Aligning Flood & Coastal Erosion Risk Management (FCERM) and Well-being in Wales – An analysis and evaluation of FCERM governance

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Context

An estimated 245,000 properties are currently at risk of fluvial, coastal and surface water flooding in Wales, with coastal erosion affecting a further 400 properties along the Welsh coastline. These risks will be exacerbated in the future by climate change and sea level rise. This presents both challenges and opportunities for delivering the aspirations of the Well-being of Future Generations (Wales) Act 2015 and the national well-being goals.

Examining the relationship between Flood & Coastal Erosion Risk Management (FCERM) and well-being, this research highlights the strengths and weaknesses in current FCERM governance, while identifying the synergies and conflicts between FCERM and the national well-being goals. The research draws from in-depth policy and legal analysis of approximately 200 documents, as well as 47 interviews with policymakers and practitioners operating at national and local scales. The findings were further validated through a stakeholder workshop in July 2019.

Key strengths and weaknesses in FCERM governance

Strategic direction

STRENGTHS

• Holistic, diversified, risk-based approach is reinforced in national policy and is key for societal resilience
• Discursive strength and growing expectations towards multi-beneficial initiatives

WEAKNESSES

• Adaptation is not specified as a strategic objective in the revised National FCERM strategy
• National FCERM strategy lacks ambition
• Absence of explicit well-being objectives and limited perspective on well-being goals in the National FCERM strategy

Ecosystem resilience

Strengths

• Environment (Wales) Act 2016 mandates Sustainable Management of Natural Resources (SMNR), with strong compatibility with FCERM objectives
• Area statements could facilitate SMNR and collaborative working
• Natural Flood Management (NFM) must be shortlisted for FCERM schemes
• National Habitat Creation Programme (NHCP) provides compensatory habitats for FCERM schemes

Weaknesses

• Slow delivery of NHCP due to challenges including multiple land /asset owners, misaligned planning cycles and legal duties (related to care and Public Rights of Way)
• Expensive to realign and decommission existing assets for compensatory habitats

Coastal adaptation

Strengths

• Long-term planning policies outlined through Shoreline Management Plans (SMP2) and new requirement on Coastal Groups to report on action plan progress
• Newly established Wales Coastal Monitoring Centre (funded until 2022) to support evidence-based decisions
• Examples of frameworks for navigating adaptation processes (e.g. Fairbourne and Newgale), which actively involve communities and adopt long planning horizons

Weaknesses

• Lack of governance mechanisms /policy instruments to enable adaptation, with calls for strategic support from Government
• “Adaptation gap” in FCERM funding and budget silos
• Non-statutory status of SMP2 conflicts with Highways legislation and duties to maintain Public Rights of Way
• ‘Difficult conversations’ demand proactive, sustained and meaningful engagement (not consultation), that places communities at the heart of decision-making

Funding

Strengths

• Medium-term capital commitments in FCERM programme and CRMP to support loner-term planning and efficiency savings

Weaknesses

• Funding is primarily allocated to protect people and property which is ill-suited to adaptation schemes, leaving an ‘adaptation gap’
• Wider benefits and well-being contributions receive lowest weighting in scoring criteria for funding
• Shortfall in revenue funding to support wide range of FCERM activities

Spatial planning

Strengths

• Guidance on Development and Flood Risk (TAN 15), which adopts a precautionary approach, according to flood zone and vulnerability of development
• Flood Consequence Assessments (FCA) required for Flood Zone C, alongside Justification and Acceptability tests
• Numerous weaknesses are addressed by revised TAN15 (under consultation), including merger with TAN14 (‘Coastal Planning’) and stronger emphasis on use of Strategic FCA

Weaknesses

• Local Planning Authorities not formerly required to adhere to NRW advice (although call-in powers in place)
• Significant limitations of current approach e.g. detachment from TAN 14 and criticisms of Development Advice Maps (e.g. different flood zones and thresholds to NRW’s Flood Map) (although many of these are addressed in revised TAN15)

