Draft National Flood and Coastal Erosion Risk Management Strategy for England

While we welcome the recognition to internalise better costs to society that traditional business models have largely externalised, the FCRM national strategy must not assume the beauty of our countryside, coast, towns, most valued landscapes or the wealth of biodiversity they support, and the life-support systems they protect can be adequately valued in monetary terms.

In principle, a well-designed and ambitious net environmental gain policy with appropriate legal and administrative frameworks and safeguards could generate positive results for local places – enabling more strategic environmental outcomes to be delivered – but the FCRM national strategy must recognise that the public value of these places to people today and in the future extends beyond their monetary asset value.

The FCRM national strategy should ensure biodiversity net gain is always a pre-requisite for the achievement of the broader ambitions of securing an environmental net gain and look to see how it might be extended to cover other aspects of natural capital to take into account the full environmental costs of development schemes. This should include delivering improvements in ecosystem services, such as pollination, flood prevention, air quality, carbon sequestration, as well as connecting people with nature.

A net gain approach for the environment must be in addition to existing environmental protection, including that afforded to biodiversity and it would be inappropriate to apply a net gain approach to those irreplaceable habitats that cannot be re-created.

Often infrastructure works are promoted as a way of ensuring inward investment to an area and providing the means to boost an area’s economy, increase jobs and the opportunities for less-favoured areas, and help the more prosperous areas to cope with growth. This may be the case if the proposed investments are fully thought through but it is worth noting that economic prosperity is the result of many processes spanning a wide range of human activity and such a crude instrument cannot necessarily be expected to deliver improvements in employment, welfare, and economic progress.

Pleased to see the recognition given to the importance of soils but perhaps more needs to be made of the very real but so often ignored permanent damage to and loss of soil owing to different forms of development, which may include flooding and coastal change infrastructure.

Soil is a living system and covering it with an impermeable surface such as concrete or tarmac – known as ‘soil sealing’ – prevents it functioning naturally. Sealing reduces the multiple functions of non-developed land and soil to a single function.

This severely restricts the land’s value as natural capital or the multiple ecosystem services it can deliver. It’s important to understand the damage to the soil goes well beyond the footprint of a development and that it extends out to the neighbouring area. This will be exacerbated by the predicted effects of climate change

Biodiversity is also adversely affected by damage to soil. Healthy soil hosts an incredible diversity of life from tiny, single-celled organisms like bacteria and protozoa to fungi, insects and invertebrates and animals like moles and badgers. Land management that changes the physical and chemical properties of the soil will have a negative impact on soil biodiversity.