Written evidence submitted by Coastal Partners, Standing Conference for Problems Affecting the Coastline and Southern Coastal Group
 

Soon to be published SCOPAC 2025 Study:  Coastal Heritage within Local Authority Flood and Coastal Erosion Risk Management (FCERM) - the Challenge of Conflicting Priorities

Introduction

Whilst this paper focuses on the implications of heritage assets on the coast in relation to Flood and Coastal Erosion Risk Management (FCERM) schemes and local authority over-stretched maintenance budgets, we fully support the conservation of these assets into the future.  We hope by highlighting the scale of the challenge, a more sustainable solution can be found to preserve these valuable assets for future generations to enjoy.

Background

The coastal zone contains a legacy of heritage assets, including historic buildings, quay walls and landscapes (both terrestrial and submerged) as well as fragile and irreplaceable archaeological remains and shipwrecks. These play an important role in society, contributing heavily to social, economic, and environmental characteristics of place. It is therefore generally considered vital that the profile of heritage is incorporated into Local Authority decision making and resource allocation. A significant number of these assets have historically benefited from Flood and Coastal Erosion Risk Management Grant in Aid (FCERM GiA) funding. However, defending these assets, can divert limited FCERM GiA away from protecting people and property from flooding and erosion.  Lack of suitable funding streams, combined with uncertainties surrounding accountability and understanding of responsibility for heritage assets, puts significant pressure on the effective delivery of FCERM, risking both their permanent irretrievable loss or damage and putting communities at increased risk.

Where a historic site sits within a wider FCERM funded scheme, protecting homes and businesses, it is frequently required that heritage conservations and advisories are employed to align with certain licence or planning requirements, in many cases adding considerable extra cost. However, the benefit and value of doing so is not recognised in the economic case, frequently resulting in a significant funding shortfall. Whilst it is possible to account for some of these costs with adequate risk factored in, this will essentially increase the overall cost of the scheme, lowering the partnership funding score and in some cases, making the scheme unaffordable. A further question remains over those heritage assets that do not sit within a qualifying FCERM GiA scheme regarding who pays for protection or relocation.

Even if all the correct processes, investigations and mitigations have been carried out, it is still commonplace for previously undocumented assets to become exposed during the construction phase of an approved scheme. Should this occur, significant additional costs may be added to the overall project costs through requirement for further archaeological mitigation and in some cases, design amendments to preserve the asset as considered appropriate. 

A significant challenge is presented where heritage assets directly perform a coastal defence function. Many of these are now reaching the end of their lives and are becoming increasingly vulnerable due to pressures associated with climate change. However, the cost of their maintenance is significantly increased by statutory mitigations exerted by their heritage status, a problem which is often further compounded by other complications relating to their general aging nature, lack of appropriate record keeping and conflicting interests between stakeholders. This results in limited Local Authority revenue budgets becoming significantly stretched, reducing affordability, and therefore increasing risk to the communities these assets protect.

To detail and evidence, the above issues along the South Coast of England (but with implications nationally), a report was commissioned by the Standing Conference for Problems Affecting the Coastline and Southern Coastal Group (SCOPAC and SCG) and the Southern and Wessex RFCC’s and is currently being undertaken by Coastal Partners. This document is unpublished at the time of writing but is expected to be disseminated in spring 2025. The following outlines some of the key findings of this report to provide evidence to this enquiry.

1. Local Authority Funding Challenges Associated with Defending Heritage Assets at Coastal Risk.

The UK coastline supports a large number of designated heritage assets which are either currently or imminently at direct risk of loss or damage through flooding or erosion. The present-day construction costs of defending these assets on the south coast alone (Worthing to Lyme Regis) has been estimated to be approximately 1.4 billion (SCOPAC,2025 unpublished). Local Authorities overwhelmingly act as a primary landowner for the majority of coastal heritage sites or hold maintainer responsibilities; as such considerable public investment is required to ensure their future management is viable.  The unpublished SCOPAC (2025) report reveals that 70% of historical assets at risk from coastal erosion and/or flooding along the south coast between Worthing and Lyme Regis are maintained by publicly funded bodies. However, a review of funding streams has revealed that at present no funding streams exist to specifically support the costs associated with heritage assets at coastal risk (SCOPAC,2025 unpublished). Sufficient funding must therefore be drawn down either through traditional FCERM funding pathways or acquired through other streams geared up for other (non-FCERM focussed) aspects of heritage conservation, wider regeneration, or other community funding.

However,

• Heritage assets do not qualify for allocation of Flood and Coastal Erosion Risk Management Grant in Aid (FCERM GiA) (the main source of central government funding for coastal flood protection works) in current economic assessments.
• Alternative funding streams are either directly unsuitable, yield insufficient sums or hold considerable uncertainty in their eligibility to contribute to heritage related coastal risk management issues.

Due to this funding gap, defending coastline on the basis of the presence of Heritage significance alone is at present aspirational but practically unachievable for most sites within the current funding landscape. With increasing climate pressure, a number of historical assets will become more vulnerable, and it is likely that cost pressures will increase, and the funding deficit be exacerbated.

