Written Evidence submitted by the National Trust (FCC0009)

The National Trust is a charity founded in 1895 by three people who saw the importance of our nation’s heritage and open spaces and wanted to preserve them for everyone to enjoy. More than 120 years later, these values are still at the heart of everything we do. We look after special places throughout England, Wales and Northern Ireland for ever, for everyone.

1. The nature of the problem and what we would like to see

1.1 The National Trust welcomes the EFRA Committee Inquiry on Coastal Flooding & Adaptation to Climate Change. The inclusion of the word adaptation marks the beginning of an important shift from historic coastal flood and erosion risk management practice based on an approach characterised as ‘defend or do nothing’, to a more welcome adaptive approach to managing coastal change.

1.2 The National Trust has considerable interests around the coasts of England, Wales and Northern Ireland, approximately 10% of the total length of coast. The National Trust aspires to deliver an approach to managing coastal flooding and erosion based on the principles that sit under the banner of our Shifting Shores [1] advocacy work, namely; taking the long view, adapting to change, working with others and working with natural processes

1.3 The impacts of climate change at the coast are becoming more apparent. In 2018 the Committee on Climate Change’s Adaptation Sub-Committee investigated the long-term challenges of managing England’s coastline against the backdrop of a changing climate.

Overall the report [2] concluded that the current approach to coastal management in England is unsustainable in the face of climate change.

The key findings being that:

• Coastal communities, infrastructure and landscapes already face threats from flooding and coastal erosion. These threats will increase in the future.
• In the future, some coastal communities and infrastructure are likely to be unviable in their current form. This problem is not being confronted with the required urgency or openness.
• Sustainable coastal adaptation is possible and could deliver multiple benefits. However, it requires a long-term commitment and proactive steps to inform and facilitate change in social attitudes.

1.4. Over the past 15 years the National Trust has undertaken a phased and detailed approach to assessing the implications of sea level rise, increased storminess and thus the impacts of coastal change at our places through our Coastal Risk Assessment. This is complimentary to the public process of Shoreline Management Planning that occurs in England and Wales.  We are using this information to develop Coastal Adaptation Strategies at our priority coastal change locations. (Map One)

2.  Addressing the specific questions posed by the EFRA Committee Inquiry on Coastal Flooding & Adaptation to Climate Change

Q1. What are the risks and consequences of coastal flooding?

There are a number of important physical characteristics associated with coastal flooding that shape the risks and consequences of coastal flooding:

• UK coastal flood risk is expected to increase over the 21st century and beyond under all emission scenarios considered. This means that we can expect to see both an increase in the frequency and magnitude of extreme water levels around the UK coastline.[3]
• Hard coastal defences such as concrete walls and flood banks have a finite lifespan, and will be increasingly prone to failure in response to sea level rise. As a consequence it will become more technically challenging and costly to replace sea defences as they reach the end of their design life.  Maintenance costs will also rise if existing defences are to be kept in good working order.
• Sea defence structures often cause unwelcome side effects such as beach lowering in front of sea walls, and as a consequence of groynes, the starving of sediment supply to neighbouring coasts, in essence ‘chasing’ the problem along the coast. Bigger future sea defences will exacerbate these negative geomorphological responses.
• Coastal flooding can occur solely as a consequence of flooding from the sea but it can also occur in combination with fluvial and pluvial flooding, underlining the importance of a joined up approach to Catchment Flood Management and Shoreline Management Planning
• Changes in groundwater levels at the coast, in response to sea level rise, will impact on some coastal communities, subject to geology, hydrology and topography. Groundwater changes can force increased land instability leading to subsidence, or saline intrusion into groundwater, impacting on drinking water aquafers and the fabric of buildings

The key risks and consequences of coastal flooding:

• Public safety and welfare is at risk as a consequence of inundation of coastal towns and villages, with the potential for an immediate risk of loss of life, and longer term consequences for welfare as communities impacted by coastal flooding try to recover. Work by the Joseph Rowntree Foundation [4] has highlighted disadvantaged communities as being disproportionately affected by coastal and fluvial flooding and coastal erosion. This is because social housing has historically been developed in areas prone to flooding, and because these communities lack the resources, through for example lack of insurance or savings, to begin the process of recovery. It is recognised that significant advances have been made in weather forecasting and storm tracking, and therefore the ability to communicate timely and accurate flood alerts that encourages people to move to safe places of refuge in anticipation of flood events.
• Critical Infrastructure in the form of roads, rail, waste water treatment works, port facilities, electricity supply networks and drinking water supplies are all at risk from coastal flooding.  Much of this infrastructure was put in place at a time that predates awareness of the risks and consequences of climate change driven sea level rise and the associated increases in the potential for coastal flooding.  Many commercial businesses are at risk of coastal flooding with potential for disruption to the often already fragile economies of coastal communities.
• Cultural heritage and the historic environment is at risk from coastal flooding. Historic buildings and archaeological sites can be directly and detrimentally impacted by coastal flooding, coastal erosion and combined coastal and fluvial flooding. Changes in groundwater will lead to the waterlogging of some archaeological sites.
• Wildlife and the natural environment are at significant risk as protected habitats and species become impacted by coastal flooding. There is an extensive network of key wildlife sites behind seawalls, it will not be possible to conserve all of these in situ, adaptation will be needed. Habitats such as saltmarsh and sand dunes additionally provide excellent natural sea defences but are vulnerable to coastal flooding and often subject to coastal squeeze, i.e. the habitats lack the ability to roll-back and reform inland due to the presence of seawalls or a lack of accommodation space. We need to adopt a Natural Flood Management based approach as one of the key adaptive measures in response to climate change driven coastal flooding.

Q2. What progress has been made to implement coastal erosion and flooding adaptation measures, and how much more still needs to be done?

What progress has been made?

To date very little progress has been made to implement coastal flooding adaptation measures.

In England and Wales we do have an established, open and inclusive process of Shoreline Management Planning but as we come towards the midpoint of the first 20 year period of these plans it is clear that many of the difficult decisions, about moving from a policy of ‘Hold the Line’ to a policy of ‘Managed Re-alignment’ or ‘No Active Intervention’ i.e. adaptive measures, are simply being pushed into the future.  Most often this is for reasons of short term political expediency, combined with a lack of leadership around how we need to embrace coastal flooding adaptation, however challenging and unpalatable this might seem. This point is underlined by the Committee on Climate Change’s Adaptation Sub-Committee evidence based assertion that in the future, some coastal communities and infrastructure are likely to be unviable in their current form [and that] this problem is not being confronted with the required urgency or openness.

Research commissioned in 2015 by the National Trust [5] to examine how far public policy has advanced in pursuit of more adaptive responses to managing coastal flooding and erosion revealed that as a society we continue to ignore the known risks associated with coastal change. This research highlighted that in England in 2005 the number of buildings at medium to high risk from coastal flooding (as distinct from combined coastal and fluvial flooding) was 117,000. By 2015 this had grown to 129,000 – an increase of 10%. This evidence shows that new houses and businesses are still being built in areas prone to coastal flooding and erosion.

On a more positive note our research also showed that in this 10 year period a range of potentially helpful public policies have emerged that seek to encourage adaptive measures, however the evidence suggests that these strategic policies are not yet informing practice on the ground. For example, since 2010 Local Planning Authorities in England have been able to create Coastal Change Management Areas (CCMAs) through their local plans. These CCMAs allow councils to ensure new development doesn’t take place in areas at risk of coastal flooding and erosion – and can also inform plans to adapt or relocate existing ‘at risk’ properties. Yet in 2015 only 29 of England’s 94 coastal planning authorities were using CCMAs and the situation is not thought to have improved significantly in the last four years.  A key dis-incentive for Local Planning Authorities to adopt CCMAs is the need to deliver on targets for new housing.  This leads to land being allocated for new housing that sits within areas vulnerable to coastal and fluvial flooding on the basis that flood defences are constructed as part of the development. This protection may be adequate to reduce the likelihood of flooding based on the understanding of current flood risk but does not safeguard against projected future flood risks over say a 100 year time frame.

How much more still needs to be done?

In our view, and based upon our experience the following key challenges need to be addressed by all concerned with coastal flooding & adaptation to climate change:

• Ensure effective joint working across government departments and agencies, to turn coastal adaptation policies and strategies into tangible practice on the ground
• Ensure local authorities and the Environment Agency lead collaboratively on coastal adaptation – and that they have the right policies, tools and resources to achieve this
• Support the regional Coastal Groups so they can in turn provide effective support to government and the relevant agencies at all levels.
• Support innovation in coastal risk management – so that those at risk of flooding or erosion have a wider range of choices to manage their risk – a Pathfinder approach
• Maintain active and on-going engagement with coastal communities at risk

Q3. Is the application and approvals process for coastal erosion and flooding adaptation measures working effectively? If not, how could it be improved?

It is unclear to the National Trust that such an application and approvals process, targeted specifically at coastal erosion and flooding adaptation measures exists.

