Foundation for Common Land position statement on Natural Flood Management

Considerable interest has been shown in the potential of Natural Flood Management (NFM) to contribute to a reduction in flooding across the UK in recent months.  This position statement sets out the views of the Foundation for Common Land (FCL) on NFM and seeks to highlight the opportunities offered and challenges presented on commoners and those who actively manage commons.  Commons are now being recognised as important areas that capture carbon, hold significant archaeology and culture activities that underpin rural communities as well as regulating both water flow and quality. 

Recent research has shown that 70% of the water drunk in Devon and Cornwall fell as rain on the Forest of Dartmoor common.  In other areas there is a significant risk of low water flow that could impact drinking water supplies. Therefore it is important to take into account the full picture when planning and developing NFM proposals. 

FCL is supportive of NFM as a contribution to the reduction in flooding.  Many of the challenges outlined in the position paper refer to how NFM is implemented rather than the techniques themselves. Where it is implemented appropriately, respecting both the wide range of public benefits that common land provides and the multiple legal interests on common land, then there is potential for multiple benefits to be gained. 

Crucially NFM is a new addition to the catchment management tool kit that has now received explicit government backing with an investment of £15 million in 2016/17.  Projects such as those in Pickering, Belford, Honicote and Stroud seem to be promising but they remain relatively new and innovative, meaning that the amount of evidence regarding their impact is limited but growing.  The recent announcement by the Environment Agency on ‘Working with natural processes’  includes a number of case studies that show a strong support for advocacy, with some qualitative knowledge and less quantification of the impact of NFM.

This statement sets out:
1. The range of interventions available under NFM
2. Why stakeholder participation is essential not optional
3. The multiple benefits of NFM
4. The role of trees and grassland management
5. Common land in relation to NFM
6. Limitations of NFM

It focuses on what FCL regards as good practice regarding the potential benefits and limitations of the NFM approach.

1. Range of NFM techniques and interventions
FCL position: Given the range of NFM techniques and interventions it is likely that it will occur on common land in many situations.  This needs careful consideration regarding the type of NFM intervention and the location as set out in this position paper.

NFM refers to a range of techniques available to government agencies, catchment groups, communities, land owners and others to attenuate or slow the flow of water as it flows through a catchment.  At its heart NFM represents a shift in thinking away from flood defence to more resilient and integrated catchment management.  Commonly, NFM involves soft-engineering techniques on a small scale that act collectively to ‘slow the flow’ and increase the availability and access to temporary water storage both above and below ground. It is important that the full range of NFM measures are matched against the potential typical locations to maximise effectiveness. These include:
• Farmyard and other areas with hard surfaces (reducing the run off from in such areas);
• Woodland and tree planting and management (targeted planning and appropriate management of existing woodlands, including tracks to reduce run off and increase infiltration);
• Adjustments to land and soil management (techniques to increase surface roughness, maximise infiltration by rainfall and minimise run-off);
• In channel works (interventions in ephemeral and permanent water bodies to reduce flow speed) e.g. leaky dams and re-meandering canalised rivers;
• Flood plain meadows and wet woodland, including coastal areas (attenuation lower down the catchment by providing surface storage areas and roughness);
• Out of channel interventions (bunds and swales in field locations and grip blocking in blanket bog restorations to slow the flow and increase surface roughness).

2. Stakeholder and community engagement
FCL position: Common land management always involves multiple interests with landowners, commoners and many others who need to be involved in the co-production of plans and co-designs of interventions at the start. We commend the use of the Collaborative Action Charter.

NFM requires a far greater degree of stakeholder engagement for two related reasons.  First, it is the collective impact of numerous small NFM interventions that is required, meaning a large area is required before reduced flood risk is achieved.  Location of NFM measures is critical, but isolated pockets of NFM activity are likely to be less effective.  Second, to achieve the large areas required each NFM project needs a shared vision at the start to develop a collective problem solving approach.  Therefore those owning and managing common land need to be able to contribute their local knowledge to ensure the right location and type of NFM measure is used.  This is the basis on which the stakeholders in Cumbria (convened by the Foundation for Common Land) proactively developed the Charter for Collaborative Action on Natural Flood Management (2016). 

3. Multiple benefits of NFM
FCL position: FCL supports NFM that enhances the multiple benefits from common land while protecting the special qualities of individual commons e.g. the cultural heritage of commoning, archaeology and biodiversity.
Current available evidence demonstrates that NFM interventions provide multiple benefits, including improving water quality and regulating water flow as well as and biodiversity.  As the Pickering and Stroud projects show, these benefits are appreciated by a range of people through direct involvement in designing and implementing interventions.  There are also benefits to climate change mitigation, for example in some cases the sequestration of carbon through NFM interventions, and it is important that all aspects in this area are recognised. An area currently receiving interest concerns changes in land and soil management, which is part of a wider movement of interest in soils, particularly soil health and building soil organic matter, by farming community.  Multiple benefits can be useful in bringing stakeholders together as all those involved in NFM will have different levels of understanding and/or a variety of concerns or priorities. 

4. Tree planting, woodlands and NFM
FCL position: FCL acknowledges that the careful management of common land can increase infiltration and attenuate the flow of water and that strategically planted trees, dams and bunds hold water and reduce landslides and sedimentation of rivers. This benefit for water flow needs to be considered alongside the range of other public benefits commons provide - grazing, recreation, biodiversity, landscape, archaeology etc.

NFM and tree planting are not one and the same, however, tree planting with the right species and management can make an important contribution.  Research on the Culm grasslands has shown that there are very high levels of stored carbon in uncultivated well-managed grassland which attenuates large amounts of water.  In some instances tree planting can be counter-productive and culturally insensitive.  Crucially the planting of trees needs to be a process involving experts and local stakeholders at the point of development to avoid unintended consequences, such as the disruption to grazing hefts.  Multiple benefits such as shelter for livestock or using locally grown species to aid biodiversity together either with a long-term management plan using local stakeholders are important.

5. The Role of common land in NFM
FCL position: Commons offer a scale for NFM initiatives that other land does not, in order to manage water supplies before they reach the river channel.

FCL is a charity whose objective is to improve the public benefits from common land.  Commons are found throughout catchments from upland source to salt marshes on coastal river mouths.  The greatest area is at the top of the catchment at and before the source of the rivers.  The partnership approach in Cumbria recognises there have been considerable changes in farming systems and that viable businesses are most likely to contribute environmental and landscape benefits to society. Since 82% of common land is in National Parks and AONBs these areas are heavily visited and enjoyed by tourists and local communities as well as providing the social fabric of the area.  NFM provides an opportunity for partnerships to develop resilient and innovative approaches when considering NFM interventions. 

6. Limitations of NFM
FCL position: NFM is important but not the only outcome that society is seeking from common land.  It is not either/or but both/and but those involved need to be wary of raising expectations that can’t be fulfilled.

Technical models, such as opportunity maps, are complex but limited in what they can cover.  Some models may not be able to recreate fine scale local conditions because models, by definition, are abstracts from reality.  Crucially they are not reality.  NFM is new and, as a result, an adaptive approach needs to be taken where local stakeholders and NFM coordinators co-develop ideas and collectively perform monitoring activity.  In some respects there needs to be a management of expectations, as Pickering shows where NFM alone does not provide the protection required but is part of the solution in combination with traditional flood protection measures.  Current evidence suggests that NFM works best in smaller catchments of less than 100km2 both in terms of the interventions and the ability to develop a strong local partnership.  For example Pontbren is 12km2 whereas Stroud is 250km2.