FDG 0004

Written evidence from the National Farmers’Union (NFU)

The NFU represents more than 47,000 farming businesses in England and Wales and, in addition, some 40,000 countryside members with an interest in the countryside and rural affairs.  

The NFU welcomes the opportunity to submit written evidence to the Environment Audit Committees inquiry into Flooding: cooperation across government.

The NFU believes that flood and coastal risk management policy and practices must be reviewed to find far more resilient ways of managing flood risk.  Our whole approach to flood risk management should be planned to cope with more extreme weather.  Our approach must also be balanced, looking at the whole catchment and must consider all interventions, including dredging, de-silting, vegetation management and engineered flood defences and natural flood risk management techniques, where needed.

It is still too soon to assess the full impact of the December 2015 rainfall and floods on agriculture, but in the winter of 2013/14 some 45, 000 ha of agricultural land were flooded, including some coastal areas, at a cost of some £19 million to the sector and in the summer of 2007 some 42,000 ha of agricultural land were flooded at a cost of some £50 million to the sector[i]. 

The NFU recognises that agriculture has a role to play in flood risk management, but a more coherent and planned approach needs to be taken to manage flood risk to protect agricultural land and rural communities, as well as urban areas.

Our interest and reasons for submission to this review are twofold:-

• We would like an opportunity to respond to evidence that the Committee has heard so far on subjects such as farmers’ role in flood mitigation and natural flood risk management; and
• We are keen to submit our own thoughts on potential areas for good cooperation across government to mitigate the impact on agricultural land and rural areas.

Value of agriculture and valuation of agricultural land

Some of our highest quality agricultural land is vulnerable to flooding:- 13% of the best and most versatile agricultural land is in the floodplain, but some 58% of grade 1 land, our most productive farmland, in England is within the floodplain[ii].

Too often at present farmland and rural communities are being sacrificed as the lowest priority when determining investment decisions to manage and improve the nation’s flood defences. As a consequence of this prioritisation rural communities and farmers experience a lack of maintenance of watercourse and coastal channels, banks and fluvial assets and as a result more frequent, more extensive and longer duration flooding. This is an unsustainable outcome.

The contribution of Britain’s farms should not be ignored if the nation is to become less dependent on food imports. The farming sector is a major employer and in 2015 the national agricultural workforce stood at 476,000. Agriculture’s importance to the UK economy is also emphasized by the fact that the UK has 142,000 businesses that are registered as farm businesses for VAT purposes. Agriculture’s performance has seen the industry contribution to the economy (in GVA terms) grow by a staggering 84 per cent between 2007 and 2014. Similarly, agricultural output has increased from £15.9bn to £25.8bn over the same time period. Farming is the foundation stone of the UK’s food and drink industry, and collectively, the UK has a total farming and food sector worth some £102 billion, the equivalent of 6.7 per cent of the GVA of the UK economy.

The NFU believes that the Outcome Measures currently used to prioritise flood defence funding towards people, property and protected habitats undervalues wider public benefits, especially in terms of high quality agricultural land, and infrastructure, such as: railways, roads, telecommunications, gas, electricity and water supply. A review of this current approach is needed to rebalance the priorities towards the true value of agriculture, rural areas, communities and critical infrastructure.

Further, because of the narrow application of the Treasury's Green Book rules and Defra’s guidance on the Valuation of Agricultural Land and Output for Flood and Coastal Defence Appraisal purposes the benefits of the defence of agricultural land are not fairly reflected in any assessment to allocate flood defence funding. This results in a valuation that is related to its land classification value and any agricultural production valued is generally assumed to be as for wheat, the most prevalent crop within the UK. No estimate is included for the consequential losses for other parts of the rural economy, for the food chain, or for the opportunity cost of lost domestic production replaced by imported food.  

Therefore the NFU believes that there is an urgent need to review the current guidance to ensure that farmland is properly valued in terms of its long term benefit to society rather the present situation where a discounted market value is applied. Critically, consideration must be given to the future value of agricultural production.

Impacts of storms Desmond & Eva on agriculture

As a result of Storms Desmond & Eva, unprecedented amounts of rainfall fell on a large area over a short time period, affecting parts of northern England.  Meteorological office figures show that December 2015 was the wettest for over a century, with estimated statistics showing a 191% of average rainfall (230mm) in northern England, northern Wales and southern Scotland. 

Many of the immediate problems affecting our farming members following these storms included damage to critical infrastructure, such as loss of power, impassable roads and bridges deemed unsafe to cross.

Problems persisted even as flood waters dispersed and many experienced difficulties as rocks, gravel and other debris were deposited on farmland and highways, livestock were lost and property and buildings were damaged.

It is still too soon to outline the full cost and impact of the storms and flooding, but the Cumbrian Farm Flood Action Group[iii] contacted 1,000 farmers, of whom 220 completed a detailed survey.  Results released in early February 2016 showed that of those:

• 63% of those surveyed lost sections of watercourse bank sides;
• 37% lost walls;
• 14% lost hedgerows;
• 38 farmers reported 701 sheep deaths between them and in addition 16 farmers reported a total of 189 sheep missing; and
• 53% reported river stone/gravel deposit and 22% have had land slips.