The main mechanism of Flood Defence Grant in Aid is geared towards hard, and occasionally softer engineering schemes, rather than being used to support adaptive measures in the form of managed re-alignments and roll-back.

The situation would be improved if a percentage of the Defra FCERM budget was ring fenced for exclusive use to fund adaptive and innovative approaches to managing coastal flooding and erosion.

There would also be merit in requiring those with responsibility for providing coastal defence structures to demonstrate that they have considered adaptive measures as part of their scheme, through an options appraisal process.

Q4. Is adequate funding available to counter coastal erosion and build and maintain coastal defences?

The Defra FCERM budget over the current period is significant and it is welcome that FCERM expenditure has been maintained.  However it is also clear that almost the entirety of this budget is spent on hard coastal defences and that for the reasons outlined in response to Q3 above coastal flood and erosion adaptive measures and approaches tend to be marginalised, if not entirely overlooked.

The cost benefit analysis (CBA) process that is used to determine the funding of coastal flood and erosion risk management schemes may be another factor that discriminates against coastal flooding adaptation measures, and would warrant review. In our view little effort is applied to valuing benefits linked to coastal erosion; sediment from eroding cliffs feeds beaches and allowing estuaries to respond to sea-level rise. The value of these ecosystem services is largely unrecognised but will be essential in allowing our coastlines to evolve and adapt to climate change.

Support for adaptive measures to manage coastal flooding and erosion would contribute to restoring natural processes to our coasts, which can deliver multiple benefits where flood risks can be mitigated, new wildlife habitat can be developed and access to nature and landscapes can be enjoyed by people.  These aspirations align with those of the 25 Year Environment Plan and delivery of the plan through a nature recovery network.

Q5. Is there a transparent process, criteria and timeframe for determining when to support or withdraw from coastal erosion and flooding adaptation measures, and does the process inspire public confidence in decision-making?

As stated in response to Q5 the SMP process has much to commend it. It provides a solid scientific evidence base in relation to past, present and projected future changes at the coast.  It takes a long term view based on how each section of coast is likely to change over three epochs (0-20yrs, 20-50yrs and 50-100yrs) It also sets one of four policies for managing each coastal cell or sub-cell, with the ability for a policy to change as we move from one epoch to the next, for example moving from a policy of hold the line in Epoch 1 to managed realignment in Epoch 2.

The problem arises however when specific coastal communities face the actuality of moving on from hold the line, where hard coastal defences have been maintained but have come to the end of their design life, and new hard defences cannot be justified.  In these circumstances communities are faced with the uncertainties that accompany a switch to managed re-alignment or no active intervention.  Our experience in managing our coastal places, where big changes in our approach to managing flood and coastal erosion risk management are concerned, is that considerable resources are required to support adequate community involvement, such that a shared understanding of the need to accept change can be realised.

Too often those us involved professionally in FCERM make assumptions about public and community understanding of living with change at the coast.  Furthermore there is a disconnect between shoreline planning and land use planning as outlined in the answer to Q6 below.  In tandem these assumptions and the failure to embrace land use planning as an integral part of managing change at the coast, through for example the use of Coastal Change Management Areas, undermines public confidence in decision making. This is particularly the case when it comes to deploying novel yet untested adaptive approaches to managing coastal flood and erosion risk. 

To tackle this a new emphasis needs to be established and maintained on active and on-going engagement with coastal communities at risk.  The Defra Pathfinders of a decade ago sought to do this and with some considerable success, and this pathfinder or innovative approach should be reinstated utilising, as necessary, funding from the overall FCERM budget.

In addition HCLG need to take a more proactive role in promoting land use planning as an integral part of FCERM management, sharing the burden of FCERM with Defra on a more equitable basis than has occurred to date.

Q6. This year, the UK Government will publish its long-term policy statement on flooding and coastal erosion, and the Environment Agency will issue a new 50-year strategy – what should they each prioritise?

We believe that government priorities should be to:

• Revise planning frameworks and guidance to make Coastal Change Management Areas (CCMAs) a requirement for local plans, where risk areas are identified.
• Provide greater detail on coastal change management in all planning guidance – including that for Neighbourhood Plans
• Consider the advantages and disadvantages of elevating SMPs to the status of statutory Plans
• Review the cost benefit analysis (CBA) process that is used to determine the funding of coastal flood and erosion risk management schemes. The review should seek to determine whether the current 8:1 CBA multiplier discriminates against coastal flooding adaptation measures, and what improvements might be made.
• Maintain strategic coastal monitoring to provide an evidence base for decision making on coastal protection and adaptation and extending the monitoring that takes place to include impacts on the historic environment.
• Develop a Defra ‘innovative funding’ approach to encourage  coastal adaptation, by for example ring fencing a percentage of the Defra FCERM budget for exclusive use to fund adaptive approaches to managing coastal change.
• Harness adaptive approaches to coastal flooding and erosion as a means to deliver on the 25 Year Environment Plan, utilising land management policy and funding (such as agri-environment schemes) as part of the delivery mechanism. The statement and strategy should make clear what the contribution of action at the coast will be towards the Government’s wider environmental ambitions in the 25 Year Environment Plan, such as the Nature Recovery Network.

We believe that Environment Agency priorities should be to:

• Ensure Shoreline Management Plan (SMP) policies are implemented through local plans, and that SMP reporting is improved.
• Refine guidance for implementing SMPs to
• reduce the risk of difficult decisions being deferred
• build in a requirement for periodic (10yr) formal SMP review to ensure the right evidence based policy is in place for each section of coast. At present in some SMPs blanket policies of Hold the Line across all 3 epochs are being deployed when in reality this is likely to be difficult to deliver over a 100yr time frame.
• Require reactive review in response to storm events and encourage, an evidence based bringing forward of policies from future Epochs in response to the impacts of specific storm events.
• Develop a performance measure on coastal adaptation to sit alongside the existing Environment Agency performance measure on coastal erosion.
• Assess all coastal defence schemes on the basis of their ability to deliver natural flood management and working with natural processes based approaches
• Work with Historic England to bring the monitoring of the impacts of coastal flood and erosion on the coastal historic environment into the orbit of the strategic coastal monitoring centres.

3. Further information

3.1 The National Trust, with more than 120 years’ experience of coastal management, would welcome the opportunity to contribute further to the EFRA Committee Inquiry on Coastal Flooding & Adaptation to Climate Change

4. The National Trust and the coastal environment – some detail

4.1 The National Trust is one of Europe’s leading conservation charities, with over 5 million members and 70,000 volunteers.  We own and actively manage ten percent, or nearly 1200 km, of the coast and estuaries of England, Wales and Northern Ireland for nature conservation, landscape, cultural heritage and public access. We are committed to finding solutions for the sustainable management of the coast.

4.2 Over the past 15 years the National Trust has undertaken a phased and detailed approach to assessing the implications of sea level rise at our sites through our Coastal Risk Assessment. The Coastal Risk Assessment (CRA) has three distinct phases: 

• CRA1 completed in 2005 identified which Trust sites were at risk as a consequence of coastal change.
• CRA2 completed in 2008 has examined in greater detail the impacts of increased coastal erosion and flooding at a site-specific scale.
• CRA3 or the development of Coastal Adaptation Strategies (CAS) for ‘hotspot’ coastal change sites has begun. Map One indicates CAS locations.

4.3 The National Trust’s perspective on the issues being considered by the EFRA Committee Inquiry on Coastal Flooding & Adaptation to Climate Change is based on:

• Our statutory purpose of conserving and promoting access to the nation’s natural and cultural heritage in perpetuity – we are a steward of special and fragile places for ever, with decisions taken for long term public benefit. We are actively involved in the management of 90 sites around England, Wales and Northern Ireland that are on the frontline of facing up to the impacts of climate change induced coastal change
• Our significant experience of coastal management  – we have decades of expertise in understanding and managing risks and undertaking our conservation work through the ‘management of change’, working with natural processes wherever possible.
• Our public communications and engagement at local, regional and national levels, indirectly through the media and directly through interpretation and events at our sites – we have the potential to reach millions of people and promote greater understanding of the importance of adaptive approaches to management to deal with coastal change.
• Our partnerships, with local communities, neighbouring land owners other organisations and agencies – we actively want to learn from others and share our own experience and to manage our sites within their wider coastal context.

5. References

[1]Shifting Shores – https://nt.global.ssl.fastly.net/documents/shifting-shores-report-2015.pdf

[2] Managing the coast in a changing climate, Committee on Climate Change, 2018

[3] UKCP18 https://www.metoffice.gov.uk/pub/data/weather/uk/ukcp18/science-reports/UKCP18-Overview-report.pdf

[4]Impacts of climate change on disadvantaged UK coastal communities, Joseph Rowntree Foundation, 2011

[5] Shifting Shores +10. Public Policy and adaptive approaches to coastal change management: How are we doing? 2015, CH2M

29 April 2019

Map 1