolved.

1. How effectively do the new Government policy statement and Environment Agency strategy meet the challenge posed by a changing climate?

The long-term thinking and the consideration of climate change that clearly underpin the Environment Agency’s National FCERM Strategy for is a new approach which is not just welcome, but necessary. The strategy acknowledges that “building our way out of managing future climate risks will not always be the right approach” so Government’s rejection of the concept of developing resilience standards could be questioned: such standards could give certainty to communities at risk of flooding or coastal change, providing a clearer ‘offer’ from Risk Management Authorities and making it easier for individuals to then make informed decisions about how they themselves can act to increase their resilience. They would also provide greater certainty to developers and businesses about where to target investment, including those businesses who themselves have a role to play in supporting the resilience of others, such as utilities providers. If Government’s alternative approach is to provide similar benefits, helping communities to respond to climate change and ensuring that FCERM actions are ‘climate-smart’, it will be important to ensure that climate factors and other public benefits are properly valued in cost benefit assessments.

In order to secure such public benefits, Government’s Policy Statement says that “Local flood and coastal erosion plans will link with wider plans for an area such as water resource plans and local nature recovery strategies” (LNRS). This alignment is particularly important on a number of climate-change-related fronts. For example, LNRS may offer opportunities for the Environment Agency (EA) to meet net zero goals in relation to flood schemes, by identifying nature-based solutions or habitat enhancements that can eliminate or offset carbon emissions from FCERM activities. It can also identify opportunities for FCERM activities to help meet the climate challenges faced in other sectors; such as by considering where water resources shortages can be lessened by flood storage schemes which contribute to aquifer recharge, for example.

A measure in EA’s National FCERM Strategy for England is that “From 2021 risk management authorities will work with catchment partnerships, coastal groups, land managers and communities to mainstream the use of nature-based solutions.” The Evidence Directory established by the Working With Natural Processes (WwNP) programme demonstrates that Natural Flood Management approaches can help to reduce flood risk, and that attention should move to demonstrating how NFM approaches can be used most effectively. In this context, we question whether the ambition of Government’s vision to “double the number of government funded projects which include nature-based solutions” is quite right (although welcome); in the face of a climate crisis and nature emergency, implementing measures to mainstream NFM techniques, expanding their use and continuing to add to our understanding of effectiveness may be more appropriate and ambitious objectives than simply considering the number of schemes which include them.

2. Are the current national and local governance and co-ordination arrangements for floods and coastal risk management in England effective?

The national strategic overview and advisory role of the EA will remain important in achieving the integrated approach to land and water management that will be required to deliver reduced flood risk in the face of increasing pressures including climate change. If efforts to deliver a resilient environment are not to be undermined, it will be important for the EA to support the environmental aspects of FCERM delivery by other organisations, and to help them grow their expertise in this area, as these activities may not be as well embedded within those organisations for whom environmental enhancement is not a primary purpose.

In particular, working alongside other Risk Management Authorities and wider partners, EA’s experience in working with natural processes will be important in ensuring that NFM techniques are deployed to maximum effect, and are considered as an integral component of Flood Risk Management (FRM) approaches, rather than as a bolt-on.

The Nature Recovery Network, which will be established under the Environment Bill, will play a key role in helping to ensure that interventions and land management approaches for FRM are delivered in locations and in ways which mean that biodiversity also benefits.

3. What level of investment will be required in future in order to effectively manage flood risk in England, and how can this best be targeted?

It appears unlikely that Government alone will be able to meet the level of investment in FCERM that the country requires. As well as the “£1bn a year for the next 50 years” that EA Chief Executive Sir James Bevan outlined would be needed for the building and maintenance of traditional defences, funding beyond that will be required to invest in resilience).

It will therefore be necessary to ensure that future varied funding sources can be effectively pooled to support the level of FCERM investment needed. Changes already made to the partnership funding calculator (e.g. to risk bands and Outcome Measures for the environment) will make it easier to secure funding for schemes that deliver multiple benefits, and to identify partnership contributions for those which do not qualify for full Grant in Aid funding alone. This is a positive step. As the next 6 year programme is delivered in England, further beneficial changes to the calculator may be identified which could further facilitate the use of natural flood management techniques within flood schemes – such changes should be implemented as a priority since research has increasingly demonstrated that NFM measures are typically extremely cost-effective no-regrets interventions that provide multiple benefits to society including biodiversity enhancements, carbon storage, water quality protection, and opportunities for access and public engagement. Again, the Nature Recovery Network will aid in the identification of locations in which the greatest biodiversity benefits can be delivered by NFM interventions.

