Eastbourne & District Friends of the Earth has submitted a response to the consultation launched by East Sussex County Council about its Draft Local Flood Risk Management Strategy for the period 2106-2026:
There has been no inclusion in the strategy of many of the techniques for rewilding the landscape in order to increase flood protection, such as dramatically increasing the number of trees planted in the upper reaches of catchment areas. Groups such as Sussex Wildlife Trust would be crucial in helping to create such a landscape-scale strategy for creating natural flood protection features, and should be consulted with extensively in order to maximise the contribution rewilding can make to local flood resilience. Also, there is no mention of the need to develop strategies for worst-case scenarios, such as the sea breaking through the sea defences into the Pevensey Levels, causing extensive flooding far inland. This scenario becomes increasingly likely as climate change accelerates. There may be a need to think about letting the sea come inland in a managed way, such as has happened in Pagham Harbour, where part of the sea defences were deliberately taken away so as to allow the power of the sea to be dissipated over a wide area, away from populated areas. The present sea defences are predominantly shingle-based, and not sustainable in the long-term, and as your strategy implicitly admits that in a time of austerity funding for bigger, harder defences are not likely, it is crucial to start thinking about radical options such as a managed retreat from the coast.
Furthermore, the strategy is negative in its vision of flood resilience, as it passively accepts the subordination of planning and funding for flood resilience to the strategic priority of central government to impose austerity measures in order to reduce the national debt. Apart from the fact that austerity is a failed policy and the national debt is increasing rather than decreasing, your strategy will fail if, despite the increased climate risks you admit to in the draft strategy, spending on flood defences and flood resilience measures remains less than it should be because of austerity restrictions. If spending needs to be at a certain level to ensure adequate flood resilience, then that level must be achieved, regardless of what the economic imperatives of central government are. The need to protect the lives and livelihoods of the residents and businesses of East Sussex are too important to be put at risk by a slavish subservience to the current economic nostrums of central government. Furthermore, making funding for essential projects dependent upon finding enough local partners to contribute towards them creates too much uncertainty for those projects and could pose too much of a burden for local communities to bear. Indeed, instead of perceiving flood resilience as just another burden upon ever reducing local government budgets, the need to increase flood resilience should be seen as an opportunity to help in the economic development of the area, helping to bring jobs and income into local communities as part of an integrated local economic strategy and helping to increase the quality of life for local residents through improvements and additions to the stock of natural capital in East Sussex. Too often nature and the environment is seen as an externality to economic development, whereas natural capital is crucial to, and underpins, all other forms of capital investment – something that will become ever more apparent as climate change intensifies. The strategy also puts too much reliance upon SuDs (sustainable urban drainage systems) as a way of increasing flood resilience. However good the SuDs techniques that are embedded in planned developments, they will not suffice to overcome the still excessive number of developments being built on, or very near, to flood plains and areas at high risk of flooding. Also, the sheer number of new housing developments being built, and planned, especially for the southern part of East Sussex means that existing infrastructure, such as sewage, roads, etc., won’t be able to cope with a drastically increased run-off in intense rainfall events, especially as climate change intensifies. There is no recognition in the strategy that there is a limit to how many new homes should be built in those parts of East Sussex that are already at great risk from flooding and which are particularly vulnerable to climate change. This will store up huge problems for the future, especially when sea level rises dramatically, and the frequency and intensity of storms increases significantly.
The consultation period has now ended, and we await ESCC’s response. Meanwhile, here’s an excellent 5-point plan by The Wildlife Trusts for working with nature, not against it, when planning for greater flood resilience.