The loss experienced by 144 farmers taking part in the Cumbrian survey has been estimated to be some £1.7 million.

While the exact area of agricultural land impacted by flooding in Northumberland and Yorkshire has been significant, it is still too early to assess the financial cost to farming.  In addition, many weeks on, some low-lying arable and horticultural areas in West Lancashire and Yorkshire still remain flooded, in some cases affecting high value crops[iv]. 

Natural flood risk management

The December 2015 flooding can be characterised from other recent floods because of the focus placed on natural flood risk management techniques. 

The NFU recognises that natural flood management techniques, in the right location, can have a role and there are a number of examples of natural flood risk management schemes that farmers are already participating in and contributing to. These include tree planting, river restoration on the River Eden[v] and the establishment of woody dams to trap sediment and reduce in-river deposition[vi].

However, natural flood risk management measures are not the universal panecea.  We must recognise that the extent of flood attenuation provided by these measures cannot mitigate against all rainfall events and certainly not the extreme events experienced in large areas across the north of England during the winter of 2015/16.

Further, we believe that these should only be used as part of a cohesive and carefully planned series of interventions across a catchment, looking at upstream attenuation and downstream conveyance.

Compensating farmers for flooding agricultural land

The Defra Secretary of State, Liz Truss, recently commented that Defra would ‘consider’ paying compensation to farmers to flood their land using Common Agricultural Policy (CAP) Pillar II funds.

In some situations agricultural land may offer a solution to flooding elsewhere. This may include natural flood risk management techniques discussed above, and also ‘flood storage’ in low-lying areas, but holding back water on agricultural land does not come without its own costs and repercussions, such as lost crops or damaged grassland, or even water contamination. 

Some farms have endured 4 major flood events in as many years (November 2012, December 2013, January 2014, December 2015), with devastating impacts upon their business.

Therefore we believe that flooding on agricultural land must be managed:-

• properly planned and considered alongside other flood risk solutions such as engineered flood defences and the maintenance of watercourses;
• in the right location, backed by a strong science & evidence base; 
• properly rewarded through appropriate financial support;
• able to go hand in hand with agriculture’s role in producing food and supporting rural economies;
• voluntary, rather than a requirement;
• undertaken with full consultation, engagement and agreement with farmers; and
• able to work for both land owners and tenants.

In terms of the suggestion to use Pillar II monies, there are already numerous demands on this funding so we are sceptical that sufficient action can be funded from this budget. Furthermore, Pillar II schemes are competitive and geographically targeted scheme, so we are unsure that farmers in the right areas will be able to enter.  

In addition, strict EU funding rules for Pillar II scheme require that farmers are only paid for changes in their usual cropping or farming system and for any loss of grassland and crops if the land was flooded. It doesn't pay for the on-going service which benefits the wider economy and society. As Pillar II only relates to cost of production loss, we question whether this is the right funding source.

Instead, we believe that government ought to look at funding mechanisms which truly value the flood mitigation services provided and help farmers continue producing food – whether in the uplands or in more low-lying areas.

A recent guide published by the Scottish Environment Protection Agency on natural flood management[vii] shows that no one size fits all when it comes to funding mechanisms and schemes can be funded in different ways including using rural development funds, but also using river restoration funds, local authority grants, Heritage Lottery funds and EU Life funds. 

The Rural Payments Agency

In the immediate aftermath of Storms Desmond & Eva, the NFU welcomed many of the pragmatic decisions made by the Rural Payments Agency (RPA), on matters such as inspections, to allow farmers to focus on the flood recovery operation. 

Furthermore, the NFU welcomed the quick launch of the Farming Recovery Fund[viii] worth between £500 and £20,000 for farms affected in certain areas of northern England.  The Fund will help to help restore damaged agricultural land and cover farmers’ short-term uninsured recovery costs, such as repairing damaged soils, tracks and flood channels although we are continuing to call for the extension of the fund to cover the whole of northern England.

In addition, whilst the Farming Recovery Fund can cover re-seeding of grasses, apparently Commission rules dictate that arable and horticultural crop losses cannot be covered. Outside of the farming recovery fund, clarity is needed on help government can give to arable and horticultural producers affected by the recent storms.

We are aware that some farmers affected by the storms have received their BPS payments, but many payments are still lots outstanding.  Cash flow is needed to ensure that farmers can carry out the necessary recovery work as soon as possible.  The NFU continues to call for Basic Payment Scheme (BPS) payments to be made to those in the flood affected areas as quickly as possible. 

Investment in flood defence

Investment in the maintenance of our watercourses and assets and structures is of great importance to the NFU.  In November 2014, the National Audit Office (NAO) published a report on Strategic Flood Risk Management[ix] warning that spending on managing flooding in England was "insufficient" to maintain defences.

