The Wildlife Trusts                            FRE0061

Written evidence submitted by The Wildlife Trusts

EAC to examine flood resilience as homes and businesses recover from more flooding misery in recent weeks

Inquiry launch: Flood resilience in England

The Wildlife Trusts are a federated movement of 46 charities, supported by a central charity, the Royal Society of Wildlife Trusts. Together we have more than 900,000 members, 35,000 volunteers and 3,000 staff across the UK. We share a vision of nature in recovery, with abundant, diverse wildlife and natural processes creating wilder landscapes where people and nature thrive.

The increasing intensity and frequency of extreme weather events, such as flooding, are among the most visible consequences of climate change. The recent flooding across the UK highlights this issue, and we are pleased that the Environmental Audit Committee will be investigating flood resilience in this inquiry. Nature can play a crucial role in improving the resilience of homes and businesses.

The Wildlife Trusts are a member of Wildlife and Countryside Link and supported the written evidence submitted by Link on behalf of its members. We are in addition providing supplementary evidence to the Committee given our specific experience in the fields of Natural Flood Management and wider flood resilience. Wildlife Trusts across the country are actively involved in delivering natural flood management schemes, and in undertaking conservation land management which delivers flood risk reduction alongside other benefits.

In addition, we engage with the Environment Agency, Lead Local Flood Authorities and other Risk management Authorities in plan development and project delivery, and are members of several Regional Flood and Coastal Communities, often as EA-appointed independent members for conservation. The following evidence is provided based on our experience in these various roles.  

Executive Summary

At The Wildlife Trusts, we believe building resilience to flooding requires a shift from reliance on traditional defences to a more holistic approach that works with nature. The challenges posed by flood risks demand innovative, sustainable solutions that protect people and businesses while restoring our natural landscapes.

We champion Natural Flood Management (NFM) techniques that slow water flow through catchments, reducing flood risks downstream. These methods include creating wetlands and ponds, restoring floodplains, enhancing soil health, planting trees, and constructing natural features like leaky dams. By working with natural processes, we can reduce the need for costly and environmentally damaging infrastructure.

Traditional defences like flood walls can play an important role, but they are not enough on their own. We see opportunities to complement these measures with nature-based solutions, particularly in rural areas where land can be used to hold and store water safely. We support policies like the Environmental Land Management (ELM) Scheme, which can empower farmers and land managers to adopt flood-resilient practices.

Through these combined efforts, we aim to create landscapes that are better equipped to manage water, protect communities, and enhance biodiversity. By working with nature, we can achieve a more resilient and sustainable future for people, businesses and wildlife alike.

Strengthening flood resilience 

1. To what extent are current flood resilience assets and interventions fit-for-purpose and what are the strengths and weaknesses?

• Are there alternative approaches from across the UK and elsewhere which could help inform improvements and innovation?

Flood risk reduction actions employed to date have been successful at reducing flood risk to large numbers of properties; over 314,000 homes were ‘better protected’ under the prior six-year Flood and Coastal Erosion Risk Management (FCERM) programme (2015 – 2020) and the current six-year FCERM programme (2021 – 2027) originally aimed to reduce flood and erosion risk to 336,000 properties, using a record capital budget of £5.2bn (later boosted to £5.6bn) to protect homes as well as other (non-residential) properties including businesses, shops, schools, hospitals, transport links and utility sites.

This broader focus is reflective of a move towards creating greater resilience to flooding, alongside managing flood risk - for example, through the welcome recognition that the impacts of flooding upon society and the economy occur through a wider range of mechanisms than solely the flooding of houses; such as by preventing access to healthcare and by making rescue from or recovery after flooding significantly more complex.

It will be increasingly important to deliver an integrated portfolio of projects that deliver a combination of flood resilience and flood risk reduction, given the broad acknowledgement that ‘We cannot expect to build our way out of future climate risks with infinitely high walls and barriers’[1].