Community preparedness and emergency management

Strengths

• Strengths of Flood Awareness Wales
• Increased coverage of warnings and automated services
• Community flood planning strongly advocated & supported
• Effective arrangements for activating and scaling-up emergency response according to subsidiarity principle, with further clarity provided by the Wales Flood Response Framework

Weaknesses

• Criticism that community engagement focuses too heavily on outputs (i.e. community flood plans), rather than the process of effective engagement
• Engaging and empowering communities on matters of coastal adaptation requires alternative ways of working and resourcing
• Scope for increasing involvement of the voluntary sector

Flood insurance

Strengths

• Flood Re ensures access to affordable insurance
• Post-2009 properties exempt from Flood Re (i.e. discouraging inappropriate development)

Weaknesses

• Hard incentives within Flood Re are unlikely to drive significant change in householders’ behaviours
• Risk that Flood Re is seen as the panacea, or may undermine urgency required to ready communities for risk-reflexive pricing

Surface water

Strengths

• Clearer distribution of responsibilities since the Flood and Water Management Act 2010
• Implementation of SuDS Approval Bodies (SABs) in Jan 2019, requiring sustainable urban drainage for new developments
• Regulatory incentives to encourage consideration of SMNR and long-term planning in Welsh water companies

Weaknesses

• Too early to establish effectiveness of SABs in practice
• Potential difficulties establishing an institutional cultural shift in the water industry and embedding long-term planning within 5-yearly Asset Management Periods

Land use management

Strengths

• Proposed Sustainable Farming Scheme to reward environmental outcomes, including flood mitigation benefits
• Conditional payments better incentivise a wider range of activities than universal income currently provided through CAP

Weaknesses

• Conditional payments better incentivise a wider range of activities than universal income currently provided through CAP
• Conditional payments better incentivise a wider range of activities than universal income currently provided through CAP

Marine management

Strengths

• Welsh National Marine Plan includes policies related to coastal adaptation, including reference to SMP2s
• Marine Planning Decision Makers Group supports integration across policy areas
• Marine licensing for coastal defences takes into account SMP2 policies

Weaknesses

• Lack of engagement between terrestrial and marine planners
• Resource constraints limit opportunity and capacity for collaboration & integration between FCERM and Marine management

Recommendations

Below are the top 3 recommendations from each area. [For full set of recommendations, please access the original text].

Strategic matters

1. There is a need for urgent action in the current climate emergency – Welsh Government should strengthen its strategic policy around coastal adaptation and display a greater sense of urgency when developing and implementing adaptation planning. Longer-term adaptation should be better embedded within the risk-based paradigm of FCERM, forming an explicit objective within the revised National Strategy for FCERM in Wales, alongside specific adaptation-based measures to provide greater clarity to all stakeholders (including the public) about the future. Longer-term ambitions should be clearly stated.
2. Reframing problems and solutions – FCERM should be understood as a key component of climate change adaptation and as part of a wider social, economic and environmental challenge that demands a diversified approach, in addition to protective measures. Climate change adaptation should be given the same level of priority within Welsh Government as climate change mitigation and decarbonisation goals.
3. There is a current lack of clarity in how Welsh Government understands and expresses the contribution of FCERM to the well-being goals. Stronger leadership from Welsh Government is essential if it is to maximise its strategic steering capacity. Welsh Government should specify well-being objectives within the National FCERM Strategy and consider specific measures for monitoring progress against these.

FUNDING

1. Diversifying funding sources and establishing ‘funding partnerships’ will be essential for maintaining and enhancing FCERM and wider well-being benefits in the face of future threats. Further research is required to better understand how this might be implemented, barriers addressed and action incentivised.
2. A boost and long-term commitment to revenue funding is required to keep pace with the rising demands facing FCERM associated with climate change.
3. Prioritisation of FCERM capital funding should reconsider the weighting assigned to multiple benefits in order to better incentivise delivery of wider well-being goals. This could vary depending on different categories of FCERM schemes.