Resilient infrastructure and measures such as natural flood management are those where there is the greatest potential to secure support via a variety of funding mechanisms; as well as existing sources, future opportunities include developer contributions to secure Biodiversity Net Gain (already a requirement under the National Planning Policy Framework but specified at 10% under the Environment Bill), Environmental Land Management payments, and corporate and potential future national commitments towards Environmental Net Gain. The partnership funding mechanism must be updated if any barriers to the pooling of these funding sources are identified.

4. How can communities most effectively be involved, and supported, in the policies and decisions that affect them?

Community involvement in policies and decisions can be achieved through consultation, and through close working with landowners and other local stakeholders in the context of the Catchment Based Approach. Learning from the Defra NFM pilots has found that sufficient time must be built into project programmes to allow for local-level engagement and that often scheme details are enhanced as a result; as an emerging area of work with a growing evidence base, time needs to be taken to engage with the communities that could benefit from such techniques to explain their use and benefits, but once engaged, communities can often align behind the concept and use local knowledge to identify additional opportunities for interventions. One of the major values of such nature-based solutions is that typically they are low-cost compared to traditional flood infrastructure, meaning that communities at risk of flooding may benefit from schemes based on NFM techniques where traditional FCERM measures are not cost beneficial.

5. With increasing focus on natural flood management measures, how should future agricultural and environmental polices be focussed and integrated with the Government's wider approach to flood risk?

With regards to NFM, agricultural, environmental and flood policies must be aligned to ensure that delivery in one area does not undermine that in another, and that land managers are supported (rather than penalised) for implementing NFM measures, through both funding & consenting regimes. The forthcoming ELM scheme must include forms of land management that are beneficial to flood risk management but that are not actively encouraged through current land management regimes, such as taking action to enhance soil organic matter. Other beneficial actions can be actively discouraged; for example, the deliberate and planned flooding of agricultural land to create new watercourses and permanent wetlands impacts claims under the Basic Payment Scheme, creating a significant disincentive to the naturalising of catchments and deliberate creation of wetlands. For this reason many NFM projects delivered by Wildlife Trusts have drawn not upon FCERM or land management funding but upon charitable or other finance; for example:  4km of man-made ditches at Eycott Hill Nature Reserve that were draining water from the uplands have been blocked by , slowing the flow into rivers downstream, using funding from WREN and HLF.  are restoring wetlands, floodplains, and riverbank woodlands, to reduce downstream flooding, improve water quality and enhance biodiversity, as part of a Landscape Partnership Scheme.  On a former lowland raised bog which was drained for agriculture, Lancashire Wildlife Trust are raising water levels and growing a permanent cover of sphagnum mosses, beneficial in terms of capturing carbon and improving wildlife sites, as well as regulating water levels within the landscape – the mosses can soak up more than eight times their own weight in water. The work forms part of an experimental demonstration project on “carbon farming” supported by Interreg funding. Elsewhere, NFM schemes have been delivered with FCERM or other EA funding, such as the Staffordshire Wildlife trust led ‘Nature’s Flood Defence’ project which includes in-channel measures, ‘roughening up’ bankside vegetation, creating storage wetlands and increasing infiltration through reverting arable land to grassland. As ELM comes into operation it will be critical that funding through other government and non-government sources can be pooled effectively in order to ensure that synergies between different policy areas can be effectively realised.

Within the land management sector, ELM could be the delivery mechanism which supports a transition away from using land solely for ‘agricultural’ activity towards land being used for the purpose of regulating water quantity and quality, as key public goods. This should include NFM measures, where River Basin Management Plans, Catchment Plans and EA opportunity mapping are used to identify key sub catchments where NFM work could be most beneficial, aiding the targeting of features such as cross slope hedgerows/woodland creation, in-channel features and floodplain storage. A number of land managers remain concerned around financial liabilities if structures were to fail, or about maintenance responsibilities. Designing out risk, best practice sharing amongst practitioners, and the involvement of Landowner representative bodies in advising on mitigating residual risks (e.g. developing appropriate risk assessment processes) will all be important, but for some the provision of maintenance funding via ELM, and assurances around insurance policies, may be the only means of providing the confidence needed to enable projects to progress.

