Submission to Environmental Audit Committee Inquiry on flood resilience in England

Question continued: What role can natural flood management techniques, such as wetland restoration and tree planting, play in enhancing flood resilience while contributing to broader biodiversity and climate objectives?

1. Characterisation of ‘grey’ hard-infrastructure and ‘green’ nature-based solutions, typically referred to as Natural Flood Management (NFM), creates a false dichotomy as:

• there is a spectrum of solutions between NFM and hard engineering approaches, all with potential for co-benefits of varying types and magnitudes.
• there are multiple dimensions to ‘naturalness’ which make it difficult to define ‘natural’ or ‘nature-based’.
• ‘grey’ and ‘green’ approaches should be considered together in an integrated manner rather than as alternative competing approaches.

Recommendation: Approaches and programmes to improve flood resilience should move away from a binary categorisation (green/grey) and allow for integrated, hybrid approaches which can be implemented across both rural and urban environments.

2. The naturalness of NFM (or nature-based approaches) should be considered in terms of:

• materials (i.e. local/native or artificial/foreign)
• context (i.e. would that feature occur in that landscape naturally)
• size/number (i.e. would that number or that size of features occur naturally?)
• maintenance/management (i.e. does the feature require maintenance or is it left to evolve naturally?).

3. These dimensions of naturalness of NFM installations are important as they will affect their ability contribute to broader biodiversity and climate objectives. There are trade-offs between maximisation of ‘natural’ (and accompanying co-benefits) and optimisation towards flood risk reduction. For example, a leaky barrier may reduce flood risk better if fixed in place, built using an engineered arrangement and/or regularly maintained. However, these three factors could reduce the long-term biodiversity benefits. Therefore, benefits of potential NFM schemes and their contribution to broader climate and biodiversity objectives should not be taken for granted or oversold.

Recommendation: Implementation of nature-based approaches should be guided by nuanced assessment of co-benefits based on scheme design, explicitly acknowledging the dimensions of ‘naturalness’ and potential trade-offs with flood risk benefit.

Question continued: What changes, if any, should be made to the next iteration of the Flood and Coastal Erosion Risk Management (FCERM) investment programme to improve its outcomes?

4. Our research shows that the two recent flagship NFM programmes (launched in 2017 and 2023) resulted in funding being disproportionately allocated to less-deprived areas. These unintended consequences were evident at both the application and funding stages and emerged as a result of the competitive funding process.
5. These findings are consistent with international literature that shows how competitive tendering approaches to environmental management can benefit certain communities with greater skills and capacity and exclude marginalized groups.
6. This is contrary to the aim of Defra’s Flood and Coastal Erosion Risk Management (FCERM) budget which seeks to prioritise funding for more deprived communities. The UK has committed to increasing to expanding the role of NFM within FCERM. In doing so, we strongly advise that funding allocation processes are examined to ensure equitable outcomes. Alternative approaches may include stratifying the tender process or allocating NFM budgets within existing FCERM processes as part of an integrated approach.

Recommendation: Alternatives to open competitive grant funding should be considered for future NFM funding schemes to ensure equitable outcomes.

7. Due to resource constraints, NFM schemes often have limited, if any, funding for monitoring and maintenance which jeopardises the long-term sustainability of NFM measures. Within the 2023 NFM programme, funding was available for monitoring but not for maintenance. Many NFM schemes are led by Local Authorities who are unable to claim FCERM Grant in Aid towards future maintenance and monitoring costs. This is not the case for conventional flood defences constructed by the Environment Agency. Whilst Local Authorities do have other funding streams available, which the EA can’t access, they are for purposes besides flood management.
8. Consequently, there is a lack of evidence to support the realisation of many of the co-benefits central to NFM and lack of resource to maintain benefits. NFM schemes often have no formal long-term monitoring provision or monitoring is restricted to the minimum monitoring requirements which typically focus on water levels (primary benefit). Empirical monitoring and modelling studies within the reviewed NFM literature rarely quantify benefits beyond flood risk.
9. The evaluation report of the 2017-2021 NFM investment programme highlighted “more work is required to implement nationally consistent ways of recording data and information from NFM projects across England”. From conversations with recipients of funding from the 2023 NFM programme, it is apparent that monitoring is still primarily focused on flood risk benefit. To ensure NFM contributes to broader biodiversity and climate objectives, monitoring of co-benefits is essential.

Recommendation: Ongoing resource should be allocated to the long-term monitoring and maintenance of benefits (e.g. flood risk, biodiversity) for new and existing NFM schemes.