Indeed, it is clear that it is becoming increasingly infeasible to deliver against society’s expectations for flood defences. The National Audit Office highlighted in its November 2023 report[2] that the Environment Agency had reduced its forecast of how many properties can be better protected by 2027 to 200,000, a reduction of 40%. This figure was expected to be confirmed as a revised programme target in summer 2024, when the General Election was called; resultantly it has still not been formally published as a revised target, but in any case, is regarded to be a realistic if not potentially optimistic projection of what can be delivered, meaning a reduction in protection to over 136,000 properties compared to original targets. At the same time the number of properties predicted to be at flood risk has increased (due largely to improved understanding, rather than to changes in actual flood risk) - an updated National Flood Risk Assessment (NaFRA2)[3] published in December 2024 places the total number of properties at flood risk at 6.3 million, increasing to 8 million, or 1 in 4 properties, by mid-century.

This increased (understanding of) risk, combined with reduced delivery of flood risk reduction, alongside Government concerns about the affordability of the flood programme as noted in the Autumn 2024 Budget[4], highlights the vulnerabilities of our current approaches, which are overly reliant upon capital schemes to reduce flood risk.

• The current flood programme has faced significantly increased costs due to externalities, including the impacts of Brexit, Covid19 and geopolitical instabilities upon the supply chain – labour costs and skills shortages have increased, and the cost of construction materials has ballooned.
• EA have faced recruitment struggles, perhaps related to the perception that - in particular in their other major role as environmental regulators - they are (intentionally) underfunded and hamstrung.
• Risk Management Authorities, tasked with delivering more than half of the projects and 49% of the original 336,000 ‘properties protected’ target, face the same pressures as the Environment Agency. In addition, Local Authorities – responsible for the majority of RMA-led schemes – are struggling to prioritise FCERM spend when faced with other unmanageable budgetary pressures, particularly for adult social care.

All of this points to the need for a more holistic approach to flood risk reduction and flood resilience, employing a wider range of actions in addition to building and maintaining (largely traditional) flood defences. As highlighted by the NAO in their report, this includes “avoiding inappropriate development in flood plains; using nature-based solutions to control the flow of flood water; better preparing and responding to incidents; and making properties and infrastructure more resilient to future flooding”. To this list we would add ‘considering the management of water at a catchment scale’, looking at the role of natural habitats as well as currently-drained farmland in better managing both flood and drought risk. The forthcoming Land Use Framework (LUF) could usefully identify areas of a catchment that should be utilised for water management, delivering flood / drought protection and mitigation, potentially alongside other land uses, and should facilitate delivery via the establishment of a mechanism that links Environmental Land Management scheme payments to LUF outcomes.

In the Netherlands, strategic Land Use Change has been employed to successfully manage flood risk, delivering floodplain restoration to resolve flooding and restore nature at scale.

• In a series of programmes, most recently “Room for Rivers”, waterways have been restructured so that floodplains are once again able to play their natural role in flood protection. At Millingerwaard in the Gelderse Poort, clay mining provided the financial input to create new channels through mineral excavation, displacing agriculture from flood-prone areas and creating flood storage capacity alongside rewilded areas of riparian forest, marshes, herb-rich grasslands, lakes and river dune. Diverse habitats support a variety of wildlife, in particular mammals including beaver and otter, and vast bird populations - creating the setting for an extraordinary economic uplift to the area through nature-based tourism.
• Kempen~Broek is a large complex of natural habitats restored from agriculture, where wetlands have been recreated to store water in times of flood and release water to agriculture in times of drought. Their creation was made possible with Government funding; state acquisition of farms in the surrounding area enabled voluntary land exchanges, relocating farming away from former wetland areas, and allowing habitat restoration in the floodplain. Often agricultural soil was stripped and relocated, enhancing the new farmland and facilitating habitat restoration at the donor sites. Managed as nature reserves, the former farms attract an abundance and diversity of species, supporting nature tourism alongside delivering drought and flood risk reduction.

These international examples of delivery at scale demonstrate that even in highly-populated, built-up and heavily farmed areas, Land Use Change can be effectively employed to deliver flood risk reduction to towns and cities at the same time as securing more resilient agriculture and widespread nature recovery, at an affordable cost. It is also worth noting that these approaches were community-driven; after devastating floods in the winters of 1993 and 1995, local pressure for a new approach to flood prevention was the driving force that led to the establishment of the policy goals of the Room for Rivers programme.

