ADA has responded to the draft National Flood & Coastal Erosion Risk Management (FCERM) Strategy for England that was published by the Environment Agency in May 2019.
The final National Strategy is expected to be published later in the year, alongside an updated policy direction on flooding and coastal erosion by the Government. To help set the right policy to support the new Strategy Defra opened a call for evidence on flooding and coastal erosion in early July, it closes on 19 August 2019.
ADA believes that the draft National Strategy provides England with a good direction of travel for managing flood risk and coastal change. We broadly supports the vision and strategic objectives put forward. If it is to be a Strategy looking ahead to 2100 we must use this chance to be more ambitious about having a holistic approach that is more than just resilient to flooding but tackles water as a resource and embraces water level management.
Correspondingly, the issue of funding cannot be ignored. Without a serious long-term commitment from central Government; the Strategy may be viewed in the future as a lost opportunity. We need effective Government policy on flood risk management to match the Strategy’s ambition with strong multi-year investment for FCERM, not only for capital schemes, but for revenue funding (and therefore maintenance) as well, that can help facilitate wider investment by businesses and communities.
Our members are all collectively in the front line of delivering this Strategy over the next 80 years. It will need us to completely shift the way we look at projects and how funding is allocated. No longer can we simply assess schemes as stand-alone projects, we must co-ordinate our efforts within catchments, and deliver them through strong partnerships to ensure water is managed not only as a threat, but as a resource. A new ‘Place Based Approach’ to the allocation of funding must also be part of this brave new world, valuing what makes a locality important or special, that will enfranchise local communities and partnerships. We need to look at the broad opportunities for investment that bring more integrated multi-functional flood and water management schemes to fruition.
ADA broadly supports the vision and strategic objectives put forward in the draft National Strategy. We think that the following ten key changes would further strengthen it. (Please click on each to expand them)
We think the draft Strategy’s vision and strategic objectives should be made more ambitious in terms of:
The Strategy should ensure that the new concept of standards in flood resilience takes a wide-ranging risk-based approach to FCERM assets and systems within catchments and along the coast. A critical component that needs to be urgently addressed within the Strategy is securing the safe functioning of embanked watercourses, coastal/estuarine embankments, and reservoirs, given the demonstrable risk to life that they pose.
The Strategy’s measures need to establish the clearer alignment of funding streams and direction with other Government departments and agencies in their delivery of infrastructure and management of climate change. At the same time we need to appraise and significantly overhaul the Government’s financial and fiscal mechanisms and processes to enable private finance to better invest in FCERM.
The Strategy needs to more clearly articulate the role of all Risk Management Authorities and Regional Flood & Coastal Committees, in order to provide a clear vision for growing and strengthening them, as competent bodies with skilled and knowledgeable people, to share the load.
Should look more broadly than Natural Flood Management to a range of land management practices that farmers can undertake on productive agricultural land to reduce flood risk, manage water resources and soil. These should be fully developed and incentivised through the next Environmental Land Management Scheme.
Partnership funding needs to empower local decision making for communities, businesses, and local risk management authorities to act to take measures to reduce flood risk.
Needs to better articulate the critical importance and value of maintaining assets and systems across flood and water management. Setting measures to ensure that the most appropriate authority is facilitated to manage each and every stretch of coast and river, such as Public Sector Cooperation Agreements, de-maining and ‘Transfer Powers’.
Appraisal of valuation of benefits is needed to ensure that agricultural land and infrastructure through rural areas is accurately assessed on its economic importance to the UK.
The resilience approach must look to work with land managers to make agricultural land available for water when needed whilst remaining highly productive. There is much more we can learn from Europe in this area in terms of establishing the right package of incentives, reward, and remediation.
FCERM should become a much more integral part of child education throughout the National Curriculum, building greater awareness of the impacts of our changing climate.
Download| ADA’s full response to the draft National Strategy