CLA comments on the Blyth Estuary Strategy

The CLA has produced robust comments on the Environment Agency's consultation on the draft Blyth Estuary strategy (see below) and is actively involved in further developing this strategy as well as and the Suffolk Shoreline Management Plan.  The Blyth plan is the first of many estuary plans which are being developed using the principles contained within Defra's Making Space for Water policy. 

Details of the Blyth proposals are available on www.suffolkestuaries.co.uk/Blyth/default.htm  and the progress on the SMP can be viewed on www.suffolk.smp2.org.uk

CLA comments on the draft Blyth Estuary Plan

The Country Land and Business Association (CLA) is a national organisation representing 38,000 members who collectively own and manage the majority of the rural land in England and Wales. Our members run more than 250 different types of businesses in rural areas including agriculture, forestry, fisheries, renewable energy, food, tourism, recreation and other rural businesses.  They lay at the heart of the rural economy, rural society and not least the rural environment.  Availability of fresh water, flood and coastal defences are important concerns for them, and are, in turn, influenced by their land management activities. We have members who own land in the area affected by this strategy. 

At the time of the first consultation on this strategy we made comments about the lack of investment in maintaining flood defences over previous decades and expressed concern that endless studies and strategies simply put off any action, leaving fewer choices for the future.  In the past four years the Environment Agency (EA) neglect of defences in the Blyth estuary has resulted in our worst fears – that abandonment is now regarded the only cost effective option along much of the estuary. 

In our view a policy of 'no active intervention' along the majority of the estuary is not an option.   It is false economy and unsustainable. 

We are troubled that the Environment Agency is implementing the proposed strategy ahead of the public consultation.  Following last November's storm surge defences were breached and a decision taken not to repair them – contrary to the previous 'hold the line' strategy.  How can the consultation on this strategy be meaningful if decisions are being made ahead to follow the proposed strategy ahead of the close of public consultation?

Whatever definition of 'sustainable' is chosen there is always the phrase "meeting the needs of the present without compromising the ability of future generations to meet their needs".  Abandonment of existing defences will irreversibly change the estuary and limit the options available to future generations.  In addition it is likely to seriously damage the local economy and alter the environmental assets of the area.   

At a time when world food supplies are of increasing concern, coupled with the likely effects of climate change on agricultural production, the loss of production potential by inundating agricultural land can hardly be seen as leaving future generations able to meet their needs.  In addition, the existing agricultural economy in the locality will be adversely affected by saline contamination of water abstraction sources.

The strategy should be based on the premise that ways should be found to defend every asset unless there is a good reason not to.  The strategy should clearly demonstrate that the new estuary shape will in future, be easier and cheaper to defend and that the local economy, historical assets and environment are better able to survive in the long term.  In our view the basis on which the strategy has been developed does not demonstrate this satisfactorily.

The strategy area is an important location for tourism and recreation which are essential to the current and future economy of the area.  The potential damage to the tourism associated with Southwold harbour and Walberswick beach is particularly worrying.

As a result of the introduction of landfill tax there is a large demand from contractors for sites on which to place good quality by-product clay sub-soils.   We believe this must be considered as a cost-effective option for repairing and enhancing the earth banks.   In its cost-benefit analysis the EA introduces a significant assumed cost for bringing clay to seawalls for maintenance or improvement.   Contractors will now pay for the privilege to bring clean clay to a site which would completely revolutionise the cost benefit in relation to flood defences.   On that basis it is very misleading to suggest that banks/walls protecting farmland are no longer worth maintaining.   

We have severe reservations about Defra's cost:benefit guidelines and priority criteria that are being used to judge cost effectiveness.  They take little account of socio-economic benefits, the value of historic assets, recreation and tourism in the area, nor the impact on infrastructure and utilities (roads, water abstraction points, sewerage, electricity supplies, etc).  In addition the value of agricultural land and future food production potential is grossly undervalued.

Property is a highly valuable resource.   The publication of the strategy has already resulted in uncertainty as to whether houses are likely to be flooded and has a considerable impact on property value.   Government indifference to property which may be affected by flooding is causing owners hardship, mental anguish and loss of asset value, plus difficulty with insurance.  The Association of British Insurers recently suggested that they would not insure properties unless a 1 in 75 year standard of flood protection was available.  The strategy has identified a number of properties that will have an increased flood risk.  Is the full economic implication, including loss of insurance, being properly considered?  We think not.

Access to properties and commercial transport is vital and the proposals appear to increase the risk of flooding and disruption to the A12 and A1095 and minor roads in the area.  The economic cost of such disruption and the implications on everyday lives has not been properly assessed.  If public funds are removed from flood defence they will be needed in even greater amounts to raise/move the A12 at Blythburgh to ensure access to the coast.  It is madness simply to move spending from one public budget to another and multiply the amount tenfold at the same time!

The estuary and flood plain contains many important environmental sites that need to be protected wherever possible, as relocation of new habitats is an expensive option.  It appears inequitable to be spending funds on recreating habitats whereas no help is forthcoming for those who lose their homes or business assets as a result of withdrawal of maintenance of flood defences. 

We encourage our farmers and landowners to participate in environmental stewardship schemes and become involved in any exercise to identify land that could potentially be used for managed realignment to give better long-term flood protection with the added benefit of habitat enhancement.  However, this option for land management should remain voluntary and result in greater flood protection rather than habitat creation alone. 

We are concerned that the proposed changes to the estuary – and similar policies applied to the other Suffolk estuaries - will result in serious changes to the landscape and the ability of the public to access that landscape, which in turn will alter the valuable and important features of the Suffolk Coast and Heaths Area of Outstanding Natural Beauty.  This does not appear to have been properly considered, nor the economic losses that could be sustained if the number of visitors to the area is affected.

Whilst supporting any initiative to protect and enhance the natural environment, we are concerned that the Habitats Regulations are being over-zealously interpreted so as to prevent necessary flood protection work and are stifling innovative solutions to flood management. 

We accept that Government has limited funds to spend on flood and coastal defences in rural areas, but there are many ways of spending the money more wisely  - see example above relating to use of 'waste' soils.  In addition we see no reason why private and community funds cannot be included in developing this strategy.  There are, for example, some landowners who would be willing to assist in repairing, maintaining or strengthening the sea walls around their land – which would benefit many others.  In this respect CLA is working with the Environment Agency and Natural England (nationally) to develop a working protocol on the issue of landowner maintenance of sea walls.

The whole issue of flood risk and coastal management is a complex and difficult one.  We hope that a policy of repairing and maintaining the existing defences in the short term, coupled with proper integrated coastal zone management will allow a sustainable future for all. Such policies should be formulated with the involvement of stakeholders and local communities and should recognise the range of interests that exist in the coastal strip, and should take account of the shoreline management plan and local authority spatial and regeneration plans.   It is essential that adequate resources are made available to undertake this integrated approach. This must include support that recognises the needs of the rural economy and the impacts on individual land and property owners where they are disadvantaged by proposals that have wider public benefits. The analysis of costs and benefits must recognise the true financial costs involved in the management and maintenance of essential public assets. 

We welcome further involvement in the development of the plans for the Blyth and other Suffolk estuaries.