2. How appropriate is the current balance between 'green' nature-based solutions and 'grey' hard infrastructure resilience assets, and what adjustments, if any, are needed to improve it?

• 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

Natural flood management remains an under-rated and under-funded part of the toolbox of solutions to rising flood risk, and this needs to change urgently to best protect people and infrastructure from future flooding alongside enhancing biodiversity.

The latest third UK Climate Change Risk Assessment (CCRA3) flood risk projections (Sayers et al 2021) found that flood risk will increase in all future scenarios with climate change even with very high levels of adaptation; with a projected doubling of the number of people at significant risk (currently around 1.9 million) by 2050 in a baseline scenario[5]. This was echoed in the recent Environment Agency National Flood Risk Assessment (NaFRA2) which showed that more properties are now at risk than previously estimated, particularly from surface water flooding, with again around a doubling of risk by 2050[6].  CCRA3 also demonstrated that rising risk will be mitigated the most in an ‘enhanced adaptation scenario’ where all possible measures to reduce risk are used together, including high levels of natural flood management. It modelled NFM effectiveness of up to 8% reductions in peak flows for run-off management features and 5% reductions for temporary storage features (Sayers et al. appendix D). Reductions and delays in peak flows do not stop flooding entirely, but delays to flood peaks from natural flood management are becoming well researched[7] and can reduce overall damages and buy households valuable extra time to prepare and move valuables out of harm’s way.

Evidence for the net economic benefits of natural flood management options has been lacking, but for the past year The Wildlife Trusts have been working with a major insurer and the consultancy Stantec to estimate the costs and benefits of existing Wildlife Trust NFM sites. This report will be published in February 2025, but initial results show benefit: cost ratios across the sites of around 4:1 over a ten-year time period, rising to 10:1 over 30 years. These very clear net benefits occur when the full benefits of the NFM schemes are taken into account including benefits for health and wellbeing, and biodiversity.

In England, public funding for NFM is limited to the Environment Agency, which is currently investing £25 million in development projects. This investment, whilst welcome, is tiny – just 2.5% of the total flood and coastal erosion risk management budget (capital and resource), which has been sitting at over £1 billion per year since 2020[8]. Despite the limited funding, there are hundreds of active NFM projects across the country. The Wildlife Trusts are a major deliverer of NFM; in 2023/24 we spent around £3.6 million on NFM projects, and have over 150 active projects across the UK with another 45 potential projects at ‘investment readiness’ stage. Our experience is that there is plenty of scope and available sites for natural flood management, and expertise to deliver it; the greater barrier to implementation is available funding.

This in part is related to the difficulty of quantifying with certainty the level of flood risk reduction that a NFM project will deliver, particularly whether it may move an at-risk property between risk bands, as well as the issue that NFM schemes, often being smaller-scale than many built defences, will not individually secure a significant change in flood risk, so (unless delivering multiple interventions as part of a single bid), can mean that it is more difficult to demonstrate that NFM proposals meet traditional funding criteria. This rigidity, although improved by recent changes to funding models, needs to be further tackled in order to unlock the ‘mainstreaming’ of nature-based approaches, which even if not delivered at scale have the ability to deliver multiple benefits alongside flood risk reduction, and in particular foster a feeling of agency amongst the local communities involved in delivering them, which is valuable for mental resilience in communities facing the constant threat of flooding.

