Submission to EAC call for evidence on climate adaptation

Introduction:

This submission is based on a facilitated conversation between a Flooded People UK policy analyst and four flooded individuals. Drawing from military and engineering backgrounds, these individuals have all, at different stages, assumed leadership in their communities for responding to disaster. 

Key message:

At a time when successful adaptation to surging flood risk increasingly requires mobilization of our population – to prepare, to adapt properties that may be at risk, to help manage flood assets, and to respond to emergencies and to achieve effective liaison with authorities at all appropriate levels – the relationship between risk management authorities and civil society seems broken.  Proactive institutional change is achievable and necessary – even under existing budgetary constraints.

1. UK preparedness for climate change  

  • a) What are the most significant climate risks facing the UK over the next 10, 20 and 50 years?  

Increased flood risks from both climate change and property development are well documented and captured by many authoritative studies. These include the Environment Agency’s National Flood Risk Assessment, the Climate Change Committee’s fourth Climate Change Risk Assessment, and the National Infrastructure Commission’s report into surface water flood risks. 

Barring significant increases in flood risk management expenditure and efficacy, rates of damage are likely to rise, the housing market will be disrupted, and many living near our coastline are likely to have to be relocated. 

  • b) Does the Government adequately assess current and future climate risks, including risks to vulnerable environments and potential ecosystem collapse?  

The government does not sufficiently assess knock-on consequences from increased flood risk in relation to mass relocation and large-scale housing market disruption. 

One study by leading experts finds that a policy of ‘holding the line’ (i.e. protecting coastal communities from flood risks) is likely to be untenable for 1,600-1,900km of English coastline by 2050. This would threaten 120k-160k residential properties. To our understanding, flood models do not price in the cost of relocating the inhabitants of those properties into their “do nothing” scenarios.  

Two recent studies examine the impact of flooding on England’s property market, arguing that flood risk directly imposes a lasting discount on properties. Large-scale changes in housing values have wide implications for the economy. It is not clear that the Environment Agency, the strategic authority for flood risks, tracks such developments and their implications for the cost of flooding to the national purse. 

The Flood Re scheme is currently successful at ensuring the availability of private insurance for high risk households built after 2008, but is set to expire in 2039. A solution for what comes next remains elusive. 

Yet beyond Flood Re, mortgage availability remains a blindspot. In 2024, Nationwide announced that it would no longer offer mortgages for an unspecified set of high risk properties. It is not clear to what extent, if any, the Environment Agency measures the impact of flood risks on the English mortgage market. 

The Bank of England has modelled the financial system implications of a rapid shift to a risk reflective insurance market. It has yet to model the consequences of direct depreciation, decreases in mortgage availability, or sudden shocks such as repeated major floods blighting entire areas.  

  • c) What lessons should be drawn from recent extreme weather, including heatwaves, drought, flooding and wildfires?  

A central lesson is that authorities are not learning lessons and that it feels to people like no one is in charge. 

Section 19 of the Flood and Water Management Act creates a discretionary power to lead local flood risk management authorities (LLFAs) to investigate incidents in order to learn from them. The Act does not specify when an investigation ought to be mandated, nor does it create any obligation to make or follow recommendations. 

Community groups have been told privately by some LLFAs that these investigations are ‘not worth the paper they are written on’ and some councils explicitly adopt a policy of not attaching recommendations to their investigations. In other cases, responsible authorities were unaware of the number of properties flooded (flooding is often not reported) and therefore misjudged whether their own discretionary thresholds for investigating had been met. 

The state of S19 investigations reflects a broader trend. Of the 92 recommendations made by the 2008 Pitt Review, it is understood that half are yet to be implemented. 

  • d) How might poorly planned adaptation create new vulnerabilities? 

Continued development in flood risk areas with few safeguards risks highly complicated situations in flood response. 

2. The Government’s approach to climate adaptation 

  • a) Is the statutory framework established under the Climate Change Act 2008 delivering effective adaptation? If not, what must be improved? 
  • b) Is the National Adaptation Programme an effective mechanism for delivering climate resilience? 
  • c) What needs to be reflected in the next National Adaptation Programme to sufficiently deliver climate resilience?  
  • d) Should the scheduled publication date of NAP4 be brought forward?  