The NFU is concerned that there is currently an imbalance between the investment being made by government in capital schemes, or the construction of new flood defences, and in the maintenance of existing defences, including the conveyance of our main river network by the Environment Agency, particularly in lowland areas.  Good and continued investment in maintenance is critical to maintaining the life span of capital investments. 

Our exposure to more frequent extreme weather events in this country and the greater risk of flooding justifies an increase in total public spending in both capital and maintenance activities, although we believe that a first step could be for the Treasury to allow greater flexibility for the Environment Agency to transfer monies between these funds.

At the same time sufficient flexibility in funding is needed to enable the Environment Agency to ‘invest to withdraw’ by:

• putting assets or drainage systems back into good condition before handing over to local bodies or riparian owners, and/or
• investing sufficient time and effort in the formation of local management solutions or cooperation and coordination between riparian owners.

By investing in this manner will enable greater long term savings to the taxpayer to be realised as management solutions that are more financially sustainable are delivered.

In some lowland areas of Lancashire and Cumbria new Internal Drainage Boards (IDBs) are being considered as the preferred option to help manage water levels to benefit local areas, but there progress is being slowed by concerns over the local authority contribution.  We believe that greater consideration needs to be given to how local authorities can be supported with the additional interim costs, or new burden, of IDBs in their areas. 

On another point, tax allowances are currently available to businesses who contribute funds towards Flood Defence Grant in Aid (FDGIA) funded, Environment Agency-led schemes, including contributions in kind.  Greater private investment could be encouraged by broadening the scope of this tax relief to cover all capital and maintenance flood defence works that have been consented, not just for FDGIA funded, Environment Agency-led schemes.

We have seen good models of greater co-operation across flood risk management authorities to address flood risk.  An example is the Flood Partnership Framework in Lincolnshire.  The Environment Agency, Lincolnshire County Council, 14 Lincolnshire IDBs, District Councils, Anglian Northern Regional Flood & Coastal Committee, 2 water companies, Natural England and Lincolnshire Resilience Forum co-ordinate their local delivery to ensure that local communities and infrastructure are better protected from flood risk.  This Flood Partnership model is one that works well in Lincolnshire, but could also work elsewhere.

Although the floods in December 2015 largely affected inland areas, the tidal surge in December 2013 affected some 500-700 ha of high value agricultural land where defences were breached or over-topped.  Improving coastal flood defences is vital to protect agricultural land and rural communities from tidal surges and rising deal levels.  For example, Lincolnshire produces 25 % of all UK-produced vegetables , supports agri-food industry worth £1 billion annually, is home to 225, 000 people and handles a high proportion of UK offshore gas imports.

Climate change projections

The chart below provides a good overview of the changes in annual rainfall totals for the UK since 1910.  There is some suggestion that the previous 30-year period (1950-1980) had lower annual rainfall than the current 30-year period (1980-2010) and that rainfall has increased over the latter period and seemingly continuing to do so.  However it seems that the variability in recent years has increased.

With or without climate change there have always been exceptional spells of weather and there always will be, but warmer air can hold more moisture and warmer oceans increase the moisture content of the atmosphere.  2015 is the world’s warmest year on record. Fifteen of the 16 hottest years on record have all been this century and 2011-15 is the warmest five-year period on record.  As the Met Office chief scientist said after the December floods “it’s possible that climate change has exacerbated what has been a period of very wet and stormy weather arising from natural variability.”

The government is sponsoring an update of the climate projections, UKCP18.  The NFU will sit on the Non-Government User Group.  There were three key sources of uncertainty in the last projections, UKCP09 which will still be relevant for the next set, namely natural climate variability, uncertainty in the climate models and uncertainty in rates of future emissions.  A shift towards generally wetter winters is expected, but the future response of UK summer rainfall is less well-understood. UKCP09 suggested that there is a greater likelihood that summers will be drier, but wetter summers are not ruled out. Nevertheless, whatever happens to seasonal averages, a greater fraction of precipitation is expected to fall as heavy events. Whilst modelling has come on leaps and bounds, it can only take us so far, perhaps especially on rainfall.

Rather than dealing with too much water and too little water in isolation, we do believe that it would be worth government and its agencies bringing these aspects together and dealing with better water management.

Conclusion

In conclusion, we believe that better cooperation between government and its agencies could help prevent future flooding, but also help with the recovery from the impact of flooding.

In terms of on the ground delivery, a variety of solutions are needed and there is no ‘one-size-fits-all’ approach, but there are good models of cooperation and engagement, such as the Lincolnshire Partnership Framework.

However, more cooperation is needed to

• recognise the value of agricultural land and other rural areas;
• increase investment in flood defence, particularly maintenance activities;
• remove barriers to flood management solutions, such as managing flood management assets for the long term or supporting local authorities to help fund new IDBs; and
• manage water, rather than ‘flooding’ or ‘droughts’.