COASTAL ADAPTATION

1. Long-term funding for the Wales Coastal Monitoring Centre should be secured beyond 2022 to maintain a strategic approach to coastal monitoring, essential for supporting evidence-based decision-making.
2. There is a need to raise the profile of SMP2s amongst a broader remit of stakeholders operating at national to local scales, in order to better embed shoreline management in strategic planning at the land-sea interface. This could be supported by efforts to diversify and motivate wider participation within Coastal Groups (e.g. Network Rail, National Trust and other relevant Local Authority departments). The Wales Coastal Group Forum is well-placed to develop a communication strategy to support this endeavour.
3. To sustain the valuable role played by Coastal Groups, and ensure regular attendance from local authority members, there is a need to investigate options for overcoming resource constraints and opportunities for pooling resources.

ECOSYSTEM RESILIENCE

1. Area Statements have the potential to increase opportunities for co-delivering FCERM projects and delivering schemes with flood-related benefits through alternative funding sources. However, it will be important to monitor and evaluate the extent to which Area Statements, once adopted, perform as intended.
2. Resources to support periodic monitoring of area-based approaches will be essential to establish evidence and confidence in new approaches. However, the lack of evidence should not be a barrier to trialling experimental approaches – opportunities to experiment, innovate and learn are essential for enhancing capacities to adapt to future change.
3. Coastal squeeze presents a significant threat to intertidal habitats and the integrity of the Natura Network; however, the delivery of compensatory habitat through the National Habitat Creation Programme (NHCP) is notoriously complex and faces numerous barriers related to working with multiple landowners (with different priorities, planning horizons and remits of responsibility); navigating legal duties to maintain public rights of way and duties of care; reputational risks; and lack of awareness of the implications of SMP2 amongst land/asset owners. In order to keep pace with sea level rise, these barriers will need to be overcome by – a) continued proactive engagement with landowners and service providers to identify potential sites for compensatory habitat early on; b) continuing to promote exception clauses for inviting non-Risk Management Authorities to participate in the NHCP; and c) addressing Recommendations 10, 12, 14 & 18.

FCERM, land-use management and land-sea integration

1. The significant weaknesses in Technical Advice Note 15 (Development and Flood Risk) are largely addressed through the proposed changes outlined in the current consultation of TAN 15 (Development, flooding and coastal erosion); subject to acceptance, these changes will offer better-integration across terrestrial and coastal systems. Some potential gaps exist in relation to the development of Strategic Flood Risk Assessments – engagement with Coastal Groups should be explicitly encouraged in order to better bridge coastal management and spatial planning, and strengthen the role of spatial planning in adaptation efforts. Moreover, the Welsh National Marine Plan should be cited and referred to as a source of evidence to further support joined-up thinking at the land-sea interface.
2. Periodic monitoring of the newly-implemented SuDS Approval Bodies (SABs) is essential to ensure their effectiveness is optimised.
3. Further research is required into appropriate mechanisms for promoting behavioural change and the uptake of property-level resistance and resilience measures, looking across potential mechanisms within FCERM, spatial planning, building regulations and insurance sectors, for example.

ALIGNING FCERM AND WELL-BEING

1. Push and pull messaging – There is a need for the FCERM community and National FCERM Strategy to better articulate the wider well-being benefits of their activities to attract engagement from others.
2. Public Service Boards have the potential to play an important part in FCERM governance and facilitate joined-up working. However, the extent to which flooding (and climate change adaptation more widely) has been embraced by PSBs is ad hoc. More effort is required to raise the profile of FCERM within PSBs and local well-being plans. NRW as a statutory member of PSBs could facilitate this. At the national scale, climate change adaptation should be included as a strategic priority within the Future Generations Commissioner’s priority areas to better promote its inclusion in well-being planning at the local scale.
3. Efforts should be sustained (and promoted further) within the FCERM community to support the education of children and young adults about flood and coastal erosion risks and climate change, and also cultivate a sense of global responsibility.

Citation

Plymouth Marine Laboratory. 2019. FCERM Governance in Wales: Policy Brief. November 2019. Plymouth: PML. https://pml.ac.uk/wp-content/uploads/2024/09/Policy-Brief_FCERM-governance-in-Wales_Nov2019.pdf