More accountability is needed. The CCA 2008 sets up a general adaptation cycle and flood policy is mainly delivered through other legislation. Flood Risk Management sits in the Flood and Water Management Act 2010. The NAP and the FCERM strategy are separate statutory tools, and they don’t align in terms of funding, timing, or targets. 

The CCA requires the Government to present a program addressing the risks, and the CCC assesses the progress. However, it does not require flood-risk outcomes to be met.

Flooding is a quantifiable climate risk and the CCC has provided numbers on the investment needed to stop the increasing risk of flooding.

3. Measuring progress 

  • a) What indicators should the Government use to measure progress on adaptation?  

In spite of resilience being the stated goal of the 2020 policy statement, Defra has not adopted a clear and measurable definition of resilience. 

Defra and the Environment Agency are reportedly developing new metrics for measuring exposure, which disclose how many homes would be projected to flood in a simulated ‘design’ flood with an annual likelihood of 1/100. We strongly support this. 

Yet resilience is broadly understood to refer to the ability of a system not simply to avoid harm but to cope with it, recover from it, and adapt to it following an incident. Those aspects are more challenging to measure progress on and, as the adage goes, you cannot manage what you cannot measure. 

In our view, Defra should lead in developing new key performance indicators for risk management authorities’ relationships with the public. These should include measures of trust and tracking of people’s experience in resolving their issues. Instituting such metrics has the potential to shift the culture of risk management authorities and course correct towards building more trust and cohesion with the public, promoting best practices. 

Rationale:

Good relationships with the public are central to resilience. 

If England is to be resilient to floods in this sense, it must be able to successfully mobilise the public to take part in risk management to prepare for disasters, respond to them, and recover from them effectively. There are several reasons for this. Many flood risk adaptations such as drainage systems require modification to private lands. Neighbours are often the first responders and, at a time of constrained budgets, civil society often ends up ‘plugging gaps’ in authorities’ capabilities. This includes a range of measures including managing flood risk assets such as drains, and ad hoc developing more localised warning systems. 

Our shared experience of over 10 floods shows that the relationship between authorities and the public is not apt to deliver this crucial role. Resilience in the broader sense requires productive, collaborative, and trusting relationships between civil society, members of the public, and their risk management authorities. Our experience shows the opposite. 

The consensus among the flood action group community is that the risk management culture often emphasises avoiding liability and reputational harm. Civil society is treated paternalistically or with hostility. And risk management authorities are not incentivised to build trusting and productive relationships with members of the public. 

The Environmental Audit Committee has acknowledged the need to improve relations with flood action groups and integrate them into flood risk management. Yet the subsequent community engagement subgroup, part of the ministerial task force on flood resilience, did not involve widespread or meaningful consultation of flood action groups, leaving the question of what and more importantly who ‘community engagement’ is for entirely unaddressed. 

Solutions in this case must be led by civil society, which has the expertise in working with volunteers. The National Lottery, Civic Power Fund, in particular are vital nodes of expertise in how to support civil society in taking an empowered role in policy. 

  • b) What lessons can be learnt from international best practice? 

We believe that adaptation can and should learn from a broader scope of ‘resilience’ related activities. Civil preparedness for war in NATO frontline countries such as Finland and Estonia are worth studying with particular attention to the social contract between government and society underpinning shared resilience. 

4. Leadership and governance  

  • a) Does DEFRA, supported by the Environment Agency, have sufficient authority and resources to coordinate climate adaptation across Government? 

Defra and the Environment Agency have not been successful in addressing persistent challenges concerning development. As well as significantly increasing flood risk, this undermines resilience by undermining the authorities’ credibility and legitimacy in tackling the problem. Particularly in relation to surface water, the Environment Agency is increasingly inviting members of the public to personally fund property-level flood resilience, even as planning authorities approve further problematic developments.  

We are concerned by reports of 21% headcount reductions at Defra by 2029, precisely the period in which the government is attempting a highly complex introduction of flood performance certificates. 

  • b) Are responsibilities for adaptation sufficiently clear across Government departments, local authorities, regulators and public bodies?  

On the ground, the sense is one of deep disorganisation. In a recent submission to the EFRA committee, which EAC members may find interesting, we compiled testimonies of people who had experienced emergency response to flooding.

