Written evidence submitted by the East Riding of Yorkshire Council (FCC0014)
Executive Summary
1.1. The East Riding of Yorkshire is one of the largest local authorities in the country in terms of population and area, covering over 930 square miles. It has a population of approximately 335,900 people and comprises over 300 individual settlements. The largest town is Bridlington with around 35,000 people. Around half the population live in rural communities.
1.2. Geographically, the East Riding is bounded to the east by the North Sea and to the south by the Humber Estuary. The East Riding’s coastline (sometimes referred to as the Holderness coast) begins at Spurn Point at the mouth of the Humber Estuary and extends through the soft boulder clay cliffs of Holderness to the chalk cliffs of Flamborough Head in the north. The East Riding coast is home to the seaside resorts of Bridlington, Hornsea and Withernsea along with numerous smaller villages.
1.3. As a unitary authority, East Riding of Yorkshire Council is responsible for managing the entirety of the East Riding’s 85km long coastline. Parts of this coastline are recognised as suffering from some of the highest rates of coastal erosion in northern Europe, with average annual erosion rates of up to 4m per year. However, rates of erosion are highly unpredictable and localised individual cliff losses of over 20 metres have been recorded.
1.4. Under the Flamborough Head to Gibraltar Point Shoreline Management Plan (SMP) approved by the Secretary of State in 2011, the most prevalent management policy on the East Riding coastline is ‘No Active Intervention’, whereby the natural process of erosion is allowed to continue to shape the coast. Whilst there is an intention to maintain current sea defences (‘Hold the Line’) until 2105 at the towns of Bridlington, Hornsea and Withernsea, and at the strategic locations of Mappleton and Easington, large stretches of the coast continue to be vulnerable to coastal erosion and flooding.
Coastal Flooding
2.1. The main coastal flooding risk in the East Riding of Yorkshire is within the Humber Estuary, (which borders the East Riding to the south), with the settlements of Paull, Hessle and Goole being particularly at risk. As management of flood risk within the Humber Estuary is led by the Environment Agency (EA) through the Humber Flood Risk Management Strategy, it will not be discussed in detail within this response.
2.2. At the southern end of the East Riding coast, at the villages of Easington and Kilnsea, the boulder clay cliffs (10-20m AOD) which make up the majority of the East Riding coast become lower and start to transition into the dune and sand spit system of Spurn Point, increasing the risk of coastal flooding significantly, both from the North Sea and the Humber Estuary. Although defences are currently in place to prevent flooding, both Easington and Kilnsea sit within Flood Zones 2 and 3, and both experienced significant flooding during the tidal surges of 1953 and 2013.
2.3. Indeed, the Flood Investigation Report from the December 2013 tidal surge event detailed that within the East Riding a total of some 300 properties (69 commercial and 231 residential) were directly affected by flooding. Significant areas of agricultural land (estimated at 6000 acres or 2400 hectares) and caravan sites were also affected, along with infrastructure assets including roads, railways, power supplies and sewerage services. Overall it is estimated that the damage caused by the surge within the East Riding was in the region of £13.4m.
2.4. Some coastal flooding does also occur in areas with naturally lower cliffs (e.g. Bridlington, Hornsea and Tunstall), affecting a number of commercial properties, however this is primarily as a result of wave overtopping.
Coastal Erosion
2.5. While coastal flooding is a significant risk at the southern end of the East Riding, the majority of the coastline is made up of higher cliffs, which prevent coastal flooding. These cliffs are however, subject to rapid coastal erosion as a result of their boulder clay geology. This rapid coastal erosion, while not impacting the same number of properties as those at risk from coastal flooding within the Humber Estuary, results in the permanent, rather than temporary, loss of assets. For example, in most cases a flooded house will be inhabitable at some point after a flood event, whereas a house lost to coastal erosion will not.
2.6. There are a number of impacts and consequences linked to coastal erosion on the East Riding of Yorkshire’s coastline, some of which are listed below:
2.6.1.Risk to life – Erosion events are inherently dangerous and can result in loss of life or life changing injuries. During the storm surge in December 2013, a number of residents, whose properties were at high risk from erosion, were evacuated to ensure their safety in the event that rapid erosion undermined their properties.
2.6.2.Impact on health and wellbeing of residents – Living in a property on the eroding coastline has a significant detrimental impact on residents’ mental health and wellbeing due to the stress and uncertainty of the remaining lifespan of their property and the financial burden of losing their home.
2.6.3.Loss of residential properties – Within the East Riding, 51 properties have been demolished as a result of becoming at risk from coastal erosion since 2009. A further 237 residential properties within the East Riding are projected to be lost to coastal erosion by 2105, with 24 of these becoming at imminent risk by 2025.
2.6.4.Loss of businesses – Approximately 44 commercial properties (mainly linked to tourism) are at risk along the East Riding coastline over the coming century. In addition, it is estimated that 427 caravan pitches will be lost to coastal erosion by 2025. This number is especially significant, given the importance which caravan parks play in the coastal economy of the East Riding. A large amount of good quality agricultural land is also lost each year to coastal erosion. Again, agriculture is vital to the economy of the rural East Riding.
2.6.5.Loss of infrastructure – A large amount of vital transport and utilities infrastructure is at risk of being lost to erosion over the next century. An example of this is in south Withernsea, where Holmpton Road is expected to be lost within the next six years, with the A1033 also being lost within the next 100 years. These roads are key transport links connecting Withernsea to a number of villages to the south and to large employers in south-east Holderness and Hull. All essential utilities supplies (water mains, sewage pipes, broadband cables, etc.) for Withernsea are buried under Holmpton Road, which is also a critical route for public transport providers and blue-light services. Additionally the SMP identifies the B1242 at Mappleton, which connects Withernsea (population 6500) to Hornsea (population 8500), requires review in the next 50 years.
2.6.6.Blight – Coastal erosion can result in a lack of investment into infrastructure, private residences and businesses in vulnerable coastal communities. This in turn can lead to a loss of amenity value, a rise in antisocial behaviour, the lowering of property values and the gradual deterioration of communities.
2.6.7.Financial cost to the Council – Coastal erosion results in a financial cost to the Council in a number of ways ranging from direct costs, such as the construction and maintenance of coastal defences or the demolition of properties, to indirect costs, such as a decrease in tourism opportunities due to rapid erosion preventing the construction of beach accesses.
3.1. East Riding of Yorkshire Council has gained a reputation for best practice in working with communities to help them adapt to the challenges and risks they face from coastal erosion. The Council was amongst the first local authorities to develop an Integrated Coastal Zone Management (ICZM) Plan in 2000, and in 2003 and 2005 developed and adopted ‘rollback’ policies for caravan parks, agricultural buildings and residential properties whereby landowners can relocate their properties away from the eroding coast. These rollback policies were refined and strengthened through the development of the East Riding Local Plan in 2016, which also designated a Coastal Change Management Area (CCMA) for the East Riding. The adoption of a CCMA as part of the Local Plan allows the Council to regulate land use within the coastal zone, avoiding inappropriate developments. A Coastal Change Supplementary Planning Document is now in development in order to further refine the Council’s approach to rollback and development in the CCMA.
3.2. The above adaptation measures have been designed to avoid inappropriate development in areas at risk from coastal change. What is more difficult is to support communities already at risk from coastal change to adapt.
3.3. A national attempt to trial adaptation approaches in these communities was made in 2009 through Defra’s Coastal Change Pathfinder programme. Through this programme East Riding of Yorkshire Council was awarded £1.2m to trial innovative approaches to adaptation. Rather than providing compensation for loss, the East Riding Coastal Change Pathfinder (ERCCP) enabled vulnerable coastal communities to adapt to the impacts of coastal change either by relocating to safe accommodation inland or adapting their properties as appropriate. Through the ERCCP the Council engaged with over 150 residents, businesses and community groups at risk from coastal change, provided financial support to 43 of households to help them relocate away from risk, and demolished 51 properties which were at imminent or high risk from coastal erosion.
3.4. While Defra has undertaken several reviews of the outcomes of the Coastal Change Pathfinder programme, these have not resulted in the development of a national coastal change policy. In the absence of a national policy, the Council has developed a number of local approaches to managing the impacts of coastal change in the East Riding, based on the results of our comprehensive coastal monitoring programme. This has included the continued dissemination of the remaining ERCCP funds through the East Riding Coastal Change Fund (ERCCF), and the adoption of a consistent approach to defining properties at ‘imminent risk’ from coastal erosion. These local approaches will be enshrined into Council policy through the development of an ‘East Riding Coastal Change Management Framework’, to ensure consistency going forward.
3.5. While these approaches have proved successful in helping residents to adapt to coastal change, the support we are able to provide is limited to the cost of property demolition (averaging around £12,500 per property) and a small amount of assistance related to relocation costs. Our continued delivery of these approaches is dependent on funding being available to do so. With no national funding available for adaptation measures (see Question 5 below) there is no guarantee that the Council will be able to continue offering this assistance to residents.
3.6. We would also welcome confirmation from Government that the approaches taken by the Council are appropriate through the adaption of a national coastal change policy. This will reassure local authorities that their efforts are being recognised and will ensure that residents at risk from coastal erosion in all parts of the country have access to the same information, the same adaptation options and the same level of assistance.
4.1. There is currently no national application or approvals process for coastal erosion and flooding adaptation measures as they are delivered locally, based on the priorities and resource commitments of individual local authorities (delivering adaptation is not a statutory duty).
4.2. East Riding of Yorkshire Council’s management of coastal change risk is based upon a significant amount of officer time and resource, plus a limited amount of remaining ERCCP revenue which is ring-fenced and allocated in full. The maintenance of the adaptive approach advocated by Defra currently requires significant and continuous financial support from East Riding of Yorkshire Council and works are carried out at risk. Whilst East Riding of Yorkshire Council has made a commitment to support residents whose property at risk, including those to the south of Withernsea, it has been necessary to explore external sources of funding, including EU funding streams (e.g. European Regional Development Fund) due to the lack of suitable funding options within our own Government. This demonstrates that the Government does not currently have a joined up resource to deliver adaptive measures for dealing with the ongoing issues related to climate-driven coastal change.
4.3. Whilst the Council is committed to maintaining a level of in-kind resource where possible, the revenue currently available for coastal change management will be insufficient to meet the costs associated with the demolition of all 24 properties estimated to be at risk by 2025 (and, therefore, to meet the additional social costs associated with relocating residents away from risk).
4.4. Furthermore, there are currently no dedicated national funding streams which are accessible for adaptation measures. For example, the Flood Defence Grant in Aid (FDGiA) partnership funding model does not currently allow Risk Management Authorities to submit funding bids for adaptation work, including property demolition, relocation and rollback.
4.5. The Environment Agency-administered Coastal Erosion Assistance Grant offers £6,000 per property demolition undertaken in response to coastal erosion risk, up to a maximum of £60,000 per year. This funding, however, is only available on a retrospective and competitive basis, and falls well short of meeting the true cost of demolition as identified during the ERCCP. It also cannot meet the social costs associated with relocation as funded through the ERCCF, and which was found to ease the pressure of relocation by enabling residents to relocate before properties became subject to emergency demolition notices.
4.6. Whilst recently extended to include coastal flooding and erosion risk management, the Coastal Communities Fund (CCF) has a focus on job creation and regeneration, precluding applications for adaptation projects.
4.7. As stated in response to Question 2 above, the Council calls on Defra and central government to create a national coastal change policy with a dedicated and ongoing funding stream to support adaptation as an alternative to engineered defences.
5.1. The Council recognises that it will never be possible to fund all coastal defence projects which the EA and local authorities would wish to fund, and that there are areas where it is not economically, socially or environmentally sustainable to defend.
5.2. We are however, of the opinion that the current criteria for determining which projects receive FDGiA funding are too narrow, with a considerable value put on the number of residential properties protected and the amount of habitat created, at the expense of other tangible benefits. It is critical that the wider benefits of coastal erosion defence (and adaptation) schemes are taken into account within the Funding Calculator.
5.3. It is also important that funders acknowledge that some coastal erosion defence schemes may not be able to create large numbers of new jobs in communities at risk from coastal erosion, but may be able to protect the local economy by decelerating, delaying or avoiding altogether the negative impacts of coastal change. It should be recognised that the protection of the existing local economy is often as valuable as the creation of new jobs.
6.1. While there is a push from national Government for local authorities to deliver adaptation schemes, there has been no practical guidance as to when or how this should be delivered. There has also been little practical support to enable local authorities to deliver adaptation, beyond the Coastal Change Pathfinder programme, which ended in 2012. Furthermore, the feeling still appears widespread that adaptation is a secondary option to constructing a coastal defence.
6.2. As there is no statutory duty to deliver coastal defences or adaptation, it is ultimately the decision of individual local authorities to decide the process, criteria and timescales for determining when to support or withdraw from coastal adaptation measures, and what these measures may look like. This decision can be influenced by a number of factors including local priorities, the scale of the issue in a particular area and the availability of a reliable funding stream.
6.3. It is inevitable however that adaptation measures will be focused in areas with a ‘No Active Intervention’ or ‘Managed Realignment’ policy within the local Shoreline Management Plan (i.e. where coastal erosion is resulting in the loss of land). East Riding of Yorkshire Council has made great efforts to dispel the view that ‘No Active Intervention’ means that communities are being abandoned. Explaining to vulnerable communities why it is not sustainable to provide coastal defences, and what adaptation measures are available, can play a large part in countering this view. By engaging widely with residents and businesses at risk in the short-, medium- and long-term, they can start to plan how they are going to adapt to coastal erosion proactively. This is especially important as adaptation measures such as rollback often take several years to come to fruition.
6.4. East Riding of Yorkshire Council is committed to the continued delivery of adaptation measures in communities at risk from coastal erosion, however this is dependent on funding being available to deliver these measures. Without the creation of an ongoing, dedicated funding stream for coastal adaptation, there is no guarantee that the Council will be able to offer the support which has been provided to communities through the ERCCP / ERCCF in future.
7.1. It is critical that the EA’s upcoming 50-year strategy and the Government’s flood and coastal erosion strategy recognise coastal erosion as an important and discrete issue that requires different management techniques and approaches to flooding.
7.2. Within coastal change management itself it is important that the documents reflect the increased threat posed by climate change, resulting in both increased erosion rates in unprotected areas and increased maintenance costs in protected frontages.
7.3. While we recognise and support the need to continue investing in effective flood and coastal erosion risk management measures where appropriate, it is vital that the construction of defences is not seen as the default option, and that adaptation approaches are recognised on the same footing as mitigation. Projects such as the ERCCP and ERCCF have demonstrated the value of adaptation, however these schemes can only continue to be delivered if ongoing dedicated adaptation funding is made available.
8.1. That Defra and central government create a national coastal change policy to ensure consistency of approach across different local authorities.
8.2. That a dedicated and ongoing funding stream is established to support adaptation measures as an equal alternative to engineered defences.
30 April 2019