Some work has been carried out to quantify the multiple benefits for climate, biodiversity and people from natural flood management, particularly related to beavers (which The Wildlife Trusts support strongly as part of Natural Flood Management). The Wildlife Trusts’ latest science and evidence review, Wild Science, uses the River Otter beaver trial in Devon as an example of our scientific impact over the past five years[9]. This family of wild beavers in Devon, supported by Devon Wildlife Trust, have created a series of dams that showed quantifiable reductions in peak flows. During storms, on average, peak flows were 30% lower leaving the site than entering. The lag time between peak flow entering the site and peak flow leaving the site was on average one hour, also creating a peak flow delay further downstream. The beaver ponds also store around 1 million litres of water at any one time. Alongside the study of changes in water flows, beaver activity also led to increases in fish biomass in some sections of the river, benefits for amphibians, waterfowl and water voles, and extensions to scrub and wetland habitats. Wild-living beaver populations are now known in Devon, Kent, Somerset, Wiltshire, Cornwall and Herefordshire, as well as in Scotland, but despite this, no new wild releases have yet been licensed in England. The evidence generated and shared to date is also informing the preparation of a number of applications for licences to release beavers into the wild at suitable locations across the length and breadth of England. In the meantime, Wildlife Trusts are managing enclosed beaver habitats in Cornwall, Cheshire, Cumbria, Derbyshire, Dorset, Essex, London, Nottinghamshire and Surrey. All of these sites are subject to ongoing monitoring and research.

Monitoring at other beaver sites throughout the UK is also demonstrating the role of beaver-created wetlands in reducing flood risk, including at Plymouth[10], Essex[11] and elsewhere[12].

3. What changes to the planning system and building regulations are needed to ensure that buildings and infrastructure are resilient to flooding in the short, medium, and long-term?

• What long-term land use strategies and approaches to flooding should the government consider, especially for communities that cannot be protected from flooding or inundation? 

The National Flood and Coastal Erosion Risk Management Strategy for England, published by the Environment Agency, sets out the importance of ensuring all new development is resistant to flooding and coastal change.

The first opportunity to secure this is when granting or refusing planning permission. With the number of properties in the floodplain predicted to almost double over the next 50 years, it is critical that Local Planning Authorities heed Environment Agency advice on flood risk during decision making.  In the 8 years from 2016/17 to 2023/24, 534 planning applications were granted against Environment Agency flood risk advice. These were across 39 different development categories including major schemes for infrastructure, heavy industry, light industry, retail, caravan, educational and mixed use, as well as 43 major and 288 non-major residential schemes. In total there were 341 developments approved against EA flood advice which included residential units, totalling 2,649 residential properties. Whilst these figures are not large, they are significant - particularly to the owners of these new homes who may well sadly experience flooding in the future – and it is worth noting that, rather than being overly cautious, these recommendations were based on flood risk understanding which is now out of date, meaning that the true tally of properties built despite being at flood risk will be somewhat higher than these figure suggest.

Next, where development is approved, ensuring that it manages flood risk (to itself, and to other sites) via Sustainable Drainage Systems (SuDS), must be the next port of call. Current planning policy requires that SuDS are included in all new major developments (developments over 10 homes), and all developments in flood risk areas, unless there is clear evidence that this would be inappropriate. However, the lack of statutory design standards, along with the lack of capacity to challenge either poor quality proposals or assertions that SuDS are inappropriate, leads to a lack of (particularly high quality) sustainable drainage schemes being implemented.

Government should urgently act to implement Schedule 3 of the Flood and Water Management Act 2010, in line with the key recommendation of a recent Government review into the topic.[13] The review found that Schedule 3 would provide an effective framework for the approval and adoption of drainage systems, an approving body, and national standards on the design, construction, operation, and maintenance of SuDS.

This would serve to significantly improve the quality and use of SuDS, enhancing both flood risk reduction and flood resilience. Further policy on residual points should then be set out in the National Planning Policy Framework, such as around the consideration of SuDS in development where their use is not mandatory, their use to enable development to reduce (rather than just ‘not increase’) flood risk, and their use to deliver multiple benefits such as enhancing biodiversity. SuDS standards should consider aspects such as a use hierarchy prioritising ‘green’ or ‘soft’ SuDS over hard-engineered options like geo-cellular storage systems, and the use of SuDS features in water re-use, to reduce water resources shortfalls.