As well as specific interventions, ELM must also encourage wider land management changes that reduce flood risk. Supporting paludiculture (wetter or wetland farming) on upland and lowland peat soils could encourage a move away from current agricultural approaches which are dominated by crop types that are more susceptible to flood damage and require flood risk management and drainage works to ensure success. Moving instead to the farming of novel crops including sphagnum creates a landscape which is more able to absorb and hold water, protects the carbon stores of peatlands and, crucially, can be more lucrative for land managers, helping them to adapt their businesses and practices to be more resilient in a changing climate. In line with the indicated aspirations of the England Peat Strategy (publication awaited), funding and facilitation through ELM could support a move to sustainable soil management with productivity benefits and significant market opportunities as being demonstrated by The Great Fen’s Wet Farming Project ‘Water Works’ (See Pg9 in Let Nature Help (2020) The Wildlife Trusts) Biodiversity delivery is another area where synergies exist but may be difficult to realise due to barriers which prevent integration. Delivering schemes which incorporate or rely upon the restoration of natural processes can be difficult to achieve under the current outcome-driven consenting and funding regimes. Funding approaches and outcome frameworks may need to become less prescriptive and more able to value natural ecosystem function, based on natural environmental processes, if benefits such as flood prevention and biodiversity enhancement are to be delivered in tandem. We must ensure that the funding regime / outcome framework of either policy area does not act as a barrier to implementation, and that co-funding is facilitated for all funding sources (or as a minimum, for those that originate from Government).

6. How can housing and other development be made more resilient to flooding, and what role can be played by measures such as insurance, sustainable drainage and planning policy?

It is crucial that planning reforms do not weaken requirements for sustainable drainage, which would undermine the more holistic approach to surface water management spoken of in Government’s FCERM policy statement, incorporating multi-functional sustainable drainage systems and green infrastructure.

Barriers to effective SuDS implementation need to be tackled, including in particular the issues around adoption and future management; Government have stated that “Developers need to make arrangements to meet the cost of flood resilience measures for the lifetime of new developments” but this may in practice still result in management responsibilities falling to those ill-equipped to deliver them.

With a predicted doubling of the number of properties expected to be built in the floodplain over the next 50 years, it is critical that these properties are sited away from areas that are predicted to most frequently and most severely flood, and are protected by development- and property-level flood resilience features. To this end we welcome Government’s commitment to assess whether current protections in the National Planning Policy Framework are enough and consider options for further reform, and to consider what more could be done in cases where EA’s flood risk advice on planning applications is not followed to ensure that flood risk considerations are more fully addressed. Where advice on the siting of a development is not followed, then more attention must be paid to the provision of flood protection measures at both development and property level. We have previously called for Insurance companies to encourage the uptake of property- level flood resilience measures by offering reduced premiums or excesses for homeowners that undertake property-level protection, and by funding flood resilience measures when paying out for the repair of properties that have been flooded (i.e. ‘building back better’). We are pleased to see this Government support for this approach in the FCERM Policy Statement, which could be used to encourage the uptake of measures which enhance resistance to flooding (water exclusion) as well as recovery from flooding (e.g. use of water resistant materials).

Finally the planning process should seek to deliver FCERM interventions that have additional benefits, such as protecting wider infrastructure (transport routes, and utilities supplies) or reduce the other negative impacts of flooding (for example, Drainage and Wastewater Management Plans could identify opportunities for SuDS features sited to protect homes or infrastructure, which also prevent water ingress to sewerage systems, reducing the operation of polluting Sewer Overflows).

7. What lessons can be learned from the recent winter floods about the way Government and local authorities respond to flooding events?

Recent flood events have highlighted that more could be done to incentivise landowners to make positive changes to land use and land management in critical locations, including in upper catchments and floodplains. The ELM Scheme should incentivise both specific interventions such as Natural Flood Management installations, and broader management measures that enable the landscape to hold more water; in particular by encouraging a focus on soil health, and enabling paludiculture, as outlined above. The restoration of natural function to rivers and floodplains can also help to temper the impacts rainfall (both excesses and shortages), slowing, storing and filtering rainfall to reduce or delay peak river flows, and supporting the recharge of aquifers and the maintenance of river base flows in times of shortage. The restoration of natural ecosystem function also supports the maintenance of characteristic habitats and species populations in line with Government targets for nature’s recovery.

The Nature Recovery Network could identify opportunities to deliver such nature-based solutions to flood risk which also provide biodiversity benefit, and will ensure that flood risk management interventions are not conceived and undertaken in isolation, but are planned in the context of wider catchment management.

Support will continue to be necessary to enable all Risk Management Authorities to engage with opportunities to implement such nature-based solutions; delivering not just for flood risk, but for the restoration of biodiversity and the health of our catchments.

August 2020