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Written Evidence Submitted by the Wildlife Trusts (FLO0101)

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Written Evidence Submitted by the Wildlife Trusts (FLO0101) Written evidence submitted by The Wildlife Trusts (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 England 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
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