Changes to further mandate the use of rainwater harvesting would also be beneficial, for example by considering rainwater harvesting in developing the statutory National Standards for sustainable drainage systems, and in any review of Building Regulations. The increased use of rainwater harvesting would deliver against multiple Government objectives including flood risk reduction, water quality improvements via reduced urban runoff and sewer spills, water resource security via a reduction in consumer demand for public water supply, and carbon goals due to the reduced requirement for the chemical- and energy-intensive treatment and pumping of water supplies to homes and businesses.

Monitoring flood resilience  

4. To what extent are current metrics for monitoring the effectiveness of flood resilience fit for purpose, and what improvements could make them more effective?

Despite valuable research through the NERC-funded NFM programme, which undertook work to quantify the suitability and effectiveness of different NFM measures for a range of scenarios[14], metrics for natural flood management remain poorly established. As part of an ongoing research project on natural flood management led by The Wildlife Trusts and a major insurer, business sector representatives identified the lack of standard and consistent metrics for measuring NFM as a major investment barrier. The biggest barriers to NFM adoption identified were the lack of consolidated monitoring and evaluation, difficulty in demonstrating clear monetisable outputs, and limited understanding of NFM among stakeholders. There is no standardised guidance available to Wildlife Trusts or other bodies implementing NFM to tell us what to measure, and how. Even within the small number of sites studied across different Wildlife Trusts in this study, different and inconsistent monitoring and surveying approaches were being used meaning that it was not possible to generate consistent and complete datasets across all sites.

• Do current metrics capture the range and effectiveness of privately-owned flood resilience assets, and if not, how can this be improved?

The Catchment-Based Approach Natural Flood Management Hub provides a site for mapping NFM projects and their multiple benefits, used as a repository of the locations of and information about NFM interventions. Its purpose is to ensure that local stakeholders are aware of NFM and other natural assets, including where they are, what benefits (ecosystem services) they are delivering, and how they are being managed. It is also increasingly being used to log the market and non-market benefits of NFM interventions, helping to form an evidence base for private sector investment. Whilst a useful asset, the Hub would benefit from continued Government support to ensure that it continues to function as both an asset management system (including via the ongoing addition to the database and mapping portal of further NFM assets) and as an evidence repository to support the case for the wider use of nature-based assets.  

• Do we have appropriate metrics and mechanisms to measure the cost effectiveness of flooding assets and interventions in terms of investment versus long-term savings and, if not, what should they look like? 

The above-mentioned NERC research went some way towards establishing a means of measuring the cost effectiveness of NFM measures. The researchers quantified the impacts of a range of interventions like peat restoration and tree planting, finding that the flood reduction value of NFM in catchments of 10-50 km2 was £5-10 million over 50 years. When other benefits like carbon storage and habitat enhancement were factored in, it increased this amount ten times, to between £2,630 and £6,390 a hectare a year.

All the measurement techniques and metrics that we need to demonstrate cost-effectiveness of NFM exist; as described above, we are just completing research on this basis and the metrics used include number of properties better protected, reduction in peak flow (for a given return period event), habitat quality and species abundance and diversity. What is lacking is a single set of standardised guidelines telling NFM managers what to measure and how, so that consistent datasets can be created.

Coordination of flood resilience 

5. How effectively and how frequently do flood risk management authorities work together to tackle flooding issues and do they have sufficient resources and skills available to carry out their work?

• For instance, how can the government ensure that areas prone to flooding near the mouth of a river, are not negatively impacted by increased pressure on the river, or by flood-mitigation measures taken upstream?
• Where is the interface between the responsibilities for river and surface water flooding, and how could monitoring and coordination be improved to enhance effectiveness and early warning of flooding?

The Flood and Water Management Act 2010 requires Risk Management Authorities to co-operate with each other, acting in a manner that is consistent with the National Flood and Coastal Erosion Risk Management Strategy for England and the local flood risk management strategies developed by Lead Local Flood Authorities. Similarly there is an expectation[15] that Water Industry Drainage and Wastewater Management Plans will be collaboratively developed and delivered. However requirements and expectations can be difficult to adhere to in the face of resource constraints, both budgetary and capacity-related. This is particular observed to be the case for Local Authorities, meaning that consultation over plan development can be challenging for all partners involved, and the capacity for Local Planning Authorities to assess and consent to the work set out in flood- and drainage-related schemes in a timely manner is a concern for other RMAs.

The development of catchment-scale strategies and approaches, informed by a Land Use Framework, would facilitate better joint working by all parties involved, as the establishment of overarching principles via a LUF could remove conflicts or trade-offs from the outset and make it clearer where the opportunities for joint delivery can best be focussed. In particular, catchment-scale strategies informed by LUF principles could identify areas of the catchment most important for flood storage and other nature-based interventions, giving confidence that downstream sites will be protected by upstream measures, (rather than potentially negatively impacted by uncoordinated deployment of flood mitigation measures).

6. What should the key priorities be for the Flood Resilience Taskforce, and how can it enhance coordination and improve flood resilience?

• Is there a role for community-based flood response teams, and who is responsible for building that resource?

Government has stated that the role of the Flood Resilience Taskforce will include championing NFM delivery. This is welcome given the valuable role that we know NFM can play in flood defence and flood resilience. As eNGOs are a major deliverer of these nature-based solutions, and as many eNGOs are landowners or managers working alongside farmers and rural communities to deliver both drought and flood resilience, the absence of any eNGO members on the taskforce is a missed opportunity and should be rectified.

7. Is there a backlog in maintenance of existing flooding adaptation/resilience assets and in identifying where new ones could be introduced?

• Is there clarity about whose responsibilities these are, and how could this be improved?
• How strong is the knowledge base on both the condition of existing assets and where new ones might be needed and what steps could strengthen it? 

Maintenance of existing flood assets is a vitally important part of flood management and one which has historically been neglected compared to the focus on building new defences. Targets for asset condition help to ensure a focus on this but both EA and RMA assets are currently not attaining target levels for condition, with both citing budget shortfalls as a factor in this. Government could explore using capital budget underspend to maintain both EA and RMA assets.

The role of nature-based solutions is also important here. There is a growing body of evidence that demonstrates the value of natural solutions or analogues in supporting the health of built assets - for example, the role of saltmarshes and mudflats in reducing the impact of wave action upon sea walls. With climate-driven asset damage only liable to increase with more intense storm surges and floods, natural assets that provide resilience to built structures will become increasingly important. The role of artificial features that mimic natural structures or processes will also play a key role; for example the value of artificial reefs in tempering wave action, which is benefitting from research across the EU[16] and US, and the role of ‘ecoformliners’[17] developed and installed as part of coastal defence works on Portsea Island. The formliner is a textured sea wall where the rough contours encourage colonisation by seaweed and other vegetation, stopping the wall from drying out and absorbing wave energy. This both enhances the longevity of the structure and creates habitat for marine wildlife, helping to mitigate for habitat loss due to construction of the defences.  

Resources, funding and support for flood resilience

8. What level of flood resilience is required to address the flood risks identified in the Climate Change Risk Assessment and is current funding adequate to meet these risks effectively?

• Is there sufficient government support and funding for the maintenance of privately-owned flood defence and resilience assets?
• 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?
• How well does the National Adaptation Plan address the need for flooding adaptation measures, and what additional steps should be taken to ensure effective long-term flood resilience in high-risk areas?

As the use of NFM in flood defence and resilience increases, the need to ensure that NFM assets are maintained will also increase. Many will be on private land rather than in the public realm, meaning that support to landowners to maintain or periodically renew such assets will be required. Environmental Land Management funding offers the opportunity to provide such support to farmers and land managers and evolution of the funding offer must ensure that maintenance of NFM assets such as leaky dams is catered for. The current SFI offer contains multiple actions that have some link to flood risk[18], but none specifically cater for NFM features, meaning that access to relevant payments is restricted to those farmers in or entering Countryside Stewardship or Landscape Recovery agreements. The Countryside Stewardship programme offers funding[19] for large and small leaky woody dams, swales, sediment ponds and other features, some of which are new additions to the programme and this is a positive change, but capacity to process applications and sufficient budget to bankroll the schemes remain a challenge for Government.

January 2025