The tendency for authorities to ‘buck pass’, refusing risk management responsibilities is widely acknowledged. For example, a report by the Environmental Audit Committee acknowledged ‘systemic coordination failures that cut across multiple areas of flood risk management’. Yet, to our regret, the report’s recommendations stopped short of what was needed, recommending added resources for coordination and a single point phoneline in response to the fragmentation and lack of leadership among RMAs. 

  • c) Does the current governance of the National Adaptation Programme enable effective delivery and accountability?  

No expertise. 

5. Local government and devolved administrations  

  • a) Are local authorities sufficiently resourced and funded to manage climate risks in their existing areas of responsibility? If not, what additional support is required? 

No. Some lead local flood risk management authorities’ (LLFAs) successfully overperform by retaining staff that are capable of engaging communities respectfully. Many do not overperform. In one case, a flood risk manager approached Flooded People UK to describe a state of affairs where elected officials did not understand their duties, having cut flood budgets since the last major disaster. In other cases discussed while writing this proposal, LLFAs openly told members of civil society that they considered them ‘noise’, or adopted explicit policies of investigating floods without subsequently issuing recommendations. 

LLFAs challenges are widely understood. Defra acknowledges challenges concerning capacity to deliver their duties under the 2010 Flood and Water Management Act. The National Audit Office whose surveys have found consistent reports of under-resourcing from LLFAs themselves. So too does the Environmental Audit Committee in its latest report on flood resilience. 

Ring-fenced funding and clearer accountabilities would be useful. Yet the challenges with disjoined flood risk management are likely to result from the 2010 Flood and Water Management Act itself. The role and capacity of lead local flood risk management authorities is therefore, in our view, best thought of as part of a broader strategic reflection on the risk management landscape. 

  • b) What obstacles do councils face in preparing for and responding to risks from flooding, extreme heat, drought and wildfire? 

Flood action groups report that many authorities are overly preoccupied with avoiding liability and refuse to take into account the expertise and knowledge of community members. Some take the view that flooding issues are not theirs to fix. 

This attitude is captured in a request for proposals for community engagement, which reads, “(f)ollowing flooding incidents, residents and businesses may be highly emotional and urgently seeking explanations, often directing blame towards local councils, water companies, or the Environment Agency. Communities commonly expect authorities to “fix” the issue so that flooding does not recur. These circumstances can make engagement challenging, and careful handling is required.”

Communities do rightfully expect their authorities to lead on remedying the problem of flooding. Yet the 2010 Flood and Water Management Act is highly permissive, leaving a gap and misaligned expectations. If the role of community engagement is to promote an interpretation of the Act that dispenses risk management authorities from responsibilities to alleviate flooding, significant trust between RMAs and the public will be needed. The charities subcontracted to deliver this result will be hamstrung if the wording of this RFP captures the authorities’ attitude. 

  • c) How effectively are the UK Government and devolved administrations working together on climate adaptation?  

No comments 

  • d) What lessons can be learnt from approaches to climate adaptation taken by Scotland, Wales and Northern Ireland? 

No expertise. 

6. Infrastructure and the built environment  

  • a) Are the UK’s energy, water, transport, communications and health systems adequately prepared for more frequent extreme weather?  
  • b) What are the greatest vulnerabilities within critical national infrastructure, supply chains and essential services?  
  • c) What needs to be done to ensure current and future buildings, private and public, are adequately adapted to the changing climate? 

The current direction of travel for English policy in this area is for a market-led solution to adapting buildings. The project is to incentivise private homeowners to purchase property-level flood resilience  (PFR) measures en masse. Delivering this is a highly complex task that will require significant levels of public trust as well as the active participation of the insurance and development sector. 

Flood Re has recently commissioned research from JBA to examine which properties are and are not adequate. In our experience, such guidelines are routinely not followed. It is vital for public trust that PFR is exclusively sold in appropriate environments. Barring this, it will be seen to fail repeatedly, discouraging prospective customers. 

This process is already occurring. The infamous case of Tenbury Wells, where a flood alleviation scheme was deemed too expensive, illustrates the way that PFR schemes are rolled out after communities have been told that the optimal solution is unaffordable. This process of using PFR as an alternative to doing nothing is an obstacle to public buy-in. 

