North Essex Catchment Flood Management Plan -consultation response

This is the CLA's response to the North Essex Catchment Flood Management Plan (CFMP) scoping report consultation. 

The CLA has an interest and involvement in many CFMPs and welcome the opportunity to respond to the North Essex CFMP consultation document.  We set out some brief observations below and would welcome further involvement in the CFMP process as it progresses.

To view the consultation paper see http://www.environment-agency.gov.uk/regiona/anglian  and follow the link to regional CFMPs

1.           Throughout the document mention is made of intensification of agricultural practices.  The new single farm payment regime makes this an unlikely scenario.  As incentives to produce commodity products reduce further, more land is likely to revert to grassland or be left to regenerate naturally.  There will also be a greater emphasis on environmental management and enhancement.  The CFMP scenarios should be amended accordingly.

2.           The new agri-environment schemes open to farmers will increase environmental management and are a potential vehicle through which agricultural land can be used to mitigate flood risk.  The Higher Level Scheme could prove to be a valuable tool in achieving flood management with both the landowner, wildlife and wider community benefiting. However, to be successful on a catchment scale the HLS needs to be adequately funded (perhaps by being topped up from the Flood Defence budget).

3.           Climate change is undoubtedly a major issue.  However, the long term predictions of the effects of climate change vary widely.  For this reason we strongly believe that CFMPs should take both a short term and longer term view.  We feel it is crucial to maintain existing flood defences to current standards, whilst looking at ways to enhance them through holistic and natural methods.  Unless current defences are maintained and rivers kept flowing options for the future will be limited.  The old adage 'a stitch in time saves nine' is a good one in this context.  We believe the primary objective of the CFMP should be to protect people, property  and infrastructure from flooding and would suggest amendment of the wording of the objectives to this effect.  If the strategy can protect  the environment, why can it not protect people and buildings?

4.           We support the premise that growth and development in Essex will have a significant effect on water management – both in terms of flooding and water availability.  Through the RSS process we have been lobbying for development to be more geographically widespread. to reduce local impact,  and we have emphasised the importance of development taking proper account of flood risk.  The CFMP should stress that there should be no inappropriate large-scale development in flood plains. 

5.           Sustainable development relies on taking full account of economic, social and environmental factors and this is equally true when assessing options for water management.  Much of our valuable environment has legal protection which can lead to lack of consideration being given to socio-economic factors.  It is worth remembering that nothing can be achieved without a healthy economy.  

6.           Whilst supporting the general objective to protect and enhance the environment, we urge you not to confuse environmental enhancement with flood management.  If the former is a result of the latter then it's a win:win situation.  However, there is a tendency for water level management to get wetland SSSIs into more favourable condition, and other environmental enhancements, to be the primary driver for flood management options, rather than the reverse.  The role of the CFMP is primarily flood risk management, with environmental enhancement being a valuable benefit in some instances.  We oppose the use of flood defence spending solely to achieve biodiversity targets.

7.           Funding is a key issue and the measures used to properly assess options available needs to take all factors into account.  Current cost:benefit analysis used to determine flood defence spending is fundamentally flawed – taking little account of the social costs, community views, the effect of 'blight' on buildings and lives in high flood risk areas or the historic and cultural importance of buildings.  Nor does it adequately value agricultural production and land.  The CLA is currently working with Defra on a better, more holistic approach to the cost:benefit analysis giving appropriate weight to all pillars of sustainability in both the short and longer term.

8.           The CFMP process needs to result in a holistic approach and be properly related to other flood and coastal plans.  The consultation process must continue to be open, honest and as wide ranging as possible.  Inevitably, some of the options will be unpalatable to some sectors of the community.  The key to getting 'buy in' lies in proper explanations, honesty and adequate compensation where there is hardship or economic loss.