2. Impacts of the Statutory Consenting Process on FCERM Schemes.

National and local planning policy, plus legislation, set requirements for heritage impacts and mitigation regardless of funding available to a scheme. Findings from the soon to be published SCOPAC (2025) report, identify that 58% of FCERM schemes planned to occur over the next 10 years assets between Worthing and Lyme Regis contain designated coastal heritage within their boundaries, highlighting the scale of impact this will exert in one UK region alone.  The primary vehicle to ensure schemes comply with legislation and priorities pertaining to management of the historic environment is through a statutory consenting process administrated by Historic England (HE). Engagement with this consenting process results in significant and statutory increases to costs which tend to be challenging to price upfront, resulting in flood defence money (acquired specifically and only for FCERM costs) being spent on heritage, rather than protecting people and property. Key causes of these increased costs are listed as follows;

• The results of the consenting process are statutory advisories and mitigations which schemes must adhere to including the use of sympathetic construction materials or techniques, input from specialist consultants and changes to the design which can significantly increase the cost and has been known to exceed 20% of the original forecast (SCOPAC, 2025 unpublished) and could be more for certain schemes. Statutory mitigations have no standardisation and are rather based on the opinions of a single officer (therefore two different advisors may offer different mitigations therefore cost impacts for the same site and situation) with no procedure for appeal or second opinion.

• Timescales associated with the consenting process can be lengthy and result in large delays to works holding considerable financial risk for projects. This is a particular issue where circumstances result in their extension, such as where advisories which arise from the statutory consenting process conflict with other statutory priorities from governmental bodies other than the Department of Culture Media and Sport (DCMS) bodies such as Department for Environment Food and Agriculture (DEFRA) biodiversity targets. The consenting process is also slow to react when should archaeology be found in a scheme location which can extend timescales considerably.
• There is currently limited enforcement on maintenance of designated assets. Where FCERM schemes are required to remove and reinstall assets to facilitate wider works (such as lamp columns, beach shelters, or memorials) they are obligated to foot the cost of refurbishment regardless of the state of disrepair the assets were allowed to fall into in before the works took place.

Without either adequate funding streams to support statutory costs associated with the consenting process or reform to the approach of the consenting process with respect to FCERM, many FCERM schemes will be rendered unaffordable putting homes and properties at risk, or where possible will be forced to reduce cost impacts by designing protection to exclude heritage structures in order to deliver within their funding allocation, increasing the risk of future heritage loss.

3. Maintenance Pressures on Heritage Structures which Form a Sea Defence

Significant financial pressure is placed on local authorities by stretches of coastline which are defended by designated heritage structures. Maintenance costs are increased by;

• Statutory requirements to employ heritage sympathetic construction techniques which can be more expensive and increase site time.

• Mandated heritage sympathetic construction materials required frequently carry increased cost and are less robust than their industry counterparts which increase the frequency of required maintenance.
• Where these historic sections of coastline fail (for example due to storm impacts) eliciting the need for quick response emergency works, there is currently no formal provision to expediate the aforementioned consenting process. Therefore, where large scale failures occur, it is a legal directive that the full-length consenting process must be engaged with (including the risk of delays described above in section 2) resulting in communities and property being placed at immediate risk of flooding and erosion as defences are left to continue to fail until full consents are achieved.

These extra maintenance costs must be soaked up via local authority revenue pots (which are already stretched to cover all manner of other local infrastructure priorities, not just FCERM or heritage specifically) reduce the affordability of the general maintenance of coastal flood and erosion defences, risking disrepair, and increasing the risk of future failure, flood and erosion risk to communities and the damage or wholescale loss to the heritage assets themselves.

4. Conclusion

In the face of increasing climate pressure and funding scarcity it is a reality that the cost of protecting these valuable heritage assets is becoming increasingly unachievable. Without either additional funding or reform to the statutory obligations imposed on FCERM, it is clear and unavoidable that an increased loss of heritage will occur, and homes, properties and communities will be put at increased risk.

5. Recommendations

This paper puts forward the following recommendations to reduce the impact of issues described above;

• Currently the capacity for FCERM GiA to contribute to the protection of heritage is highly limited. Discussion within DEFRA and the Environment Agency with input from DCMS and HE is welcomed to ensure the historic environment is considered correctly in FCERM GiA economic cases (the Partnership Funding calculator).
• Historic England are a funding organisation in their own right, however, currently grants appear ineligible to fund or contribute directly to the protection of sites from coastal risk, or to contribute to the funding shortfall exerted on wider FCERM schemes by statutory conservation obligations. It is recommended that the role of DCMS and HE in contributing to the funding of coastal protection for heritage assets become a topic for discussion and review.
• Reform to the current consenting process should be considered in detail incorporating the following;

-          Increased dialogue between DCMS/HE with other regulating bodies such as DEFRA / EA should occur to reach agreements and form guidance which can guide solutions to scenarios where their respective statutory priorities conflict, expediating discourse on the ground and reducing delays to FCERM/Heritage conservation works.

-          DCMS/HE to consider ways in which statutory mitigations and advisories resulting from the consenting process can reach a level of standardisation in order to reduce uncertainty and discourse on the ground and improve upfront budgeting of anticipated heritage cost impacts.

-          DCMS/HE could consider the incorporation of appeal procedures and / or access to second opinions within the consenting process to ensure full opportunities to increase confidence that the correct balance between heritage conservation and FCERM priorities / feasibility has been achieved.

6. Alternatives to Protecting Heritage Assets from Coastal Erosion and Flooding

Should the additional funding and/or necessary reduction in costs for the coastal protection of heritage outlined above not be achieved, increased loss of heritage sites will become unavoidable. The discourse then must shift to how the impacts of this imminent damage and loss can be minimised and managed in such a way that is least damaging to the socio-economic landscape to which it previously contributed. To achieve this, more adaptive management techniques, approaches and practices will need to be developed and implemented.

• DCMS/HE could engage in detailed dialogue and consideration of this as soon as possible in order to develop formal guidance for FCERM regarding the circumstances, manner, costs and funding of implementing these measures and to confirm and outline the legislative framework that underpins it before the adoption of these approaches become directly imminent and unavoidable.

7. References

SCOPAC (2025) Coastal Heritage within FCERM - the Challenge of Conflicting Priorities. Hillawi, A, Coastal Partners. Unpublished at time of writing.