PFR can be an effective flood prevention tool when tackling shallow (<60cm) and fast flowing surface water in combination with sustainable drainage systems (SUDs) and end of pipe solutions. Its role and contribution has been modelled by the Climate Change Committee and will, we expect, be further modelled by the EA in its LTIS. 

The current strategy for ‘mainstreaming’ PFR measures relies on the introduction of Flood Performance Certificates. This process is currency led by Flood Re. FPCs have the potential to increase would-be buyers’ awareness of flood risk, discouraging development in inappropriate places. Yet they carry significant risks. 

There is the risk that FPCs are applied to properties where inhabitants do not have the means to take the measures needed to increase their ‘score’. This defeats the point of a market-led solution and will require clear signals from the government about its approach to such cases. Further, FPCs will only ever be as effective as the property-level interventions they promote. Failure cases will risk undermining trust in the system. 

The overall narrative around FPCs outstrips the facts concerning their roll out. The project is being, and must be, rolled out slowly and with deep caution. Our position remains that FPCs will only serve their full purpose in the case of a flood strategy that the public understands and trusts. As per our comments above, there remain significant challenges to achieving such a strategy.  

7. Agriculture, water and the natural environment  

  • a) Is the UK’s water supply sufficiently resilient to increasing drought risk? 
  • b) How should climate adaptation be integrated with agricultural policy and food security? 
  • c) What support do farmers need to adapt to changing temperatures, rainfall and growing conditions?  

Farmers are key stakeholders in rural communities. It is incumbent on risk management authorities to urgently improve relationships. 

There are promising schemes, which must be learned from. The Water-Friendly Farming Initiative, for instance, offers benefits to both farmers and flood risk reduction. 

Community tree planting schemes also carry cost-free benefits for some farmers and create synergies. 

  • d) How can nature-based solutions contribute to adaptation, including flood management, water security and urban cooling? 

Flood risk management has historically relied exclusively on engineered interventions such as dredging and building embankments. Over the last 10 years, there has been a concerted push for other approaches to be factored in. It is vital for this push not to obscure the need for multiple interventions, or to generate undue hype for interventions such as natural flood management. 

The consensus among researchers remains that such measures are an important part of any adaptation portfolio and can reduce the reliance and cost of engineered defences, but that they tend to underperform in more serious flood events. The Climate Change Committee’s recent modelling has reinforced this point. 

8. Communities 

  • a) Which communities and groups are particularly vulnerable to the impacts of climate change? 

Flood vulnerability refers to a given individual or communities’ susceptibility to suffer particular harm if a flood does occur. This contrasts with ‘exposure’ or simply the likelihood of a flood in a particular place. 

The ‘Neighborhood Flood Vulnerability Index’ (NFVI) remains the gold standard for understanding vulnerability to flooding in the UK. It captures a communities’ susceptibility, social resources, and capacity to prepare for, respond to, and recover from flooding. The NFVI has recently been updated by the Climate Change Committee and must be used more widely in UK policy.

A growing population of particular concern is the inhabitants of at-risk post-2008 buildings. Such buildings are excluded from the Flood Re scheme and therefore risk losing their insurance after a flood, or potentially even before them. The impacts of losing insurance are potentially catastrophic, as described in a recent and highly mediatised Public First report. Given low levels of awareness of risk, it is plausible that many of these individuals purchased their properties without fully understanding what they were committing to. 

  • b) How should adaptation policy better protect vulnerable communities?  

There is currently no policy for what should be done about Flood Re excluded properties. Defra must urgently set out a clear policy for how it proposes to manage the risk to them. 

9. Funding and investment 

  • a) Is current public investment in climate adaptation sufficient?  

Funding for flood and coastal erosion risk management is consistently below what models benchmark as necessary to keep the risk in check. The result is that the public are asked to take on more and more of the risk.

  • b) Are funding arrangements for local government adequate to deliver adaptation measures?  

They are not. See above comments. 

  • c) Does the Treasury’s approach to public investment adequately account for avoided climate-related losses? 

See our comments about ensuring that housing market disruptions are taken into account. 

  • d) What lessons can